ML20154E285

Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contentions 4b in Part & 6 on Chemicals).*

ML20154E285
Person / Time
Site:	Three Mile Island
Issue date:	05/16/1988
From:	Lewis T GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20154E212	List: ML20154E208 ML20154E230 ML20154E247 ML20154E268 ML20154E285 ML20154E293 ML20154E313 ML20154E325 ML20154E349 ML20154E368 ML20154E383 ML20154E406
References
OLA, NUDOCS 8805200155
Download: ML20154E285 (4)

Text

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s May 16, 1988 UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of- )

)

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

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

Station, Unit 2) )

LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (Contentior.s 4b in part and 6 on Chemicals)

Pursuant to 10 C.F.R. S 2.749(a), Licensec states, in sup-port of its Motion for Summary Disposition of Contentions 4b in part and 6 (on Chemicals), that there is no genuine issue to be heard with respect to the following material facts:

1. The use of chemicals au TMI-2 is controlled by the TMI-2 "Chemical Control Procedure" and implementing procedures.

2. These procedures require that before a new chemical >

substance may be used at TMI-2 for a particular use, an engineer-ing evaluation must be performed, and one of the particular fac-tors that must be considered is the protection of ion exchange media used in the Submerged Demineralizer System (SDS) and CPICOR

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3. Pursuant to these procedures, chemicals introduced into accident generated water have been evaluated for their effects on.

r' the SDS and EPICOR II systems, and the introduction of substances that could impair the SDS and EPICOR II-systems has been minimal.

4. The compatability of the accident generated water chem-istry with the EPICOR II and SDS systems is also demonstrated by the observed performance of these systems, which are frequently operated, continually monitored, and consistently achieve a sub-stantial decontamination notwithstanding the chemical constitu-ents of the accident generated water.

5. The accident generated water processing systems at TMI-2 remove chemical as well as radiochemical constituents from the water, with the result that levels of chemicals other than boron and sodium in processed water are low.

6. Certain batches of accident generated water will be used for future cleanup activities, which could increase the level of chemicals in such batch'es, but reprocessing to the ex-tent necessary will reduce chemical constituents to desired lev-els. Licensee periodically performs chemical analyses to keep track of the water chemistry of accident generated sources.

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7. Evaporator and vaporizer influent criteria have been established for radionuclides, boron, and sodium, and vaporiza-tion of distillate will not be permitted until it has been t

determined analytically that the constituents of the distillate are below the established concentrations.

8. If a batch of accident generated water needs further processing to satisfy the influent criteria, it can be reprocessed until the influent criteria are achieved.

9. The evaporator itself is being designed to be compati-ble with the water chemistry of the accident generated water.

10. The evaporator design includes features that negate potential adverse effects of chemicals on evaporator performance.

11. If a chemical constituent in the evaporator influent did reduce the efficiency of the evaporator to a significant ex-tent, monitors on the evaporation system would trigger an alarm; and if radioactivity release limits were exceeded, the radiation monitor on the evaporator would terminate the evaporation pro-Cess.

12. The evaporator will reduce by over 1,000 the levels of chemicals released to the environment.

13. The deposition of chemical substances, principally so-dium borate, attributable to evaporation will be orders of magni-tude below the levels of salt deposition that have been deter-mined to be innocuous, and therefore the chemical constituents in

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l evaporator effluent will.have no significant impact on.the envi-

_ronment.

Respectfully submitted, SHAW, PITTMAN, POTTS &'TROWBRIDGE AwT2j%Q ,

Thomas A. .Baxter, P.C.

David R. Lewis Counsel for Licensee.

2300 N Street, N.W.

Washington,' D.C. 20037 ,

(202) 663-8000

~ Dated: May 16, 1988.

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