Text

Joint Affidavit of GG Baker,Dr Buchanan,Jj Byrne,Ta Grace, Je Tarpinian,Cs Urland & Ww Weaver (Contentions 1,2,3 & 8).* Supporting Documentation Encl
	ML20154E247
Person / Time
Site:	Three Mile Island
Issue date:	05/13/1988
From:	Baker G, Buchanan D, Byrne J, Grace T, Tarpinian J, Urland C, Weaver W; GENERAL PUBLIC UTILITIES CORP.
To:	;
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEN. SING 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) )

)

JOINT AFFIDAVIT OF DR. GARY G. BAKER, DAVID R. BUCHANAN, JAMES J. BYRNE, THOMAS A. GRACE, JAMES E. TARPINIAN, CHARLES S. URLAND, JR., AND WILLIAM W. WEAVER (CONTENTIONS 1, 2, 3, AND 8) l l

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,C,- Th e TABLE OF CONTENTS INTRODUCTION........................................... 1 THE GPUN PROPOSAL...................................... 6 ON-SITE SOLIDIFICATION WITH OFF-SITE BURIAL........... 19 OFF-SITE EVAPORATION.................................. 27 DISTILLATION (CLOSED CYCLE FVAPORATION)

AND SOLIDIFICATION.................................. 30 I

INTERIM MONITORED ON-SITE STORAGE IN TANKS............................................ 42 INSIDE CONTAINMENT STORAGE............................ 45 1'

CONCLUSION............................................ 54 i

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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 ) Generated Water)

Station, Unit 2) )

JOINT AFFIDAVIT OF DR. GARY G. BAKER, DAVID R. BUCHANAN, JAMES J. BYRNE, THOMAS A. GRACE, JAMES E. TARPINIAN, CHARLES S. URLAND, JR., AND WILLIAM W. WEAVER (CONTENTIONS 1, 2, 3, AND 8)

County of Dauphin )

) ss:

Commonwealth of Pennsylvania )

Dr. Gary G. Baker, David R. Buchanan, James J. Byrne, Thomas A. Grace, James E. Tarpinian, Charles S. Urland, Jr., and William W. Weaver, being duly swora according to law, depose and say as follows:

INTRODUCTION

1. My name is Dr. Gary G. Baker. My business address is P.O. Box 480, Middletown, Pennsylvania, 17057. I am employed by GPU Nuclear Corporation ("GPUN") as Manager, Environmental Con-trols, at Three Mile Island Nuclear Station. In that position, h

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which I have held since January, 1983, I am responsible for effluent dose assessment and environmental dose assessment for licensing submittals. An environmental scientist with more than 8 years of experience in the nuclear industry, I have worked in various radiological and environmental positions for GPUN (and its predecessor). A summary of my professional qualifications and experience is attached hereto as Exhibit "A."

2. My name is David R. Ruchanan. My business address is P.O. Box 480, Middletown, Pennsylvania 17057. I am employed by 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 TMI-2 Division. A mechanical engi-neer with more than 24 years of experience in the nuclear indus-try, I have worked in various engineering positions for GPUN (and its predecessor) in support of the reccvery effort at TMI-2 since July, 1980. I previously spent over 16 years in engineering work at Westinghouse Electric Corporation's Bettis Atomic Power Labo-ratory. A summary of my professional qualifications and experi-ence is attached hereto as Exhibit "B."

3. My name is James J. Byrne. My business address is P.O.

Box 480, Middletown, Pennsylvania 17057. I am employed by GPUN

! as Manager, TMI-2 Licensing. In that position, which I have held since September, 1982, I am responsible for coordinating and su-pervising the technical efforts necessary to obtain Nuclear l

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Regulatory Commission ("NRC") approval for ongoing recovery ac-tivities. A licensing engineer with more than 12 years of expe-rience in the nuclear industry, I have worked in various licens-ing engineering positions for GPUN and its contractor, Quadrex Corporation, in support of the recovery effort at TMI-2 since July, 1980. I previously worked as a licensing engineer for Sargent & Lundy Engineers for two years. A summary of my profes-sional qualifications and experience is attached hereto as Exhibit "C."

4. My name is Thomas A. Grace. My business address is 1 Upper Pond Road, Parsippany, New Jersey 07439. I am employed by GPUN as a Corporate Environmental Licensing Engineer. I have held this position since March, 1981. I have over 9 years expe-rience in the nuclear industry. I am responsible for ensuring that GPUN's operation of its plants satisfies the applicable stste and federal environmental licensing laws and regulations.

A summary of my professional qualifications and experience is attached hereto as Exhibit "D."

5. My name is James E. Tarpinian. My business address is

( P.O. Box 480, Middletown, Pennsylvania 17057 I am employed by 1

Bechtel Construction Inc. as Manager, Radiological Engineering

( for GPUN's Radiological Controls Department at Three Mile Island Nuclear Station, Unit 2. In that position, which I have held since September, 1986, I am responsible for radiological engi-i i neering, effluent monitoring, radiation analysis, and external l

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l dosimetry assessments. I have 13 years of experience in applied health physics and radiation protection primarily associated with nuclear power facilities. A summary of my professional qualifi-cations and experience is attached hereto as Exhibit "E."

6. My name is Charles S. Urland, Jr. My business address is 15215 Shady Grove Rd., Rockville, Maryland 20850. I am em-ployed by Grove Engineering, Inc. I have served as a contractor-consultant at Three Mile Island Nuclear Station, Unit 2 for the past four years. During that time, I have advised GPUN on mat-ters related to radioactive vaste management. A summary of my professional qualifications and experience is attached hereto as Exhibit "F."

7. My name is William W. Weaver. My business address is P.O. Box 480, Middletown, Pennsylvania 17057. I am a self-employed consultant for GPUN at Three Mile Island Nuclear Sta-tion, Unit 2. I am respons.ble for developing probablistic risk assessments for TMI-2. I have over 12 years experience in the t

field of probablistic risk assessment. I previously was supervi-sor of probablistic risk assessment at Babcock & Wilcox Company.

A summary of my professional qualifications is attached hereto as Exhibit "G."

3. We make this Affidavit in support of Licensee's Motion for Summary Disposition of Contentions 1, 2, 3 and 8. We have personal knowledge of the matters stated herein and believe them to be true and correct.1#

1/ The particular affiant for each paragraph, where appro-priate, is identified by that individual's initials.

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9. The Joint Intervenors allege that the NRC failed to consider or consider sufficiently five disposal alternatives for the 2.3 million gallons of AGW. Those alternatives are:

(1) on-site solidification with off-site burial; (2) off-site evaporation; (3) distillation (closed cycle evaporation),

(a) on-site solidification and burial, (b) on-site solidification and off-site burial; (4) interim, monitored on-site storage (30 years in tanks);

(5) permanent in-containment disposal in tanks.

10. We vill first review GPUN's proposal to evaporate the AGW. This review will include a description of the disposal sys-tem, the content of the AGW, the radiological dose estimates, the projected vaste management and transportation mechanisms, the en-l vironmental impacts and the costs f,or GPUN's proposal. We then vill examine each alternative put forward by the Joint Interve-l nors. This examination vill cover the transportation require-ments, radiological effects, environmental impacts, licensing feasibility, and costs of each option. Finally, we vill compare GPUN's proposal with the five alternatives the Joint Intervenors have put forward.

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THE GPUN PROPOSAL

11. GPUN's proposal for disposal of the AGW calls for forced evaporation followed by vaporization and atmospheric re-lease of the product distillate. The GPUN proposal also includes the separation and final treatment of the solids removed and col-lected during the evaporation process and the preparation of the resulting vaste product for shipment and burial at a commercial low-level vaste facility. A detailed description of the system and evolutions which will accomplish the controlled disposal of the AGW is attached as Exhibit B (hereinafter "the System De-scription") to the Affidavit of David R. Buchanan (Buchanan Affi-davit) in support of Licensee's Motion for Summary Disposition on Contentions 4b (in part), 4c, and 4d and is incorporated herein by reference. (DRB]

12. On February 27, 1980. an agreement executed among the City of Lancaster, Pennsylvania, Metropolitan Edison CompanyE !

and the NRC defined "Accident Generated Water" (AGW) as:

a. Water that existed in the TMI-2 Auxiliary, Fuel Handling, and Containment buildings including the primary system as of October 16, 1979, with the exception of water which as a result of decontamination operations be-comes comingled with non-accident generated water such that the commingled water has a tritium content of 0.025 uCi/ml or less before processing.

2/ GPU Nuclear Corporation is the successor licensee to Metro-politan Edison Company.

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b. Water that has a total activity of greater than 1 uCi/ml prior to processing except where such water is originally nonaccident water and becomes contaminated by use in cleanup.

c. Water that contains greater than 0.025 uCi/ml of tritium before processing.

The average characteristics of the AGW are presented in Table 1.

The data in Table 1 is based on information contained in GPUN's July 1986 Report. At that time, the AGW volume was 1.9 million gallons, and it was assumed that 40% of the water would be con-sidered for further processing. The data in the July 1986 Report with assumed reprocessing of 40% of the water was extrapolated to 2.3 million gallons (31% of 2.3 million gallons). (DRB]

TABLE 1 AGW CHARACTERISTICS (Based on processina 31) of the total volume)

Volume 2,300,000 Gallons Tritium: Concentration .12 uCi/ml i

Total 1020 Ci <

Cs-137: Concentration 3.79E-5 uCi/ml Total 0.33 Ci Sr-90: Concentration 1.06E-4 uCi/ml Total 0.92 Ci Boron: Concentration 3000 ppm Total 150 Tons H3BO4 Sodium: Concentration 700 ppm Total 11 Tons NaOH l

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13. The above radionuclide characteristics are representa-tive of the expected influent feed to the evaporator and are based on an assumed requirement to further process approximately 31 percent of the water prior to evaporation. While tritium (1,020 curies) is the dominant radionuclide in the AGW in terms of quantity, the most radiologically significant of the de-tectable radionuclides is strontium 90.1/ In addition to the radioisotopic content described above, the water contains approx-imately 150 tons of boric acid and 11 tons of sodium hydroxide.

[DRB]

14. 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 assem-bly to be de-coupled from the vaporizer assembly. In this con-figuration, the evaporator operates independent of the vaporizer and processes the warer 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. (DRB]

15. The radionuclides and their average permissible level of concentrations as influent to the vaporizer assembly for atmo-spheric releases are listed in Table 3-1 of the System 3/ That is because strontium tends to concentrate in bone mar-row and gives a larger, though insignificant in this context, dose compared to the whole body dose from tritium.

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Description. Table 3-2 of the System Description identifies the evaporator influent and effluent criteria for disposal system operation in the continuous cycle. These tables conservatively assume that certain radionuclides, not positively identified in the AGW samples, nevertheless exist at the stated lowest limit of detection ("LLD"). These assumed radionuclides, identified by an asterisk, are included in the table. (DRB]

16. Process operations by the evaporator coupled to the va-porizer assembly or by the vaporizer assembly independent of the evaporator, will not be permitted until after it has been analyt-ically determined by NRC approved process control procedures that the controlling constituents of the distillate are at or below those levels of concentrations noted in the influent column of the applicable table (The System Description, Table 3-1, vaporiz-er influent criteria, and Table 3-2, continuous cycle evaporator influent criteria). The imposition of these influent guidelines coupled with a conservative carry-over fraction of 0.1% assumed during evaporator operations (see Buchanan Affidavit 11 24 & 42),

will assure that the rate of atmospheric release of particulate j radioactive material will be in compliance with the permi. ble l

release concentrations noted in the effluent column of Table 3-2.

(DRB]

17. The average influent to the vaporizer assembly, noted in Table 3-1, is approximately 2.16E-7 uCi/ml. This concentra-tion, discharged at a rate of 5 GPM, limits the continuous l

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release of non-tritium radioactive material (principally cesium-137, strontium-90, and carbon-14) to approximately 8.23E-5 uCi/sec. This rate is less than 0.4% of the continuous particulate release rate permitted by the TMI-2 Environmental Technical Specifications ("ETS") (0.024 uCi/sec) when averaged over any calendar quarter. It is also less than the rate of re-lease stated in PEIS Supp. No. 2, section 3.1.1.2 (0.00028 uCi/sec (2.8E-4]) which was calculated at a flow rate of 20 GPM.

The average release rate of tritium, at a water processing rate of 5 GPM, vill be 38 uCi/sec, or 7% of the continuous release rate limit for gaseous effluents of 570 uCi/sec provided by the THI-2 ETS. (DRB]

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TMI-2 PROCESSED WATER SOURCE TERMS

- - Projected Source Terms ++*

Approatmate 31% Processing Total Radioactivity volume H-3 Sr-90 Co-137 Cs-134 Tank Descrtotton _ Gallons S0-125 Co-60 Ct Cl C1 Ct C4 Cl HC5 Reactor Coolant System PwST-3 67.286 2.64E+01 2.55E-03 3.02E-03 Processed water Storage 109.083 1.07E+02 6.2tE-03 PwST-2 Processed water Storage 2.64E-03 CO-T-IA 480.134 4.39E+02 9.05E-02 7.53E-03 Condensate Storese 101.518 1.86E+01 6.50E-02 1.59E-03 WDL-T-9A Evap. Cond. Test Tanh 5.650 j WOL-T-98 Ewap. Cond. Test Tank 2.03E+00 4.8 E-04 4.76E-04 3.28E-06 9.30E-06 CC-T-1 2.231 8.07E-OS 6.52E-04 3.72E-05 4.88E-07

EPICOR 11 Off-Spec 20.500 8.72E*00 4.23E-02 a

CC-T-2 EPICOR II Clean 1.32E-02 1.66E-04 1.99E-03 SFP-8 16.887 4.78E+00 1.79E-02 8.97E-03 3.4tE-03 Spent fuel Pool "B" 244.698 2.85E-04 SDS-T-1A 3.56E+01 9.15E-03 3.66E-03 SDS Monitor 373 9.29E-02 7.04E-03 SDS-T-38 SOS Monitor 1.30E-03 4.9tE-04 497 1.19E-OS 1.72E-03 1.77E-03 wot-T-IA HC Bleed Holdup 9.28E-04 9.26E-05 wDL-T-18 3.810 1.06E+00 1.44E-04 5.77E-05

HC Bleed Holdup 4.420 1.88E+00 1.67E-04 WDL-i-IC HC Bleed Holdup 6.69E-05 57.186 3.12t +0 8 2.16E-03 8.65E-04 SwST Dormted water Storage 458.985 WDL-T-8A 9.9tE+01 6.2tE-01 2.13E-01 6.60E-03 3.34E-03 Neutraltzer 8.675 2.55E+00 wDL-T-BU Neutralizer 3.28E-04 1.31E-04 8.605 3.91E+00 3.26E-04 1. 30E wot-T-2 Miscellaneous waste Holdup 3.712 8.38E-OI I.40E-04 5.62E-05 wDL-I-11A Contaminated Drains 3.938 l.33E-04 1.86E-04 2.89E-04 2.89E-06 wDL-I-llB Contaminated Ordins 820 3.76E-05 3.22E-05 Chem Cleaninu Blog Sump 1.680 2.47E-On 6.58E-03 Aunillary Bldg Sump 5.27E-03 1.33E-02 3.58E-05 Reactor Blog Basement 5.987 2.46E*00 2.24E-04 8.96E-05 43.082 3.49E+00 1.63E-03 6.52E-04 SFP-A Spent Fuel Pool "A* 205.234 1.75E+02 7.77E-03 3.IIE-03 Deep End of Transfer Canal 58.685 5.77E+08 2.22E-03 8.88E-04 Additional water to 10/88 391.000 3.0F*-02 3.76E-02 5.86E-02 5.86E-04 Total for Olsposition 2.299.417 Cl = 1020.61 0.92 0.33 7.36E-03 0.018 3.76E-03 Average Concentrattons uCl/ml = 1.20E-01 1.06E-04 3.79E-05 8.46E-07 2.07E-06 4.32E-07

(*) Based upon entrapolation of the data in the July 1986 Report to 2.3 million gallons.

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18. Radiological consequences to the public from the con-trolled atmospheric release of the evaporated AGW have been de-termined by estimating the dose to both the maximally exposed hy-pothetical off-site individual and to the total exposed population. The dose to the maximally exposed hypothetical off-site individual is a conservative (over estimated) assessment of the exposure to a member of the public, as required by 10 CFR 50, Appendix I using Regulatory Guide 1.109 dose methodology.

The estimated dose to the total exposed population is a more rep-resentative assessment of the radiological consequences resulting from the evaporation of the AGW. (GGB)

19. Doses were calculated using the Meteorological In-formation and Dose Assessment System (MIDAS) which is used by TMI Environmental Controls for quarterly and semi-annual dose assess-ments submitted to the NRC with TMI-1 and TMI-2 effluent reports.

MIDAS uses hourly averages of on-site meteorological data to cal-culate an integrated dispersion for the period of interest. It I

integrates the dispersion over each hour into each of sixteen sectors at ten distances. The location of the five nearest vege-table gardens larger than 500 square feet, and the location of l the nearest milk cow, milk goat, meat animal, and residence in each of the sixteen sectors, is used to evaluate seven airborne pathways: plume exposure, direct dose from ground deposition, inhalation, and the consumption of meat, cow milk, goat milk, and l vegetables. The maximally exposed hypothetical individual is l

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conservatively taken to be that person in the maximum inhalation location and is assumed to consume meat, vegetables, and milk from each of the other maximum locations. These calculations are performed in accordance with Regulatory Guide 1.109 and are iden-tical to those used for semi-annual and quarterly effluent / dose reports.S! [GGB)

20. Using the release fractions given in 1 17 and the dose methodology given above, Table 3 presents the estimated doses to the maximally exposed hypothetical off-site individual for the duration of the evaporation process taking into account the ex-tent of processing / reprocessing of the AGW. The evaporation of all of the AGW is expected to take about two years. Assuming a 15 month process time, the average annual doses to the maximally exposed hypothetical off-site individual from evaporation of the AGW would be less than the values reported in Table 3. The high-est average annual doses to the maxirslly exposed hypothetical off-site individual (i.e., 2.7 mrem to the bone and 1.25 mrem total body) are only 20% of the annual limit of 15 mrem and 25%

of the annual limit of 5 mrem, respectively, given in 10 CFR 50, l

Appendix ! for exposure from airborne releases. (GGB]

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21. To estimate the population dose, MIDAS was again uti-lized. The affected population is considered to be the popula-tion surrounding THI-2 out to a distance of 50 miles, 2.2 million people. The dose pathways include inhalation;, milk, meat, and vegetable consumption; plume exposure; and direct dose from ground deposition. Table 3 presents the population dose estimat-ed for the duration of the evaporation process taking into account the extent of water processing / reprocessing. Since the evaporation of all the processed water is expected to take about two years, the annual population doses are less than the values reported in Table 3. These annual doses are insignificant com-pared to the background radiation dose a member of the public re-ceives each year (i.e., approximately 300 mrem). (GGB]

22. The occupational dose attributed to evaporation of the AGW and the packaging of the evaporator bottoms has been conser -

vatively estimated to be 23 person-rem. This maximum dose is based on approximately 16,000 person-hours for the evaporation process in a radiation field of 0.6 mrem /hr, approximately 3,500 person-hours for the packaging of the evaporator bottoms in a ra-diation field of 2.5 mrem /hr, and the processing of about 31% of the volume of water. This dose is a very small percentage of the l total exposure to the work force estim'ated in the original PEIS l

(NUREG-0683) at Table 10.5 (i.e., 2,000 to 8,000 person-rem).

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Table 3 RADIOLOGICAL CONSEQUENCES FROM THE EVAPORATION OF THE AGW Radioisotopic Inventory Table 2 Dose to Maximally Exposed Hypothetical Off-site Individual (mrem)

Bone 3.6 Total Body 2.0 Population Exposure (person-rem)

Bone 25 Total Body 18 Average Exposure to a Member of the Population (mrem)

Bone 0.011 Total Body 0.008

23. Under GPUN's proposal, there are three available waste packaging options for the evaporator bottoms. All three options are acceptable methods, relative to applicable regulations, and all employ satisfactory volume reduction techniques. Section 2.3.7 of the System Description describes each waste packaging option and is incorporated herein by reference. (DRB]

24. It is estimated that the volume of evaporator bottom waste from the evaporator option will be approximately 165 tons of solid waste. This vaste, when packaged for shipment, is estimated to produce approximately 590 Specification 17C trans-portation drumsE / at 560 lbs per drum. These 590 drums at 7.5 ft 3 /ea represent a burial volume of approximately 4,425 ft3 The number of trucks required to transport these drums to a disposal site is calculated at the maximum truck capacity of either 120 drums or 44,000 lbs per truck. At an estimated weight of 560 lbs per drum, a truck could transport 78 drums per shipment. Thus, the total estimated transportation requirement is 8 truck ship-ments. (CSU)

25. The transportation of evaporator bottoms to a disposal site incurs radiological and non-radiological risks. Radiologi-cal risks include occupational dose to drivers and handlers of AGW and dose to members of the general population. The general population dose consists of routine dose exposure to by-standers and other vehicular passengers in addition to accident dose due to transportation mishaps. As previously discussed, it is as-sumed that 4,425 ft 3 of evaporator bottoms will be produced and vill require 8 truck shipments. The average activity of each ,

shipment is expected to be less than 0.5 curies total activity.

1/ A Specification 17C steel drum has a 55-gallon capacity and is approximately 23" in diameter and 35" high. The body and heads are constructed of 16-gage low carbon, open hearth or elec-trical furnace steel. The heads are double-seamed to the body with a nonhardening seaming compound; the side seam is velded.

i Two rolling hoops are located on the body. Specification 17C l drums are constructed according to ANSI MM 2.4-1979 and must meet i

the design criteria of 49 CFR 178.115.

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The shipments are assumed to travel along the least risk route (in terms of population density as determined by the INTERSTATN computer code] from TMI to Hanford, Washington which would be an estimated distance of 2800 miles. Using the RADTRAN computer code,2# the estimated incident free population dose from the 8 shipments would be 6.9 person-rem. The estimated dose to the driver per shipment is 95 mrem. (WWW)

26. The expected number of traffic accidents and fatalities for these shipments is 0.032 and 0.0013, respectively. Taking into account the severity and probability of the accident, the population density along the least risk route, and the resulting release fraction of radionuclides produces 2 E-3 person-rem ex-pected from these shipments. (WWW)

27. In addition, the reprocessing of 31% of the AGW will produce approximately 40 liners which will require 20 to 40 ship-ments for disposal and represent a disposal volume of 6,200 ft3, The expected number of traffic accidents and fatalities resulting from disposal of these liners is 0.093 and 0.0038, respectively.

The expected dose to each driver would average approximately 16 mrem per shipment. The incident free dose to the general f/ INTERSTAT is a computer program that selects the most desir-able route between two points to minimize exposure to the general population.

2/ RADTRAN is a computer program for the calculation of radiological risks associated with the transportation of radionuclides.

population from these shipments ir 4.8 person-rem, and taking into account the severity and probability of an accident, the es-timated accident dose is 0.56 person-rem. (WWW]

28. Based upon vendor price quotes, the evaporation and va-porization of 2.3 million gallons of processed water and the packaging of the resulting evaporator bottoms is estimated to cost S1.7 million. The transportation and disposal of the pack-aged evaporator bottoms vill cost an estimated $293,700.

Reprocessing approximately 31% of the processed water volume by demineralization prior to evaporation is estimated to cost an ad-ditional $2.1 million. The latter estimate is based on actual 1987 processing costs and includes all handling, loading, and processing operation costs including the cost of the resin and liners, transportation to burial, and disposal at Hanford, Washington. The total cost for this cisposal option is approxi-mately $4.1 million. Itemized cost estimates are presented in Table 4. (CSU]

Table 4 ITEMIZED COSTS FOR THE EVAPORATION OPTION Distillation & Packaging of Bottoms Preliminary Design S 36,045 Fabricate, Test & Install Equipment S800,732 Training & Psychological Screening S 5,000 Distillation of 2.3 MG Processed $725,310 Water Packaging of Evaporator Bottoms S 79,616 Demobilization S 33,196 Subtotal S1,689,899 Disposal of Evaporator Bottoms 17 C 55-gallon Drums (590) $ 23,700 Truck Shipments (8) S 40,000 GPUN Loading Operations S 10,000

[ Disposal of Class A Drums $220,000 j Subtotal S 293,700 l

l Reprocessing 31% PW Volume $2,100,000 i

! Total cost, including all operations

& handling resin, liners, transportation,

& burial l.

l TOTAL COST: / S4,083,599/

ON-SITE SOLIDIFICATION WITH OFF-SITE BURIAL l

l 29. Under this alternative, demineralization would be used i

to process 31% of the AGW prior to solidifying all 2.3 million

! gallons of water into 8' x 8' x 3' cement blocks. By 1

l reprocessing the water, the cement blocks can be disposed of as

! Class A radioactive wasteE ! at an approved low-level waste 1/ 10 CFR 61.55 requires that low-level radioactive waste be classified into one of three classes (A, B, or C) based on the (Continued Next Page) l l

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disposal facility. (CSU)

30. The demineralization of the water vill be accomplished by one of the water processing systems at TMI-2. Processing 31%

of the water inventory will result in the generation of approxi-mately 40 demineralizer liners. This represents a disposal vol-ume of 6,200 ft3 It is estimated that between 20 and 40 ship-ments will be required to dispose of these liners. (CSU)

31. To make the solidified blocks, a temporary batch mixing plant would have to be erected at TMI in the vicinity of the In-terim Solid Waste Staging Facility (ISWSF). In addition to the batch mixing plant, the following work areas would have to be provided: a supply varehouse with form assembly area, a tempo-rary staging and shipment loading area, a mastic dip and curing area, a cement block curing area, and a preliminary. set area. It is anticipated that this batch plant and its support systems i

(Continued) concentrations of the radionuclides present in the vaste form.

10 CFR 61.56 specifies the vaste form characteristics required for disposal. Class A vastt must meet the minimum physical form requirements, including less than 1% (by volume) free standing i

liquids in the disposal package and the exclusion of cardboard or

( fiberboard boxes for vaste packages. In addition to the minimum requirements described above, Class B waste and Class C waste i must be packaged in a manner to ensure structural stability.

Structural stability can be provided by processing the vaste with the addition of binders that will yield a free standing monolith (in the disposal package) which exhibits a 50 pounds per square inch compressability strength or by placing the vaste in a spe-cially licensed and approved disposal container that has been l designed to last 300 years in the burial environment.

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would require about 2.5 acres of land area to facilitate effi- l cient operations. (CSU]

32. At the outset of the solidification process, steel l forms would have to be assembled at the supply warehouse area.

The forms would have a rebar cage installed in their interice before being placed at the fill station of the batch mixing plant. Cement, AGW, and curing admixtures would be metered and mixed in the batch plant. When mixing is complete, the mixture would be poured into the steel forms. Approximately ten forms would be filled by one batch pour. The filled forms then would be moved to an area where the .nitial set can take place. After the initial set is complete, the forms will be dismantled to the extent that the concrete blocks can be removed from the forms and transported to a curing area where the blocks would remain for approximately 28 days until the final cure is accomplished.

After final cure, each block would be covered with a mastic type

[

, coating to retard contaminant leaching and edge chipping. The mastic covered blocks also would be covered with a polyethylene sheet precut to fit the block covering all 6 sides. The covered blocks then would be placed in a temporary staging area until i they could be loaded onto a flatbed truck for shipment to an ap-proved low-level waste disposal site. (CSU) i

33. The solidification process will produce an off-site en-vironmental dose. Like the dose acsossment for the evaporation option, the MIDAS system can be used to determine the offsite I

l

'; . ' . * ~

environmental dose since both options involve a ground level, long term release of tritiated water vapor. During the solidifi-i cation process, the AGW will release half of the tritium to the atmosphere but none of the particulates. As such, the dose to '

the maximally exposed hypothetical individual off-site is esti-mated to be 0.7 mrem from the release of half of the tritium dur-ing curing. Since no particulates are released, there is no es-timated bone dose. The average individual exposure is estimated

^

to be 0.0034 mrem to the whole body with a corresponding estimat-ed population dose of 7.5 person-rem. [GGB]

34. This option also will produce an occupational dose. It L is assumed that five people vill make 7 blocks in a day with 70%

system availability. As a result, approximately 20,000 person-hours will be required to produce 2,400 blocks. The aver-age activity of each block is estimated to be 0.216 curies, pro-ducing 24 person-rem for the solidification and handling. In ad-dition, based upon operational experience with EPICOR processing, domineralization of 31% of the water inventory will result in an additional 5 person-rem. Therefore, the total occupation dose i

for work done at the TMI site is estimated to be 29 person-rem.

(JET)

35. Using a water-to-cement ratio between 0.5 and 0.75, ap- .

i proximately 960 gallons of water would be used to make one block.

The activity of a typical block, based on the average processed '

j water activity, is provided in Table 5. A total of 2,400 blocks

, t l

J

would be produced from the solidification of the entire water volume. The total disposal volume of the solidified blocks would be approximately 460,800 ft3 It was assumed that the solidified blocks will be disposed of as Class A radioactive vaste at the low-level vaste disposal facility at Hanford, Washington. It also was assumed that 2 blocks will be transported by each flatbed truck shipment. Therefore, 1,;00 shipments from TMI to the low-level waste disposal facility at Hanford, Washington will be required. (CSU)

Table 5 ACTIVITY OF 8' X 8' X 3' CEMENT BLOCKS

(AFTER 28 DAYS OF CURE)

Based on Average Activity Isotooe (Ci)

H-3 2.13E-1 (1)

, Sr-90 3.84E-4 Cs-137 1.37E-4 Cs-134 3.07E-6 Sb-125 7.52E-6

. Co-60 1.56E-6 I

C-14 5.67E-4 (2)

Ni-63 5.39E-4 (2)

Tc-99 4.71E-4 (2)

TOTAL 2.16E-1 Ci/ Block (1) Assumes 50% of the tritium is released as tritiated water

! vapor during the curing process.

I (2) Maximum assumed activity based on LLD values reported in WaltzMills sample results.

l i,

l

,,w,.+ r ---- - - - - - - ,

. ,_ ------+ny m- - + -

36. The transportation of the blocks to the disposal site incurs radiological and non-radiological risks. Radiological i

risks include occupational dose to drivers of the truck shipments and dose to members of the general population. It is assumed that 1,/00 shipments to the disposal site would be required. The i average activity of each shipment is expected to be 0.43 curies of total activity. Using the RADTRAN Computer code, the estimat-ed incident free population dose from the 1,200 shipments would be 9.1 E-2 person-rem. The estimated driver dose from the 1,200 shipments is 8.3 mrem for each driver (approximately 0.007 mrem per shipment). (WWW]

37. The expected number of traffic accidents and fatalities for these shipments is 4.9 and 0.2, respectively. Taking into account the severity and probability of the accident, the popula-tion density along the least risk route, and the resulting re-lease fraction of radionuclides produces 5.6 E-3 person-rem ex-pected from these shipments. (WWW]

38. In addition, the reprocessing of 31% of the AGW vill i

produce approximately 40 liners which will require 20 to 40 ship-l ments for disposal. The expected number of traffic accidents and 1

fatalities resulting from disposal of these liners is 0.093 and 0.0038, respectively. The expected dose to each driver vould av-erage approximately 15 mrem per shipment. The incident free dose i

to the general population for these shipments is 4.8 person-rem, and taking into account the severity and probability of an accident, the estimated accident dose is 0.56 person-rem. (WWW]

l 1 l

l_

i.

09. The total volume of low-level waste resulting from this option (including the 6,200 ft3 of demineralizer waste) is 467,000 ft3 Under the 1985 Amendment to the Low-Level Waste Policy Act of 1980 (the 1985 Amendment to the LLWPA), GPUN was allocated a disposal volume of 66,468 ft3 for the years 1986-1992 for the TMI-2 facility. In addition, the DOE granted GPUN an ad-dition of "no greater than 46,000 cubic feet" for the disposal of low-level waste resulting from disposal of the AGW. Even with this additional allocation, the vaste produced from this option will exceed GPUN's allocated low-level waste burial volume for TMI-2. (JJB)

40. Given the volume of waste generated by this alterna-tive, GPUN vould need a commitment from DOE of an "unusual vol-ume" allocation. Under the guidelines established in the 1985 knendment to the LLWPA, the total "unusual volume" allocated for all waste sites combined, for the time period from January 1, 1986, to December 31, 1992, is not.to exceed 800,000 cubic feet.

The disposal of the AGW via this method would create a vaste vol-ume of 467,000 cubic feet, which amounts to approximately 58% of the total "unusual volume" available to all disposers of radioac-tive waste for a period of 7 years. This would represent a mis-use of scarce disposal resources. (JJB]

41. Moreover, the DOE previously has stated its opposition to this alternative in view of its environmental impacts. In its comment letter on the draft PEIS, the DOE stated:

' +

, , 3

. . . the alternatives involving offsite shipment of the water or the "solidified water" (without prior evaporation) would re-sult in an estimated number of traffic acci-dents much higher than the other alternatives because of the greater quantity of shipments.

Moreover, the solidification-offsite shipment alternative results in a total waste an order of magnitude or more higher than that for other alternatives. For these reasons, we believe the environmentally preferred alter-native appears to be onsite evaporation.

See PEIS Supp. No. 2 at A.31. Therefore, the probability of DOE granting an "unusual volume" burial allocation of sufficient size to support the on-site solidification with off-site disposal option is very low. (JJB]

42. The domineralization of 31% of the water inventory is estimated to cost $2.1 million. This includes the cost of resin, liners, shipment, and disposal. The batch mixing plant, includ-ing cement and consumables, shipment and disposal of the cement blocks is estimated to cost $38.6 million. The total project cost of this disposal option is estimated at $40.7 million.

(CSU) '

i e

1 e r , , - - - - - - - - -

i Table 6 l l

ITEMIZED COSTS FOR THE ON-SITE SOLIDIFICATION WITH OFF-SITE BURIAL OPTION l

Processing of 31% of the water S 2,100,000 :

Construction of Batch Mixing l Plant & Solidification Operations S 3,850,000 Cement & Consummables S 880,000 Block Shipments (1200) S 6,000,000 LLW Disposal of Blocks (460,000 cubic feet) $27.900,000 TOTAL / $40,730,000/

OFF-SITE EVAPORATION

43. The alternative of off-site evaporation would require processing at least 31% of the water inventory at TMI prior to loading the AGW into tank trucks and transporting it to an off-site location. The Staff, in the PEIS, assumed natural evapora-tion in a specifically constructed Hypalon-lined pond with a ca-pacity of approximately 1 million gallons (3.87 million liters) and a surface area of approximately 15,000 ft2 (1,400m2 ) at the Nevada Test Site (NTS). The water, including the tritium, would evaporate from the pond, and the remaining solids would be capped with concrete and covered with soil. (CSU)

44. Approximately 460 tank truck shipments of 5,000 gallons (19,000 liters) would be needed to transport the AGW to the NTS.

Each shipment would contain 2.2 curies of tritium, plus traces of l

cesium and strontium. Depending on the available number of trucks, shipment of all of the AGW would require 9 to 18 months.

(CSU)

45. Each stage of this operation would produce a radiation dose. As previously stated, reprocessing 31% of the water is es-timated to produce a dose of 5 person-rem. Then, it is estimated 1,700 person hours vill be required to load the water into the trucks for shipment. The average activity of each shipment is estimated to be 2.2 curies, producing a total dose of 1.9 E-3 perron-rem for the loading operation. Next, using the RADTRAN computer code, the worker dose from actual shipment is estimated to be 15 mrem / driver per trip. In additior, the estimated inci-dent free population dose from the 460 shipments would be 0.076 person-rem. (WWW)

46. Assuming that this option requires 460 truck shipments, the expected number of traffic accidents and fatalities is 1.9 and 0.076, respectively. Taking into account the severity and probability of the accident, the population density along the least risk route, and the resulting release fraction of radionuclides produces 0.216 person-rem expected from accidents during these shipments. (WWW)

47. In addition, the reprocessing of 31% of the AGW vill produce approximately 40 liners which vill require 20 to 40 ship-ments for disposal. The expected number of traffic accidents and fatalities resulting from disposal of these liners is 0.093 and

.m. ., .. , , _ _ _ . . _ _

i 0.0038, respectively. The expected dose to each driver would av- '

erage approximately 15 mrem per shipment. The incident free dose to the general population for these shipments is 4.8 person-rem, and taking into account the severity and probability of an acci--

dent, the estimated accident dose is 0.56 person-rem. (WWW)

48. The NRC estimated that the collective 50-year dose com- :

mitment to the affected population (estimated to be 6,400) within a 50-mile radius of the proposed disposal site at NTS would be !

0.0003 person-rem. I believe that the Staff's assessment is a reasonable assessment of the dose consequences to the public under this option. (GGB] I

49. Both NRC and DOE approval vould be required for the disposal of vaste described in this alternative. The Memorandum of UnderstandingE/ between agencies does not include any commit- '

ment for DOE to accept TMI waste that can be disposed by commer- l cial means. Moreover, like the on-site solidification with !

off-site burial option, the DOE has noted that the off-site evap-oration alternative would result in an estimated number of traf- I fic accidents much higher than the other alternatives because of the greater quantity of shipments. Based on this assessment, the DOE concluded that the enviromentally preferred alternative [

9/ Memorandum of Understanding between the U.S. Nuclear Regula- '

tory Commission and the U.S. Department of Energy concerning the removal and disposition of solid nuclear vaste from cleanup of the Three Mile Island Unit 2 Nuclear Plant, March 15, 1982. 47 Fed. Reg. 16,229.

appears to be on-site evaporation. See PEIS Supp. No. 2 at A.31.

(JJB]

Table 7 COSTS FOR THE OFF-SITE EVAPORATION OPTION [CSUl Processing of 31% of the Water 2,100,000 Shipping 2.3 million gallons of Water 2,100,000 Construction of the Pond 12/ 400,000

/4,600,000/

DISTILLATION (CLOSED CYCLE EVAPORATION) AND SOLIDIFICATION

50. The alternative of distillation (closed cycle evapora-tion) and solidification would provide for disposal of the AGW by closed cycle evaporation followed by solidification of the cap-tured distillate. Hypothetically, the solidified distillate then would be disposed by burial in a secure landfill at the TMI site or in an approved off-site low-level waste burial ground. (CSU)

51. The disposal system for this option would consist of three major component groups. They would bet (1) a closed cycle evaporator system; (2) an evaporator bottoms processing and packaging system; and (3) a distillate disposal system. (CSU)

52. The evaporator section used in this option would be

similar to the one described in the System Description. This system would consist of dual evaporators designed to operate at a l

10/ The Staff's estimate in the PEIS of 0.2 to 0.6 million dol-lars to construct the pond is a reasonable assessment of the con-struction cost.

i feed rate of 5 GPM. The main evaporator vould provide the dis-tillation of the AGW by changing this water into steam and '

separating the entrained solids from the rising vapors. The va-pors would be condensed into cleaner water (distillate) and col-lected in the distillate tank. (DRB]

53. The evaporator bottoms would be packaged for disposal :

consistent with commercial low-level vaste transportation and disposal regulations. Section 2.3.7 of the System Description presents a description of the evaporator bottoms packaging sys-tem. Using the vendor information that 560 lbs of evaporator bottoms will be packaged into each 55-gallon container, as many as 389 Class A drums and 292 Class B HIC's (high integrity con-tainers) will be generated. The total packaged volume of i

evaporator bottDms is estimated to be 5,200 ft3 The Class A .

l drums will be shipped to the low-level vaste disposal facility in a standard van truck. The activity of the class B HIC's, how-ever, is such that they will exceed low specific activity ("LSA") t criteria and also will be greater than Type A quantities. There-fore, the Class B HIC's will have to be shipped to the low-level l vaste disposal facility in a Type B shipping cask. It is esti-mated that 6 truck shipments would be required to dispose of the ;

Class A drums, and 37 cask shipments would be required to dispose ,

I of the Class B HIC's. (CSU}

l 54. In order to bury the solidified distillate at THI, a i

system for producing a grout mixture vould have to be !

i r.

o.

j constructed. The grouting system would be trailer mounted for location near the ISWSF. The distillate would be mixed with the grout and placed in an engineered pit that is located within the 1 dike to the North and Northeast of the ISWSF. (CSU)

55. Evaporator distillate would be transferred to a i 1

grouting system feed tank located within the system trailer. Ce-ment would be fed from storage silos to be mixed with water with- !

l in a screw mixer and transferred into the engineered pit using a grout feed pump at approximately 10 GPM. Based upon a water-to-I cement ratio between 0.5 and 0.75, a pit approximately 260' x 190; x 15' deep with a cement slab about 10' deep would be required. (CSU)

56. A 2-foot-thick layer of compacted clay and a 36-mil Hypalon liner (or equivalent) would be installed to provide groundwater protection. The compacted clay layer would provide a !

cushioned base for the synthetic liner in addition to preventing "

the instrusion of groundwater. Monitoring wells would be in-stalled for groundwater observation. The position of these vells would be such that at least one is up-gradient of the groundwater flow pathe, and the others would be down-gradient. (CSU)

57. Leachate collection laterals would be placed in the pit, directly on the synthetic liner. A gravel / soil backfill would be added to cover the laterals and protect the liner. The collected leachate would be held in a sump located at the landfill site. Radiation monitoring of this sump will be provided. The leachate would be monitored and pumped to the in-dustrial vaste treatment system. (CSU)

58. The solidification and on-site disposal of the distil-late vill cause the release of radioactive material to the envi-ronment. The solidification process is expected to release tritium to the atmosphere in the form of water vapor due to the heat of hydration during the mixing and curing of the solidifica-tion process. Prior to closure of the landfill, the release of small quantities of radioactive material to the river may occur due to the release of leachate. (CSU)

59. A conservative estimate of the continuous tritium re-

, lease rate to the atmosphere has been determined based on the as-sumptions given below the average tritium concentration in the AGW is 1 0.12 uCi/ce; a release fraction of 50% for tritium; a continuous release rate of 10 GPM; and a solidification process rate of 10 GPM (631

cc/sec).

, The above assumptions yield a tritium release rate of 38 uci/sec.

I

This is approximately 7% of the allowable continuous tritium re-l 1 ease rate limit given in 1 17 (CSU)

60. Two separate release pathways exist for the solidifica-tion and burial onsite scenario atmospheric release of half of j the tritium during curing of the slab and river release of a fraction of the particulate activity through leaching into 4

I

rainwater in contact with the slab. One percent of the activity '

in the slab is conservatively assumed to be leached from the con-crete mass each year during the contact time prior to closure and isolation of the landfill. (GGB)

61. Liquid releases are evaluated by a liquid dose routine in MIDAS, which is based on the methodology in Regulatory Guide i 1.109. Three pathways to humans are considered in the liquid ex- 1 posure route: drinking water, consumption of fish residing near the plant discharge, and direct radiation exposure from shoreline sediments. The maximally exposed individual is assumed to obtain drinking water from downstream of the plant, eat fish from down-stream of the plant, and spend recreational time on the shoreline downstream of the plant. (GGB)

62. Using the methodology given above, the maximally ex-posed individual from solidification prior to closure of the !

landfill is estimated to receive about 0.7 mrem total body from i the atmospheric tritium and 0.3 mrem to the bone from dissolved particulates released to the river as leachate. (GGB) 4

63. The airborne population dose, evaluated as described in l 1 21, is estimated to be 7.5 person-rem total body. Liquid popu-1 lation doses are evaluated by including the entire population which might use Susquehanna River water for drinking purposes, ;

including Chester County and the City of Baltimore. This in-l 4

cludes about 6 million people. The liquid pathways population dose is estimated to be about 4 person-rem. (GGB) !

4 a

f

64. Additionally, the possibility exists for members of the public to come in contact with the slab after decommissioning of the THI site. An estimate of the doses involved in this "intrud-er scenario" was performed using similar methodology as described above, but allowing for 30 years of decay and leaching prior to intruder contact. This allowance for decay and some leaching loss actually reduces the estimated intruder scenario dose.

(GBB)

65. For the intruder scenario, it is assumed that individ-uals would cause the isolation of the landfill to fail, and would spend 2,000 hours0 days 0 hours 0 weeks 0 months per year above the slab in some hypothetical occupational capacity (the Island is assumed to become a park in this scenario). Integration of the liquid pathway dose for a 50 year exposure, accounting for the decreasing source caused by leaching loss and decay, would yield an individual dose com-mittment of about 7.2 mrem ta the bone to the maximum individual, and about 100 person-rem to the bone total population dose. (GBB]

66. Direct exposure to the slab was assessed using the ISOSHLD11' point kernal shielding code. Again accounting for the initial 30 years before exposure begins, and a subsequent 50 year exposure, the maximally exposed individual vould receive about 14 mrem from exposure to the slab. Since the actual number of 11/ ISOSHLD is a computer code for general purpose isotope shielding analysis developed by Engle, Greenborg, and Hendrickson.

people who could be exposed in this manner to the slab is quite small, the population dose is expected to be less than 1 person-rem. (GBB]

67 A portion of the occupational dose from this option is obtained from the processing of the AGW and the solidification of :

the distillate. An additional occupational dose from the on-site disposal of the solidified mass is insignificant because of the layer of soil cover over the solidified mass following closure of the landfill. The occupational dose from the solidification pro-cess has been conservatively estimated to be approximately 15 person-rem. This dose is based on approximately 16,000 person-hours for the solidification and transfer of the grout and !

5 person-rem from the processing of the water. This dose is a very small percentage of the total exposure to the work force es-timated in the original PEIS at Table 10.5 (i.e., 2,000 to 8,000 person-rem). (JET)

, 68. In addition, an occupational dose will be produced by the packaging and shipment of the Class A drums and the Class B HIC's. The worker dose is estimated to be 570 mrem for each driver, while the incident free population dose from these ship-ments is estimated to be 5.2 person-rem. (WWW)

69. Assuming that this option will require 6 truck ship-ments and 37 cask shipments, the expected number of traffic acci- '

dents and fatalities for these shipments is 0.175 and 0.007, re-spectively. Taking into account the severity and probability of

-',. ',+

the-accident, the population density along the least risk route, and the resulting release fraction of radionuclides produces 0.304 person-rem expected from these shipments. (WWW)

70. Burial of solidified distillate on the TMI site would encounter several practical and regulatory obstacles. First, there is no suitable space for a landfill within the nuclear sta-tion's diked region for a large residual vaste disposal site.

Second, outside of the diked station area, most of the available land is on the 100-year flood plain. Under 25 PA Code 75.25(2)(xvii), the Pennsylvania Department of Environmental Re-sources ("PADER") cannot license a landfill on flood plain land.

Third, approval of the Federal Energy Regulatory Commission

("FERC") may be required. [ TAG)

71. If a suitable site were found on the Island, licensing the site probably would take a minimum of three years. The li-censing procedure is described in 25 PA Code 75.21-25 which is attached as Exhibit H. In addition, Pennsylvania's current poli-cy is to limit issuance of landfill disposal permits to only those that are absolutely necessary. (TAG)

72. Based on vendor price quotes, the distillation of 2.3 million gallons of AGW and the packaging of the resultant evaporator bottoms is estimated to cost $1.7 million. The trans-portation and disposal of the packaged evaporator bottoms will cost an additional $1.6 million. The disposal of the distillate in a landfill at TMI is estimated to cost S3.7 million. The

(

.)k total project cost for the distillation and on-site burial option is estimated to be $7 million. Itemized cost estimates are presented in Table 8. (CSU) l Table 8 l

ITEMIZED COSTS FOR DISTILLATION AND ON-SITE BURIAL OPTION Distillation & Packaging of Bottoms Preliminary Design S36,045 Fabricate, Test, & Install Equipment $800,732 Training & Psychological Screening $5,000 Distillation of 2.3 MG Processed Water $735,310 Packaging of Evaporator Bottoms $79,616 Demobilization $33,196 Subtotal: $1,689,899 Disposal of Evaporator Bottoms 17 C 55-gallon Drums (389) S15,600 55-gallon HICs (292) S350,400 Truck Shipments (6) $30,000 Cask Shipments (37) $925,000 GPUN Loading Operations $10,000 Disposal of Class A Drums $145,000 Disposal of Class B HICs $138,000 Subtotal: $1,614,000 Distillate Disposal On-site Trailer Mounted Grounting System $1,663,200 Cement & Admixtures $1,210,000 Operations Costs $332,200 Design, Construct & Seal Landfill $446,600 Subtotal: $3,652,000 TOTAL COST: /56.955.899/

73. A variant of the above distillation and solidification option would provide for solidification of the evaporation dis-f.illate into large blocks for subsequent disposal at a low-level

'.- '.- t l

vaste burial ground. It was assumed that the evaporator distil- l t

late would be solidified into 8' x 8' x 3' cement blocks. The average activity of each block is presented in Table 9. To make the solidified blocks, a temporary batch mixing plant similar to that described in 11 31-32, would have to be erected at TMI. A total of 2,400 blocks would be produced from solidification of 2.3 million gallons of distillate, yielding a total disposal vol-ume of 460,800 ft3 A total of 1,200 shipments from TMI to the low-level vaste disposal site at Hanford, Washington, would be required to dispose of the colidified blocks.12/ In addition, this alternative vould produce 5,200 ft3 of evaporator bottoms to be disposed of in accordance with the discussion presented in 1 53. (CSU)

Table 9 ACTIVITY OF 8' X 8' X 3' CEMENT BLOCKS

(AFTER 28 DAYS OF CURE)

Based on Average Activity Isotooe (Ci)

' H-3 2.13 E-1 Sr-90 5.55 E-4 Cs-137 3.88 E-4 Cs-134 1.10 E-6 Sb-125 5.27 E-6

Co-60 1.74 E-6 i C-14 5.67 E-7 (1)

Ni-63 5.64 E-7 (1)

Tc-99

'i 4.71 E-7 (1)

TOTAL 2.14 E-1 (1) Maximum assumed activity based on LLD values reported in WaltzMills sample results.

12/ Like the on-site solidification with off-site burial option,

.this option would require an unusual volume allocation from DOE.

(JJB) i

74. Using the MIDAS method previously presented, the dose to the maximally exposed individual off-site from this option is estimated to be 0.7 mrem to the total body from the release of half of the tritrium during curing. The population dose from this option is estimated to be 7.5 person-rem to the total body.

(GGB)

75. At each stage of this option, an occupational dose vill result. The evaporation process vill result in a 9 person-rem dose. Production and handling of the 2.400 blocks with an aver-age activity of 0.22 curies is estimated to take 20,000 person-hours and result in a dose of 24 person-rem. Processing and packaging of the evaporator bottoms is estimated to take 3,500 person-hours and produce a dose of 9 person-rem. (JET)

76. Th9 transportation of the vaste product under this option involves both radiological and non-radiological risks.

The occupational dose to each driver from the transportation of the blocks is estimated to be 8.3 mrem (approximately 0.007 mrem per shipment), while the occupational dose from the transporta-tion of the bottoms is estimated to be 570 mrem for each driver.

In addition, the incident free general population dose from the transportation of the blocks is estimated to be 9.1 E-2 person-rem, and the incident free general population dose from the transportation of the bottoms is estimated to be 5.2 person-rem.

(WWW) 77 The expected number of accidents and fatalities from transportation of the blocks is estimated to be 4.9 and 0.2, re-spectively. Similarly, the accident and fatality figures for the transportation of the bottoms are 0.175 and 0.007, respectively.

Given the severity and probability of an accident, the population i density along the transportation route, and the resulting release fraction of radicauclides from accidents produces 6.3 E-6 person-rem expected from the shipments of the blocks and 0.304 person-rem expected from the shipment of the bottoms. (WWW)

78. Based upon vendor price quotes, the distillation of 2.3 million gallons of processed water and packaging of the resultant bottoms is estimated to cost $1.7 million. The transportation 1

and disposal of the packaged evaporator bottoms vill cost an ad-ditional $1.6 million. The disposal of the distillate under this alternative is estimated to cost $38.6 million. Thus, the total project cost for this disposition alternative would be $41.9 mil-lion. Itemized cost estimates are presented in Table 10. (CSU)

',. t .

i Table 10 ITEMIZED COSTS FOR DISTILLATION AND OFF-SITE BURIAL OPTION Distillation & Packaging of Bottoms Preliminary Design $36,045

Fabricate, Test, & Install Equipment $800,732 Training & Psychological Screening $5,000 Distillation of 2.3 MG Processed Water $735,310 Packaging of Evaporator Bottoms $79,616 Demobilization S33,196 Subtotal: $1,689,899 Disposal of Evaporator Bottoms 17 C 55 gallon Drums (389) $15,600 55-gallon HICs (292) S350,400 i

Truck Shipments (6) S30,000 Cask Shipments (37) $925,000 GPUN Loading Operations $10,000 Disposal of Class A Drums $145,000 Disposal of Class B HICs $138,000 l Subtotal: $1,614,000 l

Distillate Disposal

Construction of Batch mixing Plant

, & Solidification Operations $3,850,000 Cement & Consummables $880,000 Block Shipments (1,200) S6,000,000 LLW Disposal of Blocks (460,800cu.ft.) S27,900,000 i

Subtotal: S38,630,000 i

j TOTAL COST: /S41,933.899/

INTERIM MONITORED ON-SITE STORAGE IN TANKS I

79. The alternative of interim, monitored storage would re-i

quire the AGW to be stored in tanks on the TMI site for thirty years. This is the "no action" alternative. Presently, the water is stored in tanks on the TMI site. Use of the interim, j monitored on-site storage option would require the construction of additional tanks on the TMI site at a cost of between 51 mil-lion and $1.5 million excluding pumps, piping, and monitoring systems. (DRB]

80. The apparent benefit of this alternative is that it provides time for the radionuclides in the AGW to decay. Over a 30-year period, the strontium and cesium curie content would de-crease by approximately a factor of 2. The tritium content would decrease by a factor of approximately 6 over the same time period. However, based on the off-site dose assessment performed by GPUN, this decrease in tritium would not have any significant effect on the dose assessment since the critical organ and iso-tope are strontium dose to the bone. Given the curie content of strontium, a decrease by a factor of 2 vill not reduce the dose to any significant degree. (GGB)

81. Moreover, long term storage would have no effect on LLD isotopes assumed to be present in the AGW at their detection lim-its. The inclusion of iodine 129 as present at the lover limit of detection causes the dose assessment to be based on a thyroid

critical organ dose from the I-129. Iodine 129 has a half life l of sixteen million years and cannot be eliminated by the rela-tively few years of storage envisioned in this alternative.

(GGB)

82. It is assumed that additional tankage required by this alternative vill be constructed to standards similar to and co-

located with the existing PWSTs. The PWSTs are designed to l

l

?. * '.'

API-650 and contain an interior epoxyphenolic type lining. It is assumed that all AGW will be buffered to reduce the corrosive :

effect of the boric acid. (DRB] [

83. Storage of the AGW on-site presents the continued risk l of a radiological accident. An uncontrolled release could occur ,

as a result of damage to one or more tanks due to an external event or due to tank failure (e.g., leaks due to the aging pro-cess). External events that were found to contribute to the re-lease probability include airplane crashes, tornados, floods and seismic events. The probabilities associated with the occurrence of external events that could cause a breach of the AGW tanks were derived from the Probabilistic Risk Assessment-performed for Unit 1, data contained in the Unit 2 FSAR, and data obtained from i

the Harrisburg Office of the U.S. Department of Interior, Geolog-j ical Survey Water Resources Division. The probability of a leak or rupture can be examined from comparable tank failure rates.

(WWW)

84. The probability of an uncontrolled release over the 30 year period has been estimated to be roughly 3.75%. The weighted average release results in 7 mrem via inhalation pathway and 10 mrem via liquid release pathways to the maximally exposed indi-I j vidual. (WWW) l l

85. In addition, the recovery from a major spill was hy-pothesized by using PWST water to determine the inhalation path-vay dose to workers, and by using BWST vater to estimate worker l

t !

l 4

L .

dose to standing on contaminated ground. The dose to a worker for recovery from the spill vould be 36 mrem interaal whole body dose from tritium and 0.2 mrem external whole body dose, primari-ly from Cs-137. (JET)

86. Since this alternative merely delays the ultimate dis-posal of the AGW while presenting the risk which accompany stor-age of liquid radioactive vaste, it has been consistently criti-cized by the NRC and State governments. For example, in PEIS Supp. No. 2 at 3.34, the NRC stated: ". . . this alternative is inconsistent with the Commission's Policy that the cleanup, including removal of radioactive vaste from the TMI site, be car-ried out safely and expediously. In the absence of everriding benefit associated with storing disposable radioactive vaste onsite, the NRC Staff has continued to support safe and expedi-J tious removal." Likewise, the State of Maryland commented, "We also agree that liquid storage onsite (no-action alternative) provides no reasonable benefit and merely foresta11s the disposal issue. It should receive no further consideration." PEIS Supp.

i No. 2 at A.10. Similarly, we feel this option has little merit.

INSIDE CONTAINMENT STORAGE 1

87. The alternatise of permanent in-containment disposal vould encompass storing the AGW in tanks within the Unit 2 Reac-tor Building permanently. In order to store 2.3 million gallons of water, 307,500 cubic feet of storage space is required. This 4

volume of space does not exist in the Reactor Building. However,

r 1.

.o i

if 2 million_ gallons of the AGW vere stored in the Reactor Build- t ing, the remaining 300,000 gallons could be stored in the t

Refueling Canal. (DRB) i

88. There are three available areas in the Reactor Building I for water storage: (1) the Refueling Canal; (2) the area above t [

the D-rings; and (3) the area South of the D-rings. The Refueling Canal is 24 feet vide by 66.5 feet long by 19.5 feet t deep at the shallow end, sloping to 34 feet at the deep end. It has a potential storage capacity of 300,000 gallons. A clear '

height of 55 feet exists between the top of the D-rings (370'

, elevation) and the bottom of the Polar Crane (425' elevation).

One large tank, 65 feet in diameter by 55 feet in height, or 10 ;

small tanks, 20 feet in diameter by 50 feet in length, could be -

i i built in this area above tha D-rings and provide a storage capac- r 4

ity of 1,100,000 gallons. South of the D-rings, one tank, 45

{

feet in diameter by 75 feet in height, could provide a storage capacity of 900,000 gallons.12/ (DRB)

89. The most intensive labor effort involved in this option vould be the fabrication of the storage tanks. In order to keep f ;

11/ It should be noted that installation of a tank on the south

! side of the D-rings would completely block the hatch to the 347' :

i foot elevation. Therefore, all tank material vould have to be

! staged inside the Reactor Building on the 347'-6" floor elevation '

I prior to final tank placement. In addition, tanks on the south -

l side of the D-rings would exceed the allowable floor loading mak-ing it necessary to use support steel to redistribute the load to

l nearby columns.

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i radiation doses as lov as-reasonably achievable, these tanks l

l should be fabricated outside the Reactor Building. The pre-l fabricated component parts of these tanks vould be limited in

size to 20 feet in diemeter and 50 feet in length due to the di-

! mensional limitations of the equipment hatch which the components j must pass through to the Reactor Building. (DRB) i

90. The estimated cost in oorson hou11 2nly for this option is given in Table 11. This estimate provides for the installa-

{

tion of Eng 60 foot in diameter by 60 foot in height storage tank l

fabricated and installed in the Reactor Building. It is applica-

)

! ble to either of the installation options noted above, as it is l

l based on the required storage volume for 2.3 million gallons of l vater. (DRB) i l

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Table 11 ESTIMATE FOR ONE 60' X 60' TANK Total Surface Area 16,956 ft.2fpt, ,

Total sheets Required 530 (16,956 ft. / 32 ft.2)

PERSON / HRS ACTIVITY EST. PERSON / HRS IN-CONTAINMENT Fab./ Prep / 4,870 Transport Outside RB Support RB Work 10,000 Outside RB Transport Materials 1,000 1,000 Inside RB Plant Mods Inside RB 720 720 (Civil-Elec.-Mech.)

i Scaffolding Inside RB 250 250 Tab / Erect Tank 40,000 40,000 Inside RB

, Equip Hatch Mods Allow 500 320 320 Person /Mrs Insid6 RB Supervision /(ENGRG. lqqq) 6,684 4,229 Allov 10% Person / Hrs inside RB Total Estimated Person / Hrs for ont of two tanks required (the other tank

= 45' x 75') 64,024 46,519

) ......

At $30 Mr x 64,024 = $1,920,720 for labor costs only.

, 91. It is estimated that construction of tanks inside the Reactor Building would require 130,000 person nours. The current dose ratios in the Reactor Building are typically 50-75 person-

, rem / hour at the 305' elevation and 40-50 person-rem / hour at the i

.- ' , . . 1.,

347' elevation. Ii it is assumed that the work in the Reactor Building is divided between these two locations, the total person-rem received during the construction of the tanks would range from 4,070 to 5,106 person-rem. Table 12 lists the data for the 60' x 60' tank, and Table 13 lists the data for the 45' x 75' tank. Table 14 summarizes the above data. [DRB]

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Table 14 Estimated' Person-Rem For Construction Of Two Tanks in the R.B.

Task / Activity Tank 1 Person-Rem Tank 2 Person-Rem Total Person-Ret Transport Materials 45-62 36-50 81-112 Inside R.B.

Plant Modifications 29-36 23-29 52-65 Inside R.B. '

Scaffolding Inside 10-12 8-10 18-22 R.B. (Installation Only)

Fabricate / Erect Tank 1600-2000 1110-1650 2920-3650 Inside R.B.

Equipment Hatch 16-24 N/A 16-24 Modifications Only) l Supervision / Engineering 168-210 137-172 305-382 Total Task Person-Rem 3392-4255 for 2 Tanks Total Person-Rem with 4070-5106

, 20% Rad Con Support l

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92. If the AGW is stored at TMI for an indefinite period of time as a means of disposal, the TMI site would require either a license under 10 CFR 61.3 or an exemption under 10 CFR 61.6 for waste disposal. The minimum characteristics for disposal site suitability include that the site be outside the 100 year flood plain (10 CFR 61.50(a)(5)) and have sufficient depth to the water table that ground water intrusion will not occur (10 CFR 61.50(a)(7)).1$# Further, 10 CFR 61.56(a)(2) provides:

"(1]iquid waste must be solidified or packaged in sufficient ab-I sorbent material to absorb twice the volume of the liquid."

(JJB]

l

93. Storing the AGW on-site would require meeting the above criteria. However, TMI is in a flood plain. Thus, the disposal site would have to be within the diked region of the Island. In addition, the ground water level is only about 20 feet below ground level. Accordingly, an exemption to the ground water in-trusion criteria would be necessary. Moreover, bulk storage of l the AGW in tanks would not satisfy the absorbency criteria of 10 CFR 61.56(a)(2). Therefore, it is doubtful that a license or ex-l emption could be obtained to store AGW indefinitely at TMI.

l l (JJB]

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11/ The Commission can censider an exemption to this requirement pursuant to 10 CFR 61.50(a)(7).

l l

- l' CONCLUSION

94. A comparison of GPUN's evaporation proposal and the five options put forward by the Joint Intervenors supports the selection of GPUN's pending proposal. An evaluaticn of the options in terms of environmental effects, transportation l requirements, risk assessment, cost, and licensing feasibility shows that GPUN's proposal is preferable to the other alterna- I l

tives. Moreover, GPUN's proposal removes the .sk associated )

with the continued storage of radioactive liquid waste on the THI site.

95. GPUN's proposal for disposal of the AGW calls for forced evaporation followed by vaporization and atmospheric re-lease of the product distillate. The GPUN proposal also includes the separation and final treatment of the solids removed and col-lected during the evaporation process and the preparation of the resulting waste product for shipment and burial at a commercial low-level waste facility. During the evaporation process, it is estimated that the highest average annual doses to the maximally exposed hypothetical off-site individual will be 2.7 mrem to the bone and 1.25 mrem total body. Those doses are only 20% of the annual limit of 15 mrem and 25% of the annual limit of 5 mrem, respectively, given in 10 CFR 50, Appendix I for exposure from airborne releases. They also pale in comparison to the 300 mrem per year of natural background radiation to which a member of the

- ;* 1 i

l local population is exposed. Similarly, the occupational dose l

from evaporation of the AGW and the packaging of the evaporator '

bottoms is estimated to be 23 person-rem, a very small percentage I of the total exposure to the work force estimated in the original l

l PEIS at Table 10.5 (i.e., 2,000 to 8,000 person-rem). As for <

1 transportation requirements, the evaporation option will require l only 8 shipments to dispose of evaporator bottoms with corre-sponding expected accident and fatality rates of 0.032 and 0.0013, respectively.15/ Accordingly, probability of an accident I

or fatality resulting from this option is practically zero.

Moreover, the evaporation proposal has the lowest potential for accidents and fatalities of any alternative with a transportation component. In the area of licensing feasibility, excluding 1

! GPUN's pending request for a license amendment, which is neces-l t

sary to implement any of the disposal options, there are no reg-ulatory barriers to the evaporation proposal. Finally, at a cost of $4.1 million, the evaporation proposal vill result in a com-plete resolution of the water disposal issue.

96. The on-site solidification with off-site burial option 1

calls for the reprocessing of 31% of the AGW prior to solidifying all 2.3 million gallons of water into 8'X 8' X 3' cement blocks.

t l The cement blocks then will be disposed of as Class A radioactive 1

15/ This transportation requirement is exclusive of the ship-ments necessary to dispose of the liners which will be produced during the reprocessing of 31% of the AGW.

3' waste at an approved low-level vaste disposal facility. The dose to the maximally exposed hypothetical off-site individual is es-timated to be 0.7 mrem to the total body from this option. While the latter dose estimate is lower than the GPUN evaporation pro-posal maximally exposed individual dose estimate, the occupation-al dose at the TMI site from the GPUN evaporation option is lover. Moreover, the on-site solidification option would require 150 times as many waste disposal shipments with an attendant in-crease in non-radiological transportation risks. While the prob-ability of a traffic accident under the evaporation alternative is practically zero, the expected number of traffic accidents from the on-site solidification with off-site burial option is l 4.9.15/ In terms of required regulatory approvals, the on-site l solidification with off-site burial option would require an "un-usual volume" allocation from DOE for the waste disposal which

. would amount to 58% of the total volume allocation for all vaste 1

disposers through 1992. This would constitute an unwarranted waste of scarce disposal space, and clearly would not be ap-proved. Finally, the estimated cost of the on-site solidifica-tion with off-site burial option is $40.7 million, more than ten times the cost of the evaporation proposal.

11/ This transportation requirement is exclusive of the ship-ments necessary to dispose of the liners which will be produced during the reprocessing of 31% of the AGW.

i- l'

97. The alternative of off-site evaporation calls for reprocessing at least 31% of the water inventory at TMI prior to loading it into tank trucks and transporting it to a specifically constructed pond at NTS where the water would evaporate.

Although it is estimated that this option would not produce a maximally exposed hypothetical off-site individual dose or an ad-ditional occupational dose to workers on the TMI site, the non-radiological transportation risks involved in this alternative are higher than those presented by the GPUN evaporation proposal.

The off-site evaporation option is estimated to require 460 truck shipments with an expected number of 1.9 traffic accidents.12' By comparison, the probability of an accident under the GPUN evaporation proposal is practically zero. Moreover, off-site evaporation would require DOE authorization to use NTS. This regulatory barrier to the off-site evaporation option should net be underestimated in view of DOE's past criticism of the off-site evaporation option. Finally, the $4.6 million estimated cost of this option is higher than the $4.1 million estimated cost of GPUN's evaporation proposal.

l

98. The alternative of distillation (closed cycle evapora-tion) of the AGW followed by on-site solidification and burial of the captured distillate, like the other options put forward by t

l 12/ This transportation requirement is exclusive of the ship-ments necessary to dispose of the liners which will be produced during the reprocessing of 31% of the AGW.

l l

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I 1

I' the Joint Intervenors, is not preferrable to GPUN's evaporation proposal. The option of distillation and on-site solidification and burial is estimated to produce a dose of 0.7 mrem total body dose to the maximally exposed hypothetical off-site individual.

Like all of the solidification options, the latter dose estimate is lower than the comparable estimated dose produced by the evap-oration option. However, burial of the distillate on the TMI site is not feasible because of space limitations and the site's location within the 100-year flood plain. In the area of regula-tory approvals, FERC approval may be required if the distillate

is buried on the Island, and approval of the Pennsylvania Depart-ment of Environnental Resources would be required. It also should be noted . hat PADER approval is doubtful because of a Pennsylvania policy of limiting landfill permits to only those that are absolutely necessary. In addition, with each licensing proceeding, the risk associated with the continued storage of i liquid radioactive waste will mount. Finally, the cost of the 1

on-site solidification and burial option is approximately $3 mil-l l lion dollars more than GPUN's evaporation proposal.

l

99. A variant of the above alternative provides for distil-l lation (closed cycle evaporation) of the AGW followed by on-site l solidification with off-site burial. However, this variant has greater non-radiological transportation risks than the GPUN pro-posal. In addition, this variant would require DOE approval of an unusual volume allocation of more than half of the total f

'.' l' national unusual volume allocation for the next 6 years.

Finally, the on-site solidification and off-site burial variant would cost ten times the amount of GPUN's evaporation proposal.

100. The option of interim, monitored on-site storage envi-sions storing the AGW in tanks on the TMI site. This alternative is assumed to give essentially no worker dose and no off-site dose at the present time or in the near future. However, at the end of the storage period (assumed to be 30 years), the worker and off-site doses will be essentially the same as if the water was disposed of now. For this reason alone, there is no benefit to the interim, monitored on-site storage option. Moreover, the latter option presents a risk of an accidental release during storage. Finally, the estimated cost of the interim monitored on-site storage option is $1 million to $1.5 million for current construction of tanks. In reality, however, the cost estimate for this option must include the additional costs for ultimate disposal of the AGW, which range from at least $4 million for permanent storage in the Reactor Building (labor costs only) to

$42 million for distillation and off-site burial.

101. The option of permanent in-containment storage of the AGW would require storage of the AGW in tanks within the TMI-2 Reactor Building indefinitely. While this alternative will present no dose to the public, the estimated occupational dose from construction of the tanks alone is 4,070 to 5,106 person-rem. Such a large dose more than offsets the dose savings

i u

.s a

to the public. As for licensing feasibility, this option would require NRC licensing pursuant to 10 CFR Part 61. Given TMI's failure to meet the site suitability criteria of Part 61, and this option's failure to meet the packaging criteria of Part 61, NRC approval of this option is doubtful. Finally, the $4 million cost estimate (labor costs only) for the permanent in-containment storage option does not include the additional cost for construc-tion materials (e.g., tanks, pumps, piping, and necessary support steel), long term storage, and maintenance.

102. Given the foregoing review of the GPUN's proposal and the options put forward by the Joint Intervenors, it is clear that based on environmental impacts, transportation requirements, costs, and licensing feasibility, GPUN's proposal to evaporate the AGW is superior to the other options.

t

~

Dr.Garh Baker Subscribed and sworn to before me

.this 13th day of May, 1988.

7.-

Wt Ya $t$,c~

s

~

L Notary Public i

My Commission expires: Auaust 21. 1989 1

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David R. Buchanan l I i

Subscribed and sworn to before me this ($b day of May, 1988. )

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b \ i_(d4 1 -Y Notary Public l l

i Est 54CMLU tito. NOTART PUSUC L980000fEST TW., OAMPNIE COUNTY ET 00M83105 EPIEES MPT.11.1989 My Commission er ires: sember. Pomevem Aseseem W emenes l

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&ntx.- 0 bas fJames J. Byrne f 0 Subscribed and sworn to before me this \2f2 day of May, 1988.

Uw \ l t d EI.t E . .F Notary Public m mecauu uso. NOTARY PUB 1K p y., DAgPHIN COUkiY y p gyggs stPT. I1.1989 W# ~

My Commission expires:

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- - - ~ - . - ~ - , . , - - . - - - - - - - - , - - - - , ---

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l [-42WE///'c 1 bo A.

l Subscribed and sworn to before me this iib day of May, 1988.

0 '

n NLu:kMA LOm s Notary Public ims escNild Uto. NCIARY PUguc LO40000(ttf TW DANPNit COUNTY av ceumssms crun sen.11,ises '

My Commission expires: h Puestme asseshees se sseenes l

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

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O u, h geuE

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/James E. Tarpinian Subscribed and sworn to before me this l h day of May, 1988.

6 Aw ( ~

\,

Notary Public tem usensur uso, notaar Pusuc L8400#0EREY TWP O.WPHIE COUNTY I NT C055LS$800 EIPlGE3 SEPT 11,1933 My Commission expires: ' ""*

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- . . . - - , - . . - . . , , _ , , , _ - - - - n,, , , . _ _ _ _ , , , - , _ , ,, ,.,-.,._,_n,,_, ____,__,___,,,_,,_,n,_ w..,, , , , . _, .--..r,.,.. -- -----,

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Charles S. Urland, .

Subscribed and sworn to before me this l [ day of May, 1988.

, . O 1 W LU4gno - 0

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Notary Public EffR MICHEll! Lf00. NOTARY PL'9!!C L0#00NMetY TWP.. DAUPHIN CL.,~ TY WY CONNIS$105 EIPIMS SEPT. 11.1989 My Commission expires: s w. p,wim Asiecaon of Norv,es j

% g* .h .

Yll$c+ WhNs a -

William W. Weaver Subscribed and sworn to before me this lYS day of May,1989.

I Llk 1.i di 'I Notary Public sus mesent use, move Pococ Lescosethf11sP Dampuscocm Of 00MISBN EPMI SEPT.11,1989 My Commission expires: h****

EXHIBIT A GARY G. BAKER, PH.D.

PROFESSIONAL BACKGROUND 1983 to Manacer of Environmental Controls-Three Mile Present Island GPU NUCLEAR, Middletown, PA Primary responsibility is to ensure that plant operations are in compliance with all relevant regulatory agencies. Also coordinate planning for the dismantlement of Saxton Nuclear Experimental Facility.

Environmental Controls Operations... Staffing... Budget Planning / Implementation... Policy Design / Review...Public Relations...Offsite Emergency Plan Response... Environmental / Radiological Surveys Programs...

SUPERVISE PROFESSIONAL STAFF OF SCIENTISTS AND UNION PERSONNEL

ANNUAL BUDGET -1.3 MILLION DOLLARS 1981 to Radiolocical Procrams Manacer-Three Mile 1983 Island GPU NUCLEAR, Middletown, PA Responsible for all phases of radiological environmental studies and monitoring programs. Contract Administration... Professional Testimony... Environmental Assessment Coordinator...Public Relations... Management Interface...

SUPERVISE PROFESSIONAL STAFF OF SCIENTISTS AND UNION PERSONNEL 1979 to Environmental Scientist II-Three Mile Island 1981 GPU NUCLEAR, Middletown, PA Designed and implemented radiological monitoring programs. Evaluate Exisiting Systems... Evaluate Data... Monitor Commercial Laboratories... Management Reports...

1978 to Environmental Scientist III-Pennsylvania 1979 Electric Active in all aspects of biological stuides and monitoring program for ten coal fired and two hydroelectric facilities. Program Evaluation... Design / Conduct Studies... Interpret / Report Technical Data...

1978 Instructor INDIANA UNIVERSITY OF PENNSYLVANIA, IndiGna, PA Taught General Biology and Microbiology at an undergraduate level, Other I served as a consultant to the educational and business community in Central

, Pennsylvania addressing microbiology problems and graduate student programs.

EDUCATION 1978 Ph.D.-Environmental Microbiology WEST VIRGINIA UNIVERSITY, Morgantown, WV 1975 M.S.-Environmental Microbiology WEST VIRGINIA UNIVERSITY, Morgantown, WV 1971 B.S.-Biology l MORRIS HARVEY COLLEGE, Charlestown, WV 1966 to Biolocy

1968 UNIVERSITY OF UTAH, Salt Lake City, UT l

i l

,a .

~XHI3IT 3 RESUME David R. Buchanan P.O. Box 480 Middletown, PA 17057 WORK HISTORY 07/80 - Present GPU Nuclear Corporation /GPU Service Corporatio.n. .

Current

Title:

Manager, Recovery Engineering, TMI-2 Dep t./ Loc. : Site Operations THI-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, 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 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 recovery programs work. Also, responsible for THI-2 Start-Up and Test activities.

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

Responsible for providing programatic direction and technical overview for on-site recovery activities related to reactor defueling/ disassembly as assigned by the Manager, Recovery Programs.

Assignments included defueling plus defueling water l clean-up systems, Waste Handling and Packaging 1 Facility, and the Sediment Transfer System.

09/82 - 11/84 - Manager Site Engineering, TMI-2 Same as during February 1986 through August 1986 08/81 - 09/82 - Manager, Project Engineering. Managed the Project Engineering Section to include direction of

}

t technical work, monitoring attainment of department cost / schedule goals and managing projects such as RCS Processing, EPICOR Yenting, and engineering involvement in the Quick Look Entry, i

_ _ _ - _ - _ - _ _ _ _ _ _ - - _ - - _ - - - - - .- _ -- u

I i) a I

0. 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 Employed at Bettis Atomic Power Laboratory in the positions of Associate Engineer, Refueling Equipment Design and Operations; Senior Engineer, F'uid Systems; Supervisor / Manager, Manual Welding Support; Materials Evaluation Laboratory 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 6 le

1 EXEIBIT C I 4

JAES J. BYRtE '

1 1

Twelve years experience in nuclear power. Qualifications include seven-and-a-half years in nuclear reactor licensing and four-and-a-half years in the US Navy (including three years on a nuclear power submarine).

PROFESSIONAL EXPERIEN_C_E_:

1981 to Present - GPU NUCLEAR CORPORATION, Three Mile Island (TMI) Nuclear Generating Station, Middletown, PA Manager, TMI-2 Licensing - Responsible for coordinating the efforts of staff engineers supporting the overall licensing interface with the Nuclear Regulatory Comission for the THI-2 recovery. Responsibilities include supervisory functions and technical management of efforts to obtain requisite approvals for on-going activities and satisfying NRC concerns arising from the recovery effort.

Senior Engineer - Responsible for coordinating specific THI-2 recovery activities including ensuring submittals to the NRC were technically correct and addressed the appropriate regulatory criteria.

1980 - 1981 - QUADREX CORPORATION, Field Engineering Division Staff Engineer - Licensing Engineer assigned to the THI-2 recovery project performin0 the same duties as listed above.

1978 - 1980 - SARGENT AND LUDY ENGIPEERS, Chigsco, Illinois Licensing Engineer, Nuclear Safeguards and Licensing Department -

Coordinated the preparation of the Final Safety Analysis Report for Clinton Nuclear Powe Station and prepared fire orotection safe shutdown and cold shutdown reports for several nuclear stations including Lasalle, Quad Cites, and Zion.

1974 - 1980 - US NAVY Lieutenant, USS Archerfish, SSN 678 - Served as a division officer on board a nuclear powered submarine. Qualified to stand watch as Officer of the Deck in charge of overall ship operation and as Engineering Officer of the Watch, responsible for safe operation of the ship's nuclear propulsion unit.

Page Two JAES J. BYRE EDUCATION:

University of Pittsburgh Pittsburgh, Pemsylvania Bachelor of Science, Civil Engineering PRORESSIONAL AFFILIATIONS:

Professional Engineer, State of Illinois Member, American Nuclear Society 9

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EXHIBIT D l

RESUME Thomas A. Grace 1 Upper Pond Road Parsippany, New Jersey 07439 (201) 316-7980 Education : Master of Environmental Pollution Control (Environmental Engineering)

Pennsylvania State University, Capitol Campus Middletown, PA January 1982 through September 1984 Post Graduate Studies towards Master of Science, Marine Biology California State University at Hayward Hayward, CA September 1976 through June 1977 Bachelor of Science, Biology California State University at San Diego San Diego, CA September 1972 through June 1975 Associate of Arts in Biology Contra Costa College San Pablo, CA June 1970 through June 1972 Experience : General Public Utilities - GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07504 Three Mile Island Nuclear Station, Units 1 and 2 Licensing Engineer, Environmental '

March 1981 to Present Bechtel Corporation San Francisco Power Division 50 Beale Street San Francisco, California 94119 Environmental Technician / Engineer March 1979 to March 1981 San Francisco Bay Marine Research Laboratory Point Molate Field Station Richmond, California 94801 Marine Biologist September 1976 to June 1977 Additional Infomation Member of the National and Pennsylvania Water Pollution Control Federations, Pennsylvania Electric Association SCOTE water subcomittee and the GPU Nuclear Speakers Bureau.

EXEISIT E o

JAMES E. TARPINIAN SUKMARY: Thirteen years' experience in applied health physics and radiation protection primarily associated with nuclear power facilities. A broad base of experience includes managing a radiological engineering program f or a maj or nuclear utility, technical planning of a large-scale decontamination project, quality assurance audit, and developing and conducting training programs for nuclear workers. Certified in comprehensive practice by the American Board of Health Physics.

RPM qualified per ANSI standards. Active in professional societies and standards setting organizations and made numerous presentations to technical and non-technical audiences. .

EDUCATION: University of Connecticut at Stcrrs B.A. Biology, 1975 University of Lowell X.S., Radiological Sciences and Protection, 1980 EXPERIENCE:

1984-Present Bechtel National Inc. - Manager, Radiological Engineering for'GPU Nuclear's Radiological Controls Department at Three Xile Island Unit-2, raporting to the RPM and supervising a staff of up to thirtaen engineers responsible for the ALARA planning and engineering for all TMI-2 recovery work. Other routine functions include effluent monitoring and reporting, 10 CFR 61 compliance and radwaste characterization, special source and radiation analysis, internal and external dosimetry assessments, eoergency response, and various other aspects of technical support for the Radiological Controls Depa r t me nt . Served as Deputy Manager of the group for two years prior to assuming present position in September of 1986. Previously served as the senior engineer in the Decontamination Planning Department.

Authored technical plans, planning studies, and data reports pertaining to the decontamination of TMI-2 facilities, and supervised the development of these products by other members of the group.

1980-1984 Bechtel North American Corp - Served in a variety of engineering and supervisory capacities in a group dedicated to decontamination and radwaste

JAKFS E. TARPINIAN engineering for the TXI-2 recover'y project.

Responsibilities included the development o.

decontamination specifications, technical and safety review of decontamination and radwaste procedures, ALARA planning and engineering, and supervising up to six engineers. Authored and co-authorod key technical and safety evaluation reports, served on several task groups reporting to the Office of the Director, and played a lead role in the early reactor building entry program.

1978-1980 University of Lowell- Graduate Assistant and Independent Consultant. Developed and taught i

undergraduate labs and lecture courses in physics and radiological sciences. Edited a training manual for radiographers under contract to the NRC. Developed and conducted workshops on radiation for school teachers. Developed and conducted a training program for the health physics staff at Vermont Yankee. ,

1974-1978 Electric Boat Division of General Dynamics Corporation- As Quality Assurance Auditor (1 year) was responsible for the evaluation and audit of systems and procedures for the quality control of nuclear submarine construction. Audit findings ware communicated directly to upper management. As a Radiological Controls Konitor (3 years) provided radiation safety for all aspects of nuclear submarine overhaul and refueling, including ALARA

. evaluation, monitoring the workplace for radiation hazards, and setting protectio'n requirements f or workers. Other duties included waste management, emergency response, and training of workers and peers. Qualified as Radiological Controls Xonitor per Navships 0288. " DOD Secret" security clearance.

PROFESSIONAL DATA: Certified in comprehensive practice by the American Board of Health Physics in 1984 and registered by the National Registry of Radiation Protection (NRRPT)

Technologists in 1976. Current offices held: Chair of the Nominating Committee of Health Physics Society (HPS), President of the Susquehanna Valley Chapter of the HPS, and Chair of ASTM E-10.04.02 standards writing task group on ALARA. Mem5erships: Health Physics Society, American Academy of Health Physics, Power Reactor Section HPS, NRRPT, Susquehanna Valley Chapter of HPS, Delaware Valley Society of Radiation Safety, American Nuclear Society ( ANS), Central PA Section of ANS, American Society for Testing of Materials (ASTM).

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EXHIBIT F 4-CAARLES 5. URI.AND. JR.

EXPERIENCE 1/84 - Present -

Grove Engineering. Inc.

Staff Radweste Engineer for GPU Nuclear at Three Mile Island Unit 2. Primary function is to develop. implement. and coordinate liquid and solid ,

radioactive waste manasteent activities to ensure compliance with Federal. State. and Local regulations and to minimize the cost and personal exposure incurred by processing and handling these wastes. Duties include performing economic evaluations of processing and disposal techniques for various wastes generated during the cleanup of Unit 2. specifying waste processing and volume reduction techniques, and performing analytical calculations for waste disposal classification and transportation. Specific accomplishments include preparation of the TMI-2 Accident Generated Water Disposal Report, with direct involvement in the

, technical evaluation of the various water disposal alternatives: iterative development of the TMI Abnormal Waste Disposal program with the Department of Energy, including contract and waste acceptance l criteria negotiations. development of a QA program tn ensure complience with the contract. and the actual preparation of specific submittals for the acceptance of various wastes: and participation in the shipment of the TMI-3 reactor fuel debris to 4

the Idaho National Engineering Laboratory.

I 6/83 - 4/86 Process Control Technician. Worked part-time at l the Borough of Middletown Wastewater Treate.ent l facility. Duties included performing daily and l process control laboratory tests, also provided plant operation guidance based on analysis of the laboratory test results.

l 6/83 - 1/84 Radwaste Technical Planning Co-Op Student. Held a i post-graduation co-op position with GPU Nuclear at l Thtee Mile Island Unit 2. Worked in the Waste l Management Planning Department. Duties included j performing basic engineering calculations and writing technical planning documents. ,

1/FT - 6/S1 Water Plant Operator. Worked at Borough of Middictown Water Treatment Plant. Duties included operation and preventative maintenance or potable water treatment plant and distribution systes.

'o' s

EDUCATION l

t Pennsylvania State University. Master of Engineering. Major in l Environmental Pollution Control. Nuclear Option.

1983 - Penngylvania State University. BT Civil Engineering Water Resources. Special emphasis on design and operation of Water Resources and Pollution Control facilities.

l 1981 - Lehigh County community College. AAS Civil and Construction Technology.

PROFF.SSIONAL American Nuclear Society: Water Pollution Control Federation.

Commonwealth of Pennsylvania Class B. Type I Sewage Treatment Plant Operators Certification.

i O

EXHIBIT G WILLIAM W. WEAVER eeeeeeeeeee'eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeee.

RELEVANT WORK EXPERIENCE Self-Employed Consultant 1987 to present On-Site Consultant at Three Mlle Island. Safety Review Group qualified. Member of Emergency Response team. Alternate Special Nuclear Material Coordinate. Work scope includes developing a PRA for Unit 2 and Chapter 15 accidents for SAR submittal. Performed multi-attributs decision theory analysis on block well disposition decision.

Babcock G Wilcox ,

1983 to 1986 On-Site PRA/ Reliability Consultant at Three Mlle Island. Member of emergency response team. Alternate Special Nuclear Materials Coordinater. Work scope included analyzing issues (using a probabilistic perspective) on a case-by-case basis such as exemption from seismic requirements, boron dilution concerns, and Fire Hazards Analysis. Performed reliability analyses on routine hardware such as plant cranes and unique hardware such as the Robot Vehicles.

1982 to 1983 Fellowship to Carden Business School. University of Virginia.

Work concentration'in Optimization. Scheduling. Decision Making under Uncertainty, and Strategy Formulation and Strategy implementation.

1980 to 1982 Supervisor of PRA Group. Responsibilities included technical supervisor of group and individual projects. Individual work scope included principal reviewer for Crystal River IREP. Input to Oconee/NSAC of 7ert, and peer reviewer on NUREG/CR-2300.

1975 to 1980 Reliability Engineer in technical staff group. Performed analyses (Fault Tree. RBO. FMEA. Markov) on mechanical and electrical systems including AFW. MFW, HPl. LPl. ESFAS. RPS. and ICS, Cost / Benefit and Aging Analyses. Project leader with budgetary responsibility for RAM RGO activities.

PAST ACTIVITIES

Reviewer for NRC/ industry Probabilistic Risk Assessment Guidebook.

' IEEE Subcommittee 5.4 Working Group

Atomic Industrial Forum Subcommittee on PRA

interdivisional BGW Reliability Committee

PARTIAL PUBLICATION LIST

'The impact of Aging Mechanisms on Reactor Safety Performance." (co-author with E. Celkers (BGW)). Nuclear Science and Engineering. Volume 68. No. 3. December 1978

' Aging Tgchniques and Qualified Life for Safety System Components." Nuclear Safety.

Volume 21. No.1. Jan - Feb 1980

' Deterministic Criteria Versus Probabilistic Analyses: Examining the Single Failure and Geparation Criteria." Nuclear Technology. Volume 47. No. 2. February 1980

"Auxillary Feedwater Reliability Analyses for Plants with BGW Designed NSS's." (co-author with R.S. Enzinna and R.W. Oorman (BGW)). ANS 26th Annual 14eeting. June 8-12. 1980.

Las Vegas

'Probabilistle Analysis and IREP Studies." (co-author with E.R. Kane (BGW) and P.M.

Abraham (Duke Power)). presented at the 7th Annual Nuclear Operating Experience Conference. Atlanta. March 1981

' 'Pitf alls in Current Design Requirements." Nuclear Safety. Volume 22. No. 3. May-June

1981

"Methodology and Application of Cost-Benefit Analysis: MFW System." (co-author with S. Ahmed (BGW)) presented at ANS 1981 Annual Meeting. Miami, FL

'A Decision Methodology for Quantitative Safety Goal Allocations for Nuclear Power Plants."

(co-author with S. Ahmed (B GW)). Proceedings of the ANS/ ENS Topical Meeting on Probabilistic Risk Assessment. Sept. 20-24, 1981. Port Chester (invited)

' ' Estimating Failure to Close Probabilities for Pressurizer Valves." presented at the International Meeting on Thermal Nuclear Safety. Chicago IL. August 29 - September 1.

1982

' Insights from the TMI-2 LOOP Analysise" (co-author with F.W. Deininger (Fen-Pac)), ANS.

Reno. June 1986

"A Method to Integrate PR A Results with Plant Upgrades." ANS Washington. OC. Novem-ber 1986 (invited)

EOUCATION

United States Merchant .'larine Academy - BS Marine Engineering Massachusetts Institute of Technology - MS Nuclear Engineering

George Washington University - MBA University of Virginia - All course work completed for Doctorate in Business Administration and Operations Rese&rch PROFESSIONAL CERTIFICATIONS

Certified Quality Engineer - ASQC

Certified Reliability Engineer - ASQC

3rd Engineer Steam and Olesel. Any Horsepower - USCG

3 Y'*

EXEID1T H 4

i 25 6 75.21 ENVIRONMENTAL RESOURCES Pt. I (2) Permits may be suspended or revoked by the Department in accor-dance with the provisions of the act, and all permits shall expire on that date as set forth on those permits.

(3) Appeals may be made in accordance with Chapter 21 (relating to Environmental Hearing Board).

Sebehapter C. PERMITS AND STANDARDS Sec.

75.21. Procering and disposal area permits.

75.22. Permit application and iuuance.

75.23. Plans for solid waste facilities.

75.24. General standards for sanitary landfill.

75.25. Standards for sanitary landfill liners.

75.26. Operating standards for sanitary landfills.

75.27. Standards for solid waste transfer stations.

' 75.28. General standards for storage of solid maste.

75.29. Standards for collection and transportation of solid waste.

75.30. Standards for solid waste incinerator facilities.

?$.31. General standa ds for hazardous solid waste.

75.32. Standards for sewage sludge and septic tank or holding tank maste.

75.33. Standards for construction and demolition waste disposal.

75.34. Standards for composting facilities.

75.35. Standards for esperittental facilities.

73.36. Bonding requirements for the processing and disposal of solid waste in a mine.

75.37. Standards for fly ash, bottom ash, or slag disposal areas.

75.38. General standards for industrial and hazardous waste disposal site:.

l

}75.21. Processing and disposal ares permits.

(a) A permit shall be required of any person, municipality, State Agency, or authority proposing to use or continue to use their land or any other land as a solid waste proccuing or disposal area.

(b) Permit n quirements shall not anply to farmers for normal farming operations, nor sh til permit requirements apply to the storage of by products which are utilized in the processing or manufacturing of other products unless such storage causo environmental degradation.

(c) The Deparvnent may issue a solid waste permit which is otherwise approvable if that per. nit is conditioned to exclude the disposal or processins; or both of solid waste fron municipalities whose official solid waste management plan designates another neility for receipt of their waste; providad, however, that disposal or processing or both of solid waste by a facility not designated for receipt of that waste by an official so'id waste management plan may be allow ed to the extent and so long as the facilities designated in the official solid 75 16

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Ch.75 SOLID WASTE MANAGEMENT 15 6 75.21 waste management plan for disposal,or processing or both of solid waste are,

. according to the determination of ths Department, unable to accept solid waste in a manner consistent with this chapter, (d) All facilities shall comply with the general standards set forth in this chapter, (c) Planning, design, and operation of any solid waste processing or dis-posal facility or area including, but not limited to resources recovery system, sanitary landfills, incinerators, compost plants, transfer stations, and solid waste salvage operations shall be in accordance with the standards of the Department.

(f) The Department, upon its own recommendation or the recommenda-tion of the Solid Waste Management Advisory Committee will adopt and revise and conduct periodic reviews of such standards as it deems necessary to prevent nuisances and pollution of the air, land, or waters of this Commonwealth. Such standards and revisions will include, but not be limited to, procedures to insure suitability of the site and the proper operation of the transfer station, sanitary landfill, incinerator, compost plant, solid waste salvage operation, or other solid waste processing or disposal operation.

(g) No person shall operate a solid waste processing or disposal facility area or system which is not in compliance with the provisions of this chapter.

(h) All areas of solid waste management systems, including all processing and disposal facilities, shall be operated in such manner as to prevent health hazards and environmental degradation. _

(i) Access roads suitable for use in all types of weather by loaded collec-tion vehicles shall be provided to the entrance of the site or facility.

(1) The minimum cartway width for two way traffic shall be 22 fett or a single cartway of 12 feet with pull-off intervals at no greater than 100 yards or with pull-off intervals at such distance where clear sight is available.

(2) For one way traffic, separate roads with a minimum cartway of 12 feet shall be available.

(3) The maximum sustained grade shall not exceed 12%.

(j) Provision shall be made for weighing or measuring all solid waste .

delivered to the site.

(k) Telephone or radio communications shall be located at the site or shall be readily available to the site.

(1) Fire protection shall comply with the following:

(1) Necessary measures shall be taken to prevent and extinguish fires; such measure shall be at least ecuivalent to any local municipal fire control ordinance or regulation.

(2) Adequate equipment for minimizing fire hazards shall be available at the site.

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25 { 75.21 ENVIRONMENTAL RESOURCES Pt.1 (3) All equipment and buildings shall be equipped with functional fire extinguishers.

(m) Limited access shall comply with the following:

(1) Access to the site shall be limited to those times when an attendant is on duty.

(2) Hours of operation and other limitations shall be prominently dis-played on a sign at the entrance.The sign shall be a minimum size of 3 feet by 4 feet.

(3) A gate or barrier and fencing as approved by the Department shall be erected to block access to the site during times when an attendant is not on duty.

(4) Access by unauthorized vehicles or persons shall be prevented.

(n) Unloading of solid wastes shall be controlled and restricted to the working face in accordance with the approved plan.

(o) Salvage shall comply with the following:

(1) Salvaging or reclamation of materials shall be permitted only when properly controlled to prevent interference with prompt sanitary disposal or processing of solid waste and only in such manner that no health hazard or nuisance shall be created. All salvaged materials shall be removed from the site daily or stored on site in accordance with the provisions of this chapter.

(2) Scavenging shall be prohibited.

(p) Vector control procedures shall be carried out when necessary to pre-vent health hazards or nuisances. The applicant shall submit a control program for the approval of the Department, including, when applica ble, the contractual

, arrangement for services with an exterminator.

(q) First aid facilities shall be available and job safety shall be practiced.

(r) Operational records and plan execution shall comply with the following:

(1) Daily operational records shall be maintained in a format approved j by the Department.

(2) A daily written log which I'sts the types and quantities of solid waste received shall be maintained by t; e site operator.

(3) Operational plans and specifications and the daily log entries shall be made available to authorized Department employes during inspections of the operation to determine compliance with pertinent rules, regulations, and sandards.

(4) An annual report shall be submitted to the Department summariz-ing the types and quantities of solid waste received during the preceding 12-month period.

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75 18 (101422) No.135 Feb.86 c.,,,,,4, e sees c i,ww j

6-4' Ch.75 SOLID WASTE MANAGEMENT 25 l 75.22 (s) A 25 foot zone shall be established upon which no solid waste may be deposited adjacent to perimeter property lines unless otherwise approved by the Department.

(t) Whenever asphaltic materials are utilized in the construction of a solid waste processing or disposal facility, those asphaltic designations shall be referenced to Pennsylvania Department of Transportation Form 408 and Bulletin Number 25, as i t effect January 1.1976, such references to be submitted by appropriate pagt number.

Notes of Doctonens Where a tocal ordinance neither directly not primarily governed engineering or geolosiC&I standards. but expressly furthered the tomaship's interest in protecting the health and property values of its residents and the aesthetics of its neishborhoods, the ordinance's 500 yard proximity requirement was not invalid for being in conniet with a 25 foot proumity requirement of subsectson (s). Sunny Forms. Ltd. v. North Codorus Township il Pa.

Commw. Ct. 311,376. 474 A.2d $6. 6o (1964).

Crees References This section cited in 25 Pa. Code 173.38 (relating to general standards for industrial and hazardous wate disposal sites).

l75.22. Permit application and issuance.

(a) Application. Application for a permit to operate a solid waste processing or disposal facility or area shall be made to the Department.

The application shall be made in two stages, such stages titled "Phase 1" and "Phase 11." Each phase shall be submitted with the necessary data and information required by the Department. The data and information required shall be that data and information categorized on the Module form which will be provided by the Department to the applicant for reproduction as required.

l (b) Design. Solid waste processing or disposal facilities and operations I

shall be designed by a registered professional engineer licensed as required Engineers Registration Law (63 P. S.

by the Professional Il 148 - 158) in accordance with the requirements of the Department The design plans shall bear the seal of the registered professional engineer on each document.

(c) Incomplete applications. When the Department has found an application incomplete, the applicant will be notified of the deficiencies in writing, and the application will be returned. The applicant shall supply j

the requested information within 90 days or such longer period as the j Department may specify or agree to. Failure to supply the information l

shall constitute sufficient cause for denial of the application.

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25 l 75.22 ENVIRONMENTAL RESOURCES Pt. I

. (d)

Issuance ofpermits. When the Department has determined that the application is completed and that the proposed design meets the require-ments of the pertinent regulations and acts, a permit will be issued.

(e)

Denial, suspension or revocation of permits. Denial, suspension or resocation of permits shall be in accordance with the following:

(1)

Reasons for the denial of a permit will be furnished, in writing, to the appilcant.

(2)

Permits may be suspended or revoked by the Department in accordance with the prosisions of the act.

(3) In case a permit is denied, suspended or revoked, aggrieved parties may appeal to the Environmental Hearing Board in accordance with Chapter 21 (relating to Environmental Hearing Board).

(f)

Reissuance ofpermits. Reissuance of permits shall be in accordance with the following:

(1) Permits are not transferable or assignable.

(2) If a change of ownership occurs, the new owner shall submit the following:

(i)

An application for a revised permit on a form to be provided by the Department.

(ii) A notarized statement attesting to the following items:

(A) Verification of possession of approved plans, maps, docu.

ments, schedules and commitments approved by the Department.

(B) Statement of agreement and intent to comply with the requirements, plans, stipulations and commitments previously ap-proved by the Department.

(iii) A clear and cogent narrative indicating the scheduling and procedure to be utilized in the transfer of ownership and subsequent operational inten.

Noen of Dednion County and township have standing to challenge issuance of a maste permit because they e have a direct. substantial and immediate interest in the establishment and operation of a*

totic waste landidl mithin their boundaries. Frontha Towns 4cp v. Department of Enwon-mental Raources. 499 Pa.162. 452 A.2d fit (1982). County has standing to contest amendments to an esistmg permit by appealing actions of DER in issuing order addressed to corporation engaged in sanitary landG11 operation specifying notations discovered, ordering afGrmatne actions and granting approvals for disposal of chemical mastes at the landidt.

Susquehanna County v. Department of Enwonmensat Resources. 500 Pa. $12. 438 A.2d 929 (1983).*

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75 20 (10$194) No.141 Aug.86 cw-ww r im c- w<* */ re==w ~

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Ch. 75 SOLID WASTE MANAGEMENT 25 6 75.22 Although appellet township had rebnquished solid easte management permit and the permit had been reissued to a tLtd party subsequent to Environmental Hearing Board decision. the appeal was not moot since the Department of Environmental Resources had been named as pnmsry appellet before the Board and the case could be considered a challenge to reissuance of the permit to anyone. Slavias v. New Carden Tomaship, Pa.

Comme. Ct. 496 A.2d 1309.1)ll (1983).

Ceees References I This section cited in 25 Pa. Code 175.38 (relating to generat standards for industrial and hazardous maste disposal sites).

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e Ch.75 SOLID WASTE MANAGEMENT 25 l 75.23

{75.23. Plaas for solid waste faculties.

(a) General requirements, Phase 1. Generally, Phase I plans for solid waste facilities shall conform with the following:

(1) The applicant shall describe the general operational concept of dis-posal or processing which will be submitted with the application. This con-cept shallinclude a narrative explaining the daily operational methodology of the proposed facility, the nature of the waste by source and type of material, the expected life of the facility, the proposed ultimate disposition of the site, and the anticipated environmental effects of the facility on the physical characteristics of the site and the adjacent properties.

(2) Adequate maps shall be submitted in the number prescribed by the Department and shall be drawn to the scale of one inch equals 200 feet or larger and shall contain ten foot contoer intervals. Maps shall be limited in physical size to no greater than 30-inch vertical height and 36 inch horizontal width.

(b) Geatral requirements. Phase 11. Upon notification by the Department of approval of the Phase I portion of the application, the applicaat may proceed with Phase 11, the preparation and submission to the Department of design plans and specifications. The design plans shallinclude but not be limited to the following data and information:

(1) Design plans submitted shall be limited in physical size to 30 inches vertical height and 36 inches horizontal width; clear and legible reductions will be acceptable.

(2) Grid or coordinate system, or both, for the entire site. The horizontal control system shall consist of a grid not to exceed 200 square sections. The grid shall be controlled and tied to a permanent physical marker or object located on site. Tbc vertical control shall be tied to an elevation established for the permanent marker.

j (3) Such further information as may be required by the Department to insure that the proposed solid waste processing or disposal facility or area complies with the provisions of this chapter.

(75.24. General standards for sanitary landfill.

(a) Conformity. Sanitary landfill operations shall conform to the stan-dards listed in this chapter and to the specific standards for sanitary landfill operatioits contained in this subchapter.

(b) Phase I - Application requirements. General standards for Phase I application rec,uirements shall be as follows:

(1) A descriptive narrative shall be written and submitted with the application, 75 21 (101425) No.135 Feb.86

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' 25 6 75.24 ENVIRONMENTAL RESOURCES Pt. I (2) Information on topographic maps shall include, as a minimum, the following:

(i) Borrow areas, on site or off site. Borrow shall be the material excavated for the construction of fills, use as cover material, or other construction purposes.

(ii) Location of public and private water supplies, wells, springs, streams, swamps or other bodies of water within 1/4 mile of the proposed landfill site property lines.

(3) Certain factors may serve to limit normal sanitary landfill opera-tions and information pertaining to these factors on site and within 1/4 mile l of the landfill site shall be included as follows:

(i) Location of underground and surface mines and maps showing the

, extent of deep mine workings, elevation of the mine pool, and location of j mine pool discharges.

(ii) Location of gas and oil wells.

(iii) Location of high tension power line right of ways.

(iv) Location of pipeline right of ways.

(v) Location of geologic and hydrologic features.

(4) A soils, geologic, and groundwater report of the characteristics of

, the site shall be included as required by the Department. This report shall be

, based on a soils, geology, and hydrology investigation and on a published standard soil survey or equivalent data and shall encompass the following j criteria:

I *

(i) A sufficient number of excavations and birings or wells shat! be provided to determine the valid and conclusive soil, gology, and ground-water conditions. Exploratory borings or wells shall be provided. These borings or wells shall be drilled ten feet into the groundwater or bedrock or, in the absence of groundwater or bedrock, shall be dri!!cd a distance equal l to the planned depth of refuse to be deposited. A minimum of three borings ,

or wells shall be drilled ten (cet into the groundwater to delineate ground-wster flow systems. Groundwater monitoring systems shall be required as follows: A minimum of one groundwater quality monitoring point shall be established in each dominant direction of groundwater movement and one monitoring point up-gradient of the site Location of monitoring wells shall be approved by the Department in advance of drilling. Monitoring points shall not be located in excess of 500 feet of the permitted area. Monitoring points shall be accessible to the applicant. Chemical analysis and hydro-logic data shall be submitted quarterly to the Department in a format 5

provided to the applicant by the Departrnent. Each monitoring point shall be purged prior to obtaining the annual sample analysis. -

75 22 (101426) No.135 Feb.86 cw e oss c- - we l

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4 Ch. 75 SOLID WASTE MANAGEMENT 25 { 75.24 (ii) Detailed soil descriptions shall be submitted from excavations for materials proposed for use as renovating soil or cover material.

(5) When the Department has determined that the information required under this section is verified and complete, the applicant shall be notified in writing that Phase I site approval is granted. This approval is granted to the applicant for the purpose of developing the detailed design and operational

. plans required in Phase 11 of this section.

(c) Phase !! - Application design requiremnts. General standards for Phase 11 application design requirements shall be as follows:

(1) The design plans shallinclude a cross section of the access roads and all weather roads identifying construction. A construction schedule shall be submitted by the applicant to the Department,in the format established by the Department. The design plans shall include details relative to the following:

(i) Compaction of solid waste.

(ii) Application of daily cover material.

(iii) Elevation and grade of final cover.

(iv) Management of surface water.

(v) Erosion control.

(vi) Revegetation procedures to be used.

(vii) Schedule of filling.

(viii) Site preparations.

(ix) Monitoring devices.

(x) Location and limits of areas previously filled.

(zi) Cross sections indicating the interface details between areas previ-ously filled and areas to be filled, where applicable.

(xii) Limits of construction defined by grid controls.

(xiii) Borrow areas on site defined by grid controls.

(xiv) Location, description, and purpose of all casements existing on site and a definition of all title, deed, or usage restrictions relative to the site.

(xv) Location of gas and oil wells on site.

(xvi) Location of public and private water supplies on site.

(xvii) Location of underground and surface mines on site.

(xviii) Cross sections shown on the plans shall be referenced to the grid system for horizontal location, whenever applicable.

(tix) Grades required for proper drainage of lifts.

(xx) Cross sections, grades or profiles, or both, of diversion ditches, capacities and calculations for ditch volume.

(xxi) Grades indicating the depth of soil available at the site for cover material.

75 23 (101427) No.13$ Feb.86 4

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25 6 75,24 ENVIRONMENTAL RESOURCES Pt.1 (2)

Design criteria shall comply with the following: ~

.(i)

Provisi9ns shall be made to manage surface water at the sanitary landfill site. Calculations indicating water quantities shall be submitted to the Department based on the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rainfallin inches, to be expected once in 10 years.

(ii)

The grading of the Gnal surface of the 011 area shall provide a slope of Department. than 1.0% but not exceeding 15%, except as approved by the not kss *

(iii) When final grades are approved exceeding 15%, but in no case exec.eding 33%, a horizontal terrace,10 feet minimum in width, shall be cor,structed on the slope for every 20 feet maximum rise in vertical eleva-ti,;n of the slope. The gradient of the terrace shall be 1.0%.

(iv)

Access roads to the entrance of the landfill shall be paved or surfaced with such materials as asphalt, gravel, or cinders and shall be provided with a base capable of withstanding anticipated load limits.

(s)

An all weather road negotiable by loaded collection vehicles shall be provided from the entrance gate of the landfill to the unloading area, treatment facility, or lagoon located on site, unless provi: ions are made for an alternate disposal area on site with all weather roads to the unloading area to be used during periods ofinclement weather.

(vi)

All weather roads to the unloading area shall meet the require-ments set forth in this chapter relating to axess roads.

(vii)

All solid waste shall be w eighed on permanently installed or porta-ble truck scales which are checked annually for accuracy or measured in a consistent manner approved by the Department.

(viii) Methods other than weighing for determining the quantity of solid w aste delivered to sanita ry landfills or landfills used by industrial, commer.

cial, municipal, and agricultural establishments will be reviewed by the Department on their toerits.

(ix)

Final cover shall be soils that fall within the United States Depart-ment of Agriculture (USDA) Textural classes of sandy loam, loam, sandy clay loam. sitty clay loam, and silt loam. All other final cover materials must be approved by the Department. The soil must compact well, not crack excessively when dry, and support a vegetative cover. The coarse fragment content, partic'es not passing the No.10 mesh sieve,2mm., shall not exceed 60% by volume.

(x)

Renovating soil suitable for natural renovation of teachates shall be soils that fall within the USDA Textural classes of sandy loam, loam, sandy clay loam, sitty clay loam, and silt loam. All other renovating materi-als must be approved by the Department. The coarse fragment content, fragments not passing a No.10 mesh sieve, 2mm., shall not exceed i 75 24 001428) No.135 Feb 86 c.cm ,*,eina c - ,,e e . w

Ch.75 SOLID WASTE MANAGEMENT 25 { 75.24 60% by volume. The combustib!c or coal content, or both, shall not exceed 12% by volume.

(xi) Soils to be used as daily and intermediate cover material shall be soils that fall within the USDA Textural classes of sandy loam, loam, sandy clay loam, silty clay loam, loamy sand, and silt loam. All other cover materials must be approved by the Department. The coarse fragment content, fragments not passing the No.10 mesh sieve, 2mm., shall not exceed 75% by volume, and the combustible or coal content, or both, shall not exceed 12% by volume.

(xii) Boulders and stones as classified by the USDA shall be separated out or excluded from soils to be used for any type of cover material or renovating soils.

(xiii) Landfills constructed without liners shall have a minimum of six feet of renovating soil between the refuse and any sidewall with a slope less than 110 degrees as measured from the horizontal bottom of the fill area. lf sidewall slopes are 110 degrees or greater, reference should be made to subparagraph (xv) of this paragraph. The renova'.ing soil shall have the characteristics as specified in subparagraph (x) of this paragraph.

(riv) All landfills constructed without liners or leachate collection sys-tems must have a minimum of a feci ' renovating soil beneath the refuse and abov: the high ground water table or bedrock for one s. foot lift. If more than one lift is proposed an additional ratio of I foot renovating soil to each one foot of refuse must be provided for each additional lift. The renovating soil may be undisturbed soil or emplaced soil and must have the characteristics for renovating soil as specified in this section.

(xv) In order to maintain the one to one ratio of renovating soil to refuse in sites without liners or collection systems and with ground surfaces ,

with slopes less than 175 degrees or with sidewalls with slopes equal to or greater than 110 degrees as measured from the horizontal bottom of the fill area, or both, the following criteria must be applied:

The total depth of renovating soil at say point ce the site wit! be measured on a vertical plane passing through that point from the upper surface of the renovating soil.

For saample: In a landfill that is to be ocastructed in a ravine with a V shaped cross. i secuoa. the depth of renovating soil measured in a verucal plane at any point ce the site must be equal to or greater than the refuse inunediately above it.

(xvi) Coal seams and coal outcrops shall be isolated from refuse deposits l by earthen barriers. The earthen barriers shall be a minimum thickness of ,

25 feet of natural and compacted soils. All mine openings shall be sealed in accordance with the mining laws of the Commonwealth, l (xvii) The site shali not have a flooding hazard of greater frequency than once in 100 years, and direct fill into water shall be prohibited.

(

75 25 (101429) No.135 Feb.86

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25 6 75.24 , ENVIRONMENTAL RESOURCES Pt. I (diii) The site shall be designed and operated in a manner which will prevent or minimize surface water percolation into the solid waste material deposits.

(xix) Sites not meeting the criteria listed in this paragraph for natural renovation for the prevention of groundwater pollution may be utilized if leachate collection and treatment facilities are approved by the Department.

(u) Individual cells of refuse sball be placed in layers not exceeding eight feet in depth as measured from the working plane.

(ui) A finallayer of cover material, compacted to a minimum uniform depth of 2 feet and having the characteristics specified in subperagraph (ix), shall be placed over the entire surface of each portion of the finallift.

(uii) The final cover layer shall be completed within 2 weeks after placement of solid waste in the final lift. Completion shall include perma.

nent stabilization of all slopes.

(uiii) Divenion ditches costructed shall be fully dimensioned on the plans indicating length, gradient, and cross sectional configuration. Side slopes of diversion ditches shall not be greater than two horizontal to one vertical, 50%

(uiv) Gas venting systems and gas monitoring systems shall be installed at all sites. Gas venting may be accomplished by construction of lateral or vertical venting, or both. Pipe vents located within 100 feet of any building, mechanical structure, or roadway shall be constructed so as to discharge above the roof line of such building or mechanical structure and to dis.

charge a minimum of 12 feet above the roadway surface.

(uv) The plans shallinclude a schematic presentation indicating the methods of filling to be utilized, that is, trench method, area method, or

both in combination.

(uvi) All utilities to be installed at a facility shall be shown in plan, section, and profile, where applicable. The design shall initiate at the point of service connection, on site or off site, and be shown complete to the point of usage.

(uvii) All fencing and barriers to be constructed at a facility shall be shown on the plans in full elevation, fully dimensioned, and the type of construction materials shall be identified and specified.

(3) A detailed written operational plan shall be submitted to address the standards as specified in this chapter.

crees nacersee.

This secuen cited in 23 Pa. Code l ?$.38 (relating to gener I standards for ladastrul and hazardow waste disposal site 75 26 (101430) No.135 Feb.86 c, ,6, e ions e- a or %

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Ch.75 sot.lD WASTE MANAGEMENT 15 l 75.25 '

{75.25. Standards for sanitary landitu i es.

(a)

/trmeability. A manmade liner shall be corisidered saltable for use as an impermeable barrier when the value of permeability is 1 x 10 7 cm/sec or Ims.

(b)

Resistance to leachatt. Manufactured membranes, such as Ethylene Propylene Diene Monomer (SPDM), Chlorosulfonated Pol) ethylene Poly Ethylene (PE), Polyvinylchloride (PVC), Elasticized Polyolefin, Chlorinated.

Poly ethylene (CPE), Polychloroprene (Neoprene). Asphaltic Mesh, and Iso But)lenc Isoprene (Butyl) shall have a manufacturer's warranty that the membrane is capable of preventing leachate from reaching the soil under the membrane. The composition of raw leachate for liner evaluation is expected to be within the range of maximum values shown in the fouowing table:

Leachate Composition Component Maximum Val m ph 8.5 Hardnas 8120 (carbonate)

Alkalinity (carbonate) 9500 Calcium 2570 Magnesium

' 410 Sodium 3 00 Potassium 1860 Iron (total) 1640 Chloride 2350 Sulfate 1220 Phosphate 290.c i Organic Nitrogen 550 Ammonia, Nitrogen 845 Condactivity 1200 BOD 32a00 COD 50715 Suspended Solids I 26500 Total Organic Carbon 30000 Note: Above values given in milli.

1 grams per liter escept: '

, pH (pH units)

Conductivity {Microchms per cen-timeter) l (101431) No.135 Feb.86 I

l l

\

t i

25 l 5.25 ENVIRONMENTAL RESOURCES Pt.1 (c) Deposit Whenever a particular waste material, such as sludge, is proposed to be deposited in a lined sanitary landfill, data shall be submitted to th: Department by the applicant indicating the miscibility of the membrane material relative to an undiluted exposure of not less than 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months to tbc particular waste.

(d) Physical properties. All data submitted as physical properties shall -

have the appropriate current ASTM Test Method designated. In order to providi the Department with a basis for evaluating the various manufactured membranes, the applicant shall require the manufacturer to submit, at least, the following basic data, when applicable:

(1) Tensile strength.

(2) Elongation.

(3) Tear resistance (lbs/ inch).

(4) Ozone resistance.

(5) Ultraviolet resistance.

(6) Permeability (cm/sec).

(7) Operating temperature range.

(8) Thickness (inches & mils).

l (9) Hest resistance.

(10) Sub base preparation (minimum).

l (11) Method of splicing & properties of splice material.

(12) Slope placement limitation in percent or ratio. ,

(13) Resistance to oxygenated solvents.

(14) Resistance to aromatic and halogensted solvents.

(15) Resistance to aliphatic (petroleum) solvents.

(16) Cold crack temperature.

(17) Shrinkage (per cent in length and width).

(18) Resistance to methane.

(19) Any unique or limiting characteristics.

(20) Weight per square feet in pounds.

(21) Method of patching.

(22) Resistance to soil burial.

(e) Subgrade bearing criteria. For all liner installations, the subgrade

shall have a minimum bearing capacity of 1 1/2 tons per square foot plus 1/2 of the total applied load in pounds per square foot. In areas where fill may be required to achieve the desired subgrade elevation, compaction shall be 90% of the standard proctor density test.

(f) , Asphalt Membranes -)1 eld constructed. All asphaltic designations shall be referenced to PennDOT Form 40s, specifications by section, para-( graph, and page and further referenced to PennDOT Bulletin Number 25, 75 28 (101432) No.135 Feb.86 ew s ,em e ww

e n

Ch. 75 SOLID WASTE MANAGEMENT 15 l 75,25 by page and class of material. The native ground, when in direct contact with the membrane section, shall be able to maintain a minimum field capacity,that is, moisture retention, of 5.0% dry weight of soil.

(g) Membrow iMckwss. Standards for membrane thickness shall be as follows:

(1) The trinimum allowable thickness for a manufactured membrane with properties similar to approved Polyvinyl Chloride (PVC) membranes shall be 20 mil.

(2) Membranes constructed of asphalt pavement material similar to PennDOT Bituminous Surface Course ID 2A, Wearing Course, as described in Section 420, PennDOT Form 408 Specifications, shall have a compacted thidness of not less than two inches. The surface of such membranes shall be further sealed whh an application of AC.20 or PC.! as specified in PennDOT Bulletin Number 25. The seal costs shall be applied at a quantity not less that 6/10 of a gallon per square yard,in two applications of approximately 3/10 of a gallon per square yard each.

(3) Asphalt membranes constructed to accomplish a stabilized base membrane shall be constructed according to Section 330, Soil Bituminous Base Course, PennDOT Form 408 specifications. The thickness of stabilized base membranes utilizing central plant mixing and placement through a paver or spreader box or utilizing mixing and placement utilizing a motor paver shall be three inches compacted. The thickness of stabilized base membranes utilizing mix in place methods such as windrowing shall be 12 inches. Stabilized 'ase membranes shall be scaled in tiie same manner as asphalt pavement membranes.

(4) Asphalt materials utilized to construct stabilized base membranes shall be limited to water asphalt emulsions, PennDOT designations E 5 or E-6, as specified in PennDOT Bulletin Number 25.

(5) Asphalt membranes constructed by spraying asphaltic material shall be constructed according to the applicable provisions of PennDOT Form 408 Specifications. Prior to the placement of any asphaltic material,the subgrade shall be constructed conforming to the grades and cross sections shown on the design plans. The subgrade shall be considered as that portion of the work which has been prepared as specified in this section and upon w hich a layer of specified asphaltic material is to be placed. The finished subgrade shall be true to cross section, hard, uniform, smooth, free of all debris, weeds, or other foreign material and, when tested, shall attain a relative density of at least 90% as measured by the standard proctor density test. The finished subgrade shall be stabilized with an application of MC 30 or an application of MC.

70 when the slope does not exceed 15%, as specified in PennDOT Bulletin Number 25, the application to be applied at a quantity 75 29 (10!433) No.135 Feb.86

~

25 { 75.25 ENVIRONMENTAL RESOURCES Pt. !

not less than 0.30 gallocs per square yard as placed by an approved pressure distributor. The subgrade shall be further sealed with an application of AC.

20. PC 1, or RC 800. RC 250 where the slope does not escoed 15%, at a quantity not less than 0.75 sallons per square yard. The seal coat shall be placed in two applications utilizing a distributor truck equipped with an offset spray bar with an allowable variation not to saceed 0.05 gallons per square yard from the specified rate of application.

(h) Subgradefor monitoring liners. The su bgrade for monitoring purposes shall consist of a fine graded subbase with a 12 inch base course. The base course shall be of sandy material not less than 70% by weight of sand between 2mm and .05mm in size and not more than 15% by weight of clay less than t

.002mm in size to create a flow zone for monitoring purposes. A sub-drain system consisting of a four inch drainage pipe shall be installed in the base course perpendicular to the direction of liquid flow at a spacing pattern of not more that 175 feet on center. To protect the integrity of the flow zone and to insure a permeability contrast between the 12 inch base course and the fine graded native soil subbase, an application of MC 30, as specified by PennDOT 4

Bulletin Number 25, shall be applied to the fine graded native soil subbase at an i application rate of not less than .25 gallons per square yard. Where the native soil subbase has a permeability ofless than I X 10 dem/sec., the MC 30 sk11 not

, be required.

(i) Protective cover. The protective cover for all sanitary landfill mem-branes shall consist of 6 inches of selected clean earth material and at least 8

) inches of clean earth material for a total earthen cover of not less than 14 inches. The 6 inch selected clean earth material be placed directly upon the membrane and shall be selected so that no aggregate, rocks, or solid material

, which is larger than 2 inches in greatest dimension will be placed in this zone.

The initial lift of refuse placed upon the 14 inch protective cover shall consist of two feet of selected refuse, selected refuse being that refuse which does not contain bulky waste or items where the greatest dimension is larger than 3 feet.

(j) Slopes. The minimum subgrade for all sanitary landfill liners shall be i

1.0%. The maalmum slope for all sanitary landfill liners shall be 20%. The maaimum side slope for manufactured membranes shall be 33% or the manu.

facturers' recommendation, whichever is the lesser. The maaimum side slope for asphalt ic membranes shall be 25%.

(k) I.sechare collectionfor man made liners. The applicant shall submit to the Department full and complete calculations based on natural precipitation indicating the amount of leachste generation anticipated annually over the operationallifespan of the site the and a period of 10 years following closure of the site. Natural precipitation shall be calculated on the basis of the 75 30 (101434) No.135 Feb.86 ceas,enosr e % m ,a i

i

)

1 l

l I

Ch.75 SOLID VASTE MANAGEMENT 25 6 75.25 i

past 25 year average for the nearest recording station of record.The teachate collection system shall be installed and operable in order to collect and retain the calculated volume of leachate expected during the initial first year opera-tional increment.

(1) D.-olnage system. A drainage system for the channslization and collec-tion of teachate may be installed in proalmity to the protective cover. The drainage system, whether collection piping, french drain, or other types shall not penetrate a distance in excess of ten inches into the protective cover.

(m) Collection ditches. Collection ditches installed at the extremities of the sanitary landfill liner shall be constructed with an impermeable wetted perime.

ter. The collection ditches shall be sized to accommodate the maximum antici-pated volume of leachate flow with a factor of safety not less than 25%.

(n) Ditches and drainage. All ditches and drainage facilities shall be shown on the design plans indicating gradient, elevations,'and fully dimen-sioned cross sections.

(o) Additional des /gn criteria. Additional design criteria for leachate col-lection facilities shall be as follows:

(1) The area designed for filling shall not exceed 70% of the hydraulic loading capacity of the treatment facility.

(2) After five years of operation, the applicant shall revise and resubmit the plans and design of the collection system as required by existing condi.

tions and criteria.

(3) A metering device to record the daily flow of leachate in gallons per minute from a completed lined insiement shall be installed at the orifice of that increment. An accurate record of the measured flow shall be maintained by the operator and submitted to the Department on a quarterly basis.

(4) When a lined landfill is proposed, the aggregate amount of liquid storage to be provided shall be 100% of the precipitation and induced liquid applied to the operationallined increment in one year. An operational subsec-tion of the lined area shall have a minimum two lifts of refuse in place prior to proceeding to an additional subsection. The aggregate volume of required liquid storage shall provide an allowance not to exceed 25 gallons per cubic yard of liquid capacity.

(5) When a lined increment of a site is completed, final covered, prop-erly graded, and vegetated, a total maximum allowance of 70% of natural precipitation shall be considered runoff.

(6) Natural systems may be utilized to collect leachate from landfills.

The methods to utilize the natural systems may be the manipulation of the ground water flow systems or naturally occurring impermeable zones.

75 31 (101435) No.135 Feb.86

ENVIRONMENTAL RESOURCES Pt. I 25 i 75,25

.(i) When collection and treatment ir proposed to manipulate or util.

ize natural ground water now systems, the applicant shall submit design data, plans, and specifications for the approval of the Department. l (ii) Detail analysis of the ground water flow systems must be submit-ted and include, as a minimum, ground water table maps, piezometric surface maps, hydraulic gradients, hydrologic connections, flow directions, flow regimes analysis, transmissivity, and permeability data.

(iii) When naturally occurring impermeabic zones are to be utilized, ;

the minimum site requirements shall be as follows:

(A) Zones with a uniform thickacts of greater than two feet must have a permeability of less than 1 x 10 '7 cm/sec.

IB) Zones with a uniform thickness of greater than four feet and an upward ground water gradient into the zone may be approved with a maximum permeability of less than 1 x 10 4 cm/sec.

Documentation insuring the p*optr treatment and disposal of all (7) teachate collected shall be provided to the Department by the applicant.Such documentation may include a contractual agreement with the operators of a treatment facility off site and a contractualarrangement for the transporting of teachate to such site.

Whenever the distance between the high water table and the MC 30 t (8) monitoring flow plane is less than 4 feet, a groundwater drainage system consisting of drain tile, piping, french drains, intercepts, or other conven-tional subdrainage mechanisms shall be installed to maintain a 4 foot isola-

- tion distance between the MC 30 and the groundwater table.

Ness et pecuses A tow nsh:p lacks standing to bring an appeal as a party aganeved by a DER desion regarding off site Isachste collecta and treatment plans of a sanitary landfill within the township, unims the township can show a direct, immodate, or substantial advme effect on iu munepal purpees in carrying out local government functions, or that the DElt has acted in some = sy to affect the rishu and claims ofindwidual proserty ouem against the Depenment in which the township would set as trustw Strashrg Assmetes v. NewIta TownsAlp. 32 Pa. Comme. Ct. 314, $23,415 A 2d 1014.

1017 - 1018 (1980).

Cross Refwescos Tbs secta cited in 25 Ps, Code 175.38 (relattag to general standards for industnal and hasardous easte disposal sites).

' 75 32 c,.,,e, e- asv %

(101436) No.135 Feb.56

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ML20154E247

Text

Title:

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