ML20154E313
| ML20154E313 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/13/1988 |
| From: | Buchanan D GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20154E212 | List: |
| References | |
| OLA, NUDOCS 8805200168 | |
| Download: ML20154E313 (45) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC GAFETY AND LICENSING BOARD r
In the Matter of
)
)
GPU NUCLEAR CORPORATION
)
Docket No. 50-320-OLA
)
(Disposal of Accident-(Three Mile Island Nuclear
)
Generated Water)
Station, Unit 2)
)
t AFFIDAVIT OF DAVID R. BUCHANAN (Contentions 4b in part and 6 on Chemicals)
County of Dauphin
)
)
ss.
Commonwealth of Pennsylvania
)
DAVID R. BUCHANAN, bt.ing duly sworn according to law, de-poses and says as follows:
i 1.
My name is David R. Buchanan.
My business address is P.O.
Box 480, Middletown, Pennsylvania, 17057.
I am employed by l
c GPU Nuclear Corporation ("GPUN") as Manager, Recovery Engineer-ing, at Three Mile Island Nuclear Station, Unit 2.
In that posi-l tion, which I have held since August, 1986, I am responsible for l
l all engineering support, er. cept for defueling, to the TMI-2 Divi-l sion.
A mechanical engineer with more than 24 years of experi-ence in the nuclear industry, I have worked in various engineer-ing positions for GPUN (and its pr..docessor) in support of the T
f 1
l k
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o.
-C 4
recovery effort at TMI-2 since July, 1980.
I previously spent over 16 years in engineering work at Westinghouse Electric Corpo-ration's Bettis Atomic Power Laboratory.
A summary of my profes-sional qualifications and experience is attached hereto as Exhibit "A".
P 2.
I make this Affidavit in support of Licensee's Motion for Summary Disposition of Contentions 4b (in part) and 6.
I have personal knowledge of the matters stated herein and believe them to be true and correct.
In this Affidavit, I will explain why the chemical constituents of accident-generated water will not result in the vaporizer influent criteria or atmospheric re-lease limits Leing exceeded.
I.
Influent Criteria 3.
As discussed in my Affidavit on Contentions 4b (in part), 4c and 4d, all accident generated water (AGW) will be pro-cessed through the evaporator prior to release to the environment 4
via vaporization.
The designed flexibility of the disposal sys-I tem permits the evaporator assembly to be de-coupled from the va-porizer assembly.
In this configuration, the evaporator operates independent of the vaporizer and processes the water in a batch cycle method of operation.
Conversely, if the vaporiter is cou-pled to the evaporator during operations, the water will be pro-cessed in a continuous type method of operation.
See the System Description, attached hereto as Exhibit B, pages 11-22 for an i
expanded discussion of these two operational modes. i f
E*
4.
The procese control of atmospheric releases during the evaporator and vaporization process will be implemented via the radiation monitoring and radiochemical sampling of the influent to the vaporizer section.
Establishing process control at the vaporizer influent conservatively assumes a 100% carry-over frac-tion through the vaporizer assembly.
There is no credit for plate out or solids aeparation in the heaters, flash tank or ex-haust stack.
The radionuclides and their permissible level of concentrations as influent to the vaporizer assembly for atmo-spheric releases are listed in Table 3-1 of Exhibit B.
This table conservatively assumes that certain radionuclides, not pos-itively identified in the AGW samples, nevertheless exist at the stated lowest limit of detection.
These assumed radionuclides, identified by an asterisk, are included in the table.
Table 3-2 of Exhibit B identifies the evaporator influent and effluent criteria for disposal system operation in the continuous cycle configuration.
5.
Process operations by the evaporator coupled to the va-porizer assembly or by the vaporizer assembly independcat of the evaporator, will not be permitted until after it has been analyt-ically determined by NRC approved process contral procedures that the controlling constituents of the distillate are at or belew those levels of concermretions noted in the influent column of the applicable table, (Enhibit B, Table 3-1 vaporizer influent l
criteria, and Table 3-2, continuous cycle evaporator influent criteria).
F.
6.
The average influent to the vaporizer assembly, noted
'in Table 3-1, is approximately 2.61E-7 uCi/ml.
This concentra-tion, discharged at a rate of 5 GPM, limits the continuous re-i lease of non-tritium radioactive material (principally cesium-137, strontium-90, and carbon-14) to approximately 8.23E-5 uC1/sec.
This rate is less than 0.4% of the continuous particulate release rate permitted by the TMI-2 Recovery Techni-cal Specifications (0.024 uCi/sec) when averaged over any calen-dar quarter.
It is also Jess than the rate of release stated in PEIS Supplement No. 2, section 3.1.1.2 (0.00028 uCu/sec [2.8E-4) which was calculated at a flow rate of 20 GPM.
The average re-leases rate of tritium, at a water processing rate of 5 GPM, will be 39 uCi/sec, or 7% of the continuous release rate limit permit-ted by the Technical Specifications.
7.
While the radiological content of the AGW at the indi-vidual source locations changes during defueling and decontamina-tion activities at TMI-2, the total radiological content is known.
Certain sources of AGW will be evaluated for possible pretreatment with the demineralization systems er batch cycle operations (described above) of the disposal system.
This is the volume of water currently in use for cleanup activities, and lo-cated principally in the Reactor Coolant System, Fuel Pools (A &
B), Transfer Canal and building sumps.
The AGW will be pretreated to whatever extent is necessary to meet the constitu-ent criteria, addressed above, for processing in the disposal system.
i
- i i
= -
8.
When water is processed by the SDS and EPICOR II sys-tems, it is controlled by step-by-step procedures to assure the effectiveness of the processing.
These include:
a)
Pre-processing activities:
Before each inventory is processed by SDS or EPICOR II, it is mired te a homogeneous solution and i
then sampled for analysis.
The analyses are performed to provide a characterization of both the chemical and radionuclide makeup of that body of water.
b)
Processing activities:
During the processing by SDS or EPICOR II, period-ic samples are obtained from the effluent of each I
demineralizer.
Most of the same analyses are performed on the effluent as those previously performed on the influent during the pre-processing activities noted above.
A comparison is made of this influent to effluent ratio to demonstrate that the process is func-tioning properly.
Along with the laboratory analyses, on-line instruments monitor the process.
Various loca-tions are monitored for flow, pressure, differential pressure, conductivity, pH, level, radioactivity, and total gallons throughput.
I 1
1 c)
Post-processing activities:
Ecllow-up to each processed batch includes mixing, sampling, and analyzing the water in the receiving tank.
These analyses are again reviewed to ascertain l
r the quality of the water both chemically and radiochemically.
Depending on the water quality achieved and on the recovery water volume, the batch of processed water is either transferred to a storage lo-cation or returned to the feed tank for reprocessing.
Calculations are completed to quantify the chemical and radiochemical loading that each demineralizer underwent for the batch.
These values will then identify the remaining capacity of the demineralizers for the next processing batch and demonstrate the effectiveness of the processing.
9.
Thus, if the processing does not achieve sufficient i
reduction of the pertinent constituents, the water is reprocessed until the acceptance criteria are met.
Therefore, even assuming hypothetically that some chemical constituent in the water I
reduced the efficiency of SDS or EPICOR II, that reduction would have no effect on evaporator releases, since at worst it would only require repeated applications of SDS or EPICOR II processing before the water could be introduced into the evaporator.
i s
II.
Effect of Chemicals on the Evaporator 10.
The evaporator that will be used at TMI-2 is being fab-ricated specifically for this purpose using materials of con-struction compatible with the process fluids.
The design speci-fications that GPUN has provided to the vendor include the characteristics of the accident generated water to assure com-plete compatibility with the AGW.
This compatibility will be
-demonstrated by preoperational testing using a surrogate solution that is chemically typical of the AGW.
11.
Evaporators have been used extensively and for many years, and the factors that can affect their efficiency are well
-known.
These factors include corrosion of heat exchanger tubes, improperly controlled pH which may increase the volatility of certain constituents such as organics, entrainment (which is lig-uid suspended as fine droplets that are carried along with the rising vapor streams), and foaming.
Foaming is the production of bubbly suds caused by the presence of "detergents" (organic chem-icals containing chelating agents), which can reduce heat trans-fer rates and produce vapor with a higher moisture content.
12.
The chemical characteristics of the AGW and design of the evaporator are such that none of these operational difficul-I ties or reduction in the decontamination factor is anticipated.
The reasons are as follows:
)
i
'g-i a.
The AGW will be neutralized by pH adjustment before. evaporation and therefore will not be corrosive.
Further, the materials of construction for the evaporator will be corrosion resistant types, such as titanium and stainless steel, b..
The pH, which can-effect the volatility of certain
~
constituents, will be adjusted to control volatility.
c.
The level of boron is not unusual and will not present a problem.
Borated water is treated by the evaporation process at all nuclear generating stations, d.
The AGW is relatively clean.
At the expected level of trace contaminants, neither fouling nor plug-ging of the heat exchanger tubes can reasonably be ex-
- pected, e.
The phosphate and organic level in the AGW is below the level at which excessive foaming would be ex-pected to occur. Furthermore, antifoaming agonts are effective should unexpected foaming occur.
i f.
The natural foaming tendency of water during the evaporation process will completely "wet" the heat ex-changer tubes and the resultant minute vapor bubbles g
I will prevent the formation of the larger vapor bubbles i
which would insultate the tubes, raise the hydrostatic i
! i m.
head and reduce heat transfer rates.
Any fine mist carried upward by the vapor will impinge on the two-state mesh inpingement screens where it will co-alesce by capillary action and drop to the bottom of the evaporator separator for extraction.
See Exhibit B, pages 5-8 for an expandeed discussion on this design.
13.
It is conceivable that some unanticipated chemical con-stituent in the evaporator influent might have some effect on evaporator efficiency.
However, the resultant environmental re-lease would not be affected for two basic reasons.
First, the presence of any chemical detrimental to the efficient operation
~
of the evaporator would be immediately apparent to the evaporator operator through monitoring of the evaporator and its instrumen-tation.
For example, a significant variance in conductivity, re-flective of an unanticipated constituent, would trigger an alarm, and excessive foaming causing significant heat transfer losses would interrupt the evaporation process.
Second, radiological releases to the environment are controlled by a radiation monitor calibrated to the acceptable effluent criteria.
On detection of levels in excess of the release set point (i.e. if the evaporator were not performing efficiently enough), the monitor will auto-matically terminate electrical power to the vaporizer heaters and if the condition is not corrected will initiate valve closure to isolate the distillate supply from the vaporizer.
Section 2.3.8 of Exhibit B provides an expanded discussion of the system instrumentation.
.g.
III.
Conclusion 14.
For the reasons stated above, chemicals in the accident generated water will not adversely affect the evaporator.
More importantly, there is no basis to believe that the radionuclide limits established for environmental release will be exceeded.
If for some reason the evaporator does not meet performance ex-pectations, the inotrumentation and safety systems described in Exhibit B, along with the process control plan, will assure that releases do not exceed those estimated by the NRC Staff in the PEIS Supplement No. 2.
David R.' BudKanan Subscribed and sworn to before me this l3h. day of May, 1988.
Notary Publick
~
k id I (_ J My commission ex ires:
en..
,u.nu uM es n,% :. c LO#00hNttf TW 0ANPWit COUUY ST C0AS4881W GPIN8 38M.11,1989 Gener. Pausmash Annedsman af =- -
i Exhibit A i
RESUME David R. Buchanan P.O. Box 480 i
Middletown, PA 17057 WORK HISTORY 07/80 - Present GPU Nuclear Corporation /GPU Service Corporation Current
Title:
Manager, Recovery Engineering, TMI-2 Dep t./ Loc. :
Site Operations, TMI-2 Responsible for all engineering support, except for defueling, to the TMI-2 Division. Activities include plant modifications, support to Operations l
and Maintenance, Radiochemical Engineering, i
Start-Up and Test, and Fire Protection. The section was formed September 1986, by combining the Site Engineering and Plant Engineering sections.
l 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 TMI-2 Start-Up and Test activities.
12/84 - 2/86 -
Task Leader, Reactor Disassembly and Defueling.
Responsible for providing progransnatic direction and technical overview for on-site recovery l
activities related to reactor defueling/ disassembly as assigned by the Manager, Recovery Programs.
Assignments included defueling plus defueling water clean-up systems, Waste Handling and Packaging 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 i
technical work, monitoring attainment of department cost / schedule goals and managing projects such as RCS Processing, EPICOR Venting, and engineering involvement in the Quick Look Entry.
O D. R. Buchanan Page 2 07/80 - 08/81 -
Supervisor, Recovery Technical Planning.
Supervised technical planning efforts associated with initial recovery at TMI-2, 01/64 - 07/80 -
Westinghouse Electric Corporation Employed at Bettis Atomic Power Laboratory in the r
positions of Associate Engineer, Refueling Equipment Design and Operations; Senior Engineer, Fluid 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,1065 l
L
Exhibit B i
i l
PRELIMINARY SYSTEM DESCRIPTION FOR ACCICENT GENERATED WATER DISPOSAL Rev. O r
i i
I i
I s1 w l
Mpared
",y anage M icovery Engineering i
2-/4-88 Lfj&/Qf Date
/ Defe l
i
l.0 PURPOSE. SCOPE AND ORGANIZATION 1.1 Purnose The purpose of this document is to describe the system and evolutions which will accomplish the controlled disposal of approximately 2.3 million gallons of ' Accident Generated Water",
hereinafter referred to as processed water.
1.2 Sg.g.gg o
The scope of this system description addresses the processing of this inventory by forced evaporation followed by a vaporization process and atmospheric release of the product distillate.
It also includes the separation and final treatment of the solids removed and collected during the evaporation process and the preparatior, of the resulting waste product for shipment and burial at a commercial low level waste facility.
1.3 Oroanization Section 2.0 describes the process and contains a system description i
of the evaporator, the vaporizer and the associated waste processing operations.
1 j
1 0078H/3H
Section 3.0 describes the control of process and the operational options.
2.0 DESCRIPTION
OF THE PROCESSEO WATER DISPOSAL SYSTEM
2.1 Background
The THI-2 accident resulted in the production of large volumes of contaminated water, herein referred to as processed water.
Through
(
mid-1981, when the submerged domineralizer system (SDS) began operation to process water contained in the reactor building, l
approximately 1.3 million gallons of water existed at TM1-2. Of I
this volume, about 640,000 gallons were located in the reactor building. Direct release f rom the reactor coolant system contributed 69% of this water. An additional 28% was river water introduced via leaks in Reactor Building air coolers and the remaining 3% was added via the containment spray system during the first several hours of the accident.
Subsequent to 1981, most of l
the water was processed by both SDS and EPICOR I! to reduce radionuclide levels to very low concentrations.
In addition, approximately 570,000 gallons of water existed in the auxiliary and l
fuel handling building tanks, most of which had been processed by EPIC 0A 11 by mid-1981.
The reactor coolant system contained an additional 96,000 gallons which also required processing by both l
the SOS and the defueling water clean-up system (0WCS). Since
(
i l
i 2
0078H/3H k
'1981. the total inventory of processed water has increased to the current volume of approximately 2.1 million gallons due to continued additions from support systems and conden.ation from the t
reactor building air coolers during the summer months.
l Considerable care has been exercised to minimize the additions of new water and to ensure that the commingling of non-contaminated water with the processed water is restricted.
Even with exercising i
care to minimize additions of new water, the final volume of water requiring disposal is expected to be 2.3 million gallons (as stated I
in Section 1.1).
l l
l 2.2 Process Oescriotion The processed water disposal program consists of:
(a) a dual evaporator system designed to evaporate the processed water at a l
rate of five GPM; (b) an electric powered vaporizer designed to raise the evaporator distillate temperature to 240'F and releas's l
the resultant steam to the,ttmosphere via a flash tank and exhaust i
l stack; (c) a waste concentrator designed to produce the final i
compact waste form, and (d) a packaging section designed to prepare the resultant Weste for shipment consistent with concercial low i
level waste disposal regulations.
If desired, the product distillate from the main evaporator can be routed to an interim l
staging tank for holding purposes, i.e.; to permit radiochemical i
analysis, batching evolutions and system shutdown, prior to being l
l 0078H/3H 3
l routed to the vaporizer assembly for atmospheric release.
The
)
residual concentrate (bottoms) from the main evaporator section will be routed to the auxiliary evaporator for additional processing and then to the final concentrator where it will be processed into the final compact waste form.
The project will employ well proven technology and be continually monitored and controlled with automatic shutdown capabilities designed to terminate the vaporizer and atmospheric release process. With the exception of two controlled release points, one at the vaperizer i
I section, which will release the superheated steam to the atmosphere and the other at the waste processing section which will discharge the final waste to a collection point, the system will operate in a closed loop configuration.
i
2.3 System Description
j The processed water disposal system consists of four major component groups. They are:
(1) the evaporator, (2) the vaporizer, (3) the blender / dryer concentrator, and (4) the waste preparation sections.
(See Attachment 1., Process Flow Diagram)
A contract eg'/eement was entered into with the selected vendor for construction of these four component groups and authorization was l
issued February 1988 to proceed to final design and fabrication of the equipment for the specific TM1-2 application. Certain 0078H/3H 4
i y
definitive design details necessary to prepare a-comprehensive system desti*iption are not currently available as these final designs are an on-going effort.
The ouscriptive information that is available and used extensively in the preparation of this system description is:
(a) the vendor's contract proposal, (b) a system description for a unit similar to the one proposed for this application, and (c) preliminary design information submitted by the vendor January 1988 for review / comment by GPU.
Given these limitations, the following provides a general system 4
description pending completion of the final designs.
l l
2.3.1 General The main evaporator is a vapor recompression type unit with the designed flexibility to be configured as a spraying film or climbing film evaporator. Vapor recompression units are designed to continually recycle the latent heat of vaporization (heat necessary to change water into steam) to sustain continued boiling at reduced pressures and therefore at lower temperatures.
The main evaporator employs a vapor dome, positioned over a horizontal tube heat exchanger, to collect the natural rising vapor from the evaporator process.
This vapor collection is through two 12 inch diametrically opposed uptake pipes which feed an entrainment separator housed within the dome.
The entrained i
i 0018H/3H 5
water is screened by capillary action on the wires of two-stage mesh impingement,creens that drain the separated solids to the bottom of the separator. There, the solids are extracted by the recycle pump and routed to the concentrate tank.
The vapor compressor, taking a suction on the vapor dome, superheats this dried vapor by the heat of compression and discharges the heated 2
vapor down through the tube side of the 520 f t heat exchanger.
The vapor is condensed and then routed to the skid mounted distillate tank for ultimate vaporization rnd atmospheric release.
If desired, due to batching evolutions, system shutdown or radiochemical analysis, the distillate can be routed to an interim l
staging tank.
The product concentrate, separated by the two-stage impingement screehs and collected in the concentrate tank, will be recycled bcck through the main evaporator for further processing or, depending on the level of its concentrate, routed to the settling The tank for saccad stage treatment by the auxiliary evaporator.
second stage treatment consists of increasing the level of solids concentrate to 100,000 to 500,000 ppm by forced evaporation in the auxiliary evaporator section which is similar in design and employs the same method of solids separation as the main evaporator.
4 0078H/3H 6
l
The increased concentrate f ro:n this separation process is collected at the bottom of the auxiliary evaporator separator where it is extracted by the second stage recycle pump and returned to the settling tank. This increased concentrate will be recycled through the auxiliary evaporator for further processing or, depending on the solids concentrate level, extracted by the concentrate feed pump and routed to the blender / dryer section via the concentrate holding tank fo. final treatment prior to packaging operations.
2.3.2 Evaoorator The principle utilized in a high vacuum vapor compressor distiller concentrator is similar to the refrigeration cycle except for the use of water as a refrigerant.
As the system pressure is reduced, so is the boiling point of the product solution.
Therefore, rapid evaporation takes place at a lower temperature and the latent heat of vaporization (heat necessary to change water into steam) can be continuously recycled by the use of a vapor compressor.
Vapor recompression evaporation requires steam heat to initiate start-up and occasional supplementary heat to make up for heat This losses during operation and feed heating requirements.
auxiliary start-up and supplementtry heat will be provided by the auxiliary evaporator which is dosisned to raise the start-up temperature to approximately 131*F.
Once started, the main 0078H/3H 7
4
evaporator will boil the processed water under a vacuum on the shell side of the heat exchanger tubes at temperatures of 130' to 140*F. The excessive evaporator feed, that feed above the designed rate of evaporation, will combine with the vapor generated and exit from the shell via twin 12 inch uptakes to the separator.
The foaming tendency of the water during this process will rompletely "wet" the tubes and the resultant vapor being generated will be in the form of minute vapor bubbles.
This action prevents the formation of large vapor bubbles which would insulate the tubes, raise the hydrostatic head and reduce heat transfer rates.
The evaporator twin uptakes, diametrically opposed, discharge the larger water particles of the excess feed to the bottom of the separator. Any fine mist carried upward by the vapor, impinges on the two-stage mesh where it coalesces and drops to the bottom of the separator for extraction and recycling by the concentrate recycle pump.
This feed and bleed action not only assures continuous wetting of the heat exchanger tubes, it provides the maximum concentration of the liquid for discharge to the auxiliary evaporator for additional processing.
The compressor action is described in Paragraph 2.3.4.
The superheated vapor f rom the vapor compressor is disenarged down through the annulus between the 1 inch titanium sheaths of the heat exchanger where the vapor is condensed by the evaporating action i
1 l
8 0078H/3M
from the processed boiling water.
The condensate (distillate) is propelled to the back end of the titanium sneaths where it is sucked out through 1/4 inch stainless steel tubes and discharged to the distillate collection tank.
2.3.3 VaDorizer The vaporizer section takes a suction from the product distillate supply. It is used to raise the product distillate temperatures to approximately 240'F under pressure, release the heated distillate to atmospheric pressure via a flash tank and exhaust the resultant steam through a 100 foot high stack. The vaporizer assembly consists of: (a) three. 300 (KW) heaters used to elevate the distillate temperature to 240'F at 10 psig; (b) a 24 inch diameter by 60 inch high stainless steel flash tank, used to expose the 240'F distillate to atmospheric pressure and to contain the resultant steam; (c) a 1-1/2 HP pump used to recirculate the distillate in the flash tank through the heaters; and (d) a 3 inch diameter by 100 foot high stainless steel exhaust stack, used to release the steam at a velocity of approximately 350 feet per second.
The exhaust stack will be equipped with a sound abatement dampener to modulate the sound levels during exhaust operations.
9 0078H/3H
4 2.3.4 yacor Comoressor_
The vapor compressor is designed to take suction from the vapor dome after the vapor has been dried by passing through the Flexible expansion joints will be two-stage mesh separators.
The incorporated to relieve any strain on the compressor housing.
rotary lobe compressor is a positive displacement blower with a capacity of about 5230 CFM at full load speed of 1750 rpm on the 125 HP compressor motor.
Its designed application is to take suction on the rising vapor, heated by the latent heat of vaporization being collected in the vapor dome, and compress the vapor to create a rise in temperature due to the heat of compression.
This superheated vapor is then discharged into the tube side of the evaporator heat exchanger.
2.3.5 Auxiliary Evaoorator A small waste heat auxiliary evaporator using heat generated from the before and after electric heater (s) and/or the 143*F product distillate from the main evaporator, will evaporate the product concentrate from the main evaporator at an approximate temperature of 130*F. The vapor from the process will be routed to the main evaporator vapor dome to provide supplementary or start-up heat to The inr.reased concentrate (bottoms) from the the main evaporator.
0078H/3H 10
l auxiliary evaporator will be extracted by the recycle pump and routed to the settling tank. The concentrate will be recycled through the auxiliary evaporator and the settlir.g tank until the level of concentrate is between 100,000 and 500,000 ppm at which tine the a f eed pump will take suction on the settling tank and route the concentrate to the concentrate holding tank.
2.3.6 Blender /Orver The blender / dryer will process the concentrate collected in the concentrate holding tank to the final waste form in a batch type The blender / dryer consists of a cylindrical, horizontal process.
vessel equipped with an agitator for drying liquids and slurries to total dryness.
The dryer body will be equipped with a 150 KW e?cetrically heated jacket. The liquid in the waste slurry will oe evaporated as it
.3es in contact with the heated body of the vessel as the agitator moves the waste slurry from both ends of the dryer vessel toward a center discharge valve.
The agitator consists of rotating helical ribbons which continually scrape the dried product f rta the sides of the vessel and move the waste product to a center discharge valve.
The drying process is controlled so that the waste batch is discharged when the liquid is removed, at which time the final waste product will be discharged directly into the collection section for packaging preparations.
11 0078H/3H
The liquid f rom the dryer section will be returned to the main evaporator concentrate tank and reprocessed.
2.3.7 Packaaine l'
Waste packaging options permit packaging by one of three methods, the selection of which is left to the discretion of the vendor.
All options are acceptable methods, relative to applicable regulations, and all employ satisfactory volume reduction techniques.
In the event a binder agent is required, to minimize the dispersion factors involved in calculation of release fractions during a postulated median transportation accident, its addition will not appreciably increase the estimated volume of waste generated as a result of any of these options. Option 1 utilizes a pelletizer to compact the waste into a pelletized form and then discharges the compressed product into a Spec. 17, 55 gallon transport drum. Option 2 discharges the waste product directly f rom the dryer into a 55 gallon drum, compacts the drum (and product) to a fraction of its original volume and loads the compacted drum into a transportation over-pac container.
Option 3 discharges the waste product directly into a Spec. 17, SS gallon l
transport drum and loads the drum, uncompacted, into a transportation over-pac container.
)
1 12 0078H/3H 4
The volume of waste generated as a result of any of these 3
techniques is estimated to be 4400 to 4500 ft.
This volume represents a significant reduction to the estimated waste volume presented in the PE15 Supplement 2 which used as the method of 3
waste packaging solidifying the waste in 170 ft liners.
The base case presented in the PE15 Supplement 2, which addresses 3
the solidification of waste with Portland cement in 170 ft liners, provides a waste volume estimate of between 27,000 to 46,000 ft, for 25 wt. % solids and 16 wt. 5 solids resoectively, 3
assuming a 0.35 cement to waste volume ratio.
The base case further estimated that in the event of chemical impurities retarding the curing rate and final strength of the concrete the projected volume of solicified waste could be as high as 3
88,000 ft.
2.3.8 instrumentation The system design will provide conductivity monitoring at three Each independent system locations during the evaporator process.
i of these monitoring points will be equipped with a sample point station for the extraction o' process fluids for radiochemical analysis and a conductivity probe for the steady state monitoring of process liquid quality. These monitoring locations are at the 0078H/3H 13
main evaporator feed and at the main and auxiliary evaporator distillate discharge. Additionally, there will be a sample station located at the auxiliary evaporator concentrate discharge for concentrate sampling and a conductivity probe and sample station at the radiation monitor.
Operational experience and an accumulated data base accrued during actual evaporator operations will provide a sound basis for comparing these two methods of analysis, i.e., physical sampling with laboratory analysis and steady state conductivity monitoring.
After adequate demonstration of comparable analytical results and conductivity data, operational procedures may be modified to rely more extensively on the steady state conductivity instrumentation.
However, until a data base can be compiled based on actual system operations, the control method utilized in procedures and operating programs will be the physical sampling and laboratory analysis of process liquids.
Radiation monitoring of the vaporizer influent will continue to be the essential method of process control of environmental release by the vaporizer assembly.
The vaporizer section of the system, which releases the vaporized distillate into the atmosphere, will be monitored and controlled by 1
a gamma radiation detector.
This detector, located in the vaporizer assembly flow path, will monitor levels of gamma radiation in the distillate prior to the distillate being routed to t
0078H/3H 34
the vaporizer heaters.
The detector will be calibrated to sound an audible alarm and terminate atmospheric release by tripping off the vaporizer heaters and/or initiating valve closure to isolate the distillate supply to the vaporizer section.
In the event an alarm condition occurs, the evaporator will continue to operate in a batch cycle mode, discharging the product distillate to a staging tank or recycling it through the system until the system is secured or the alarm condition is removed.
The pre-determined set points of the radiation detector are based on insuring the present TMI-2 Technical Specification instantaneous release limit of 0.3 wCi/sec. will not be exceeded. Monitoring equiptient is available which will allow a setpoint at 25% of this instantaneous release l
rate limit for particulates which is 7.5E-2 wCi/sec.
Assuming the gamma emitting isotope Cs-137 is at a concentration of 3.7 E-8 vCi/ml., the level of concentration permissible for continuous release per Table 3-1 and the PE!S Supplement 2, is present in the vaporizer influent then a corresponding maximum continuous release rate of 2.8E-4 wC1/sec, for all the l
radionuclides is also present.
This is the permissible rate of l
continuous release as bounded by the PE!S Supplement 2.
This ratio of Cs-137 concentration to the maximum permissible continuous release rate yields a scaling f actor of 1.32E-4.
Using i
f this scaling factor and the determined instantaneous release rate l
f 15 0078H/3H
of 7.5E-2 wCi/sec., which is 25% of the Technical Specification maximum instantaneous release rate, it can be calculated that the Cs-137 concentration of 9.9E-6 vCi/ml. is the permissible limit for controlling the rate of instantaneous release.
(1.32E-4 X 7.5E-2 = 9.9E-6).
State of the art instrumentation will be installed which is capable of detecting this level of CS-137 although it will be unable to detect minor variations in the extremely small quantities of most isotopes present.
(Table 3-1 notes that 22 isotopes are exoected to be present at levels <LLO). Others are of such small quantities as to be a small fraction of the Technical Specification limits. Therefore, this monitor is expected to detect ' gross upsets" and terminate releases to the environment before the Technical Specification release limits are exceedcd.
Conservatively, assuming a 1005 carryover of the particulate content through the vaporizer, radioisotopic content of the influent to the vaporiter (i.e., the evaporation distillate) is the process control mechanism and will be additionally controlled by sampling and conductivity monitoring.
It is note worthy that the radiation alarm set point is approximately the same as the limit i
for the average Cs-137 concentrations permissible in the evaporator influent. Thus, the set point limit of the detector provides reasonable assurance that the evaporator is not by-passed.
d I
0078H/3H 16
l TA8LE 3-1 VAPORIZER INFLUENT CRITERIA Continuous Release (1)
Quantity C(ncentration Constituent
$1 vCirm1 Tritium (Hydrogen-3) 1.02 x 103 1.3 x 10-1 Cesium-137 3.2 x 10-4 3.7 x 10-8 Cesium-134 7.66 x 10-6 8.8 x 10-10 Strontium-90 9.6 x 10-4 1.1 x 10-7 Antimony-125/
Te11urium-125m 2.0 x 10-5 2.3 x 10-9 Carbon-14 8.7 x 10-4 1.0 x 10-7 Technetium-99 8.7 x 10-6 1.0 x 10-9 Iron-55 4.2 x 10-6 4.8 x 10-10 Cobalt-60 4.2 x 10-6 4.8 x 10-10 Boron 0.15 tons H 803 3.0 ppm B 3
Sodium 0.011 tons NaOH
.7 ppm Na+
- !odine-129
<5.2 x 10-3
<6.0 x 10-7
- Cerium-144
<1.4 x 10-5
<1.8 x 10-9
<3.5 x 10-7
<4.0 x 10-11
- Cobalt-58
<3.5 x 10-7
<4.0.x 10-11
- Nickv1-63
<5.2 x 10-6
<6.0 x 10-10
- Zinc-65
<8,5 x 10-7
<9.8 x 10-11
- Ruthenium-106/
Rhodium-106
<2.9 x 10-6
<3.3 x 10-10
- Silver-110m
<4.9 x 10-7
<5.6 x 10-11
- Promethium-147
<4.2 x 10-5
<4.8 x 10-9
- Europium-152
<3.3 x 10-9
<3.8 x 10-13 l
- Europium-154
<3.8 x 10-7
<4.4 x 10-11
- Eu ropium-155
<9.6 x 10-7
<1.1 x 10-10
- Uranium-234
<8.7 x 10-8
<1.0 x 10-11
- Uraniam-235
<1.0 x 10-7
<1.2 x 10-11
- Uranium-238
<1.0 x 10-7
<1.2 x 10-11 l
- Plutonium-238
<1.0 x 10-*7
<1.2 x 10-11
- Plutonium-239
<1.2 x 10-7
<1.4 x 10-11
- Plutonium-240
<1.2 x 10-7
<1.4 x 10-11
- Plutonium-241
<5.7 x 10-6
<6.5 x 10-10
<1.0 x 10-7
<1.2 x 10-11
- rurium-242
<8.7 x 10-7
<1.0 x 10-10 l
Totals 2.61 x 10-7 uti/ml.
Concentration (Average):
Continuous Rate of Release at 5 GPM:
8.23 x 10-5 uti/sec.
"Denotes assumed constituents
< Oenotes less than level of detection (1) Release concentration average over any calendar quarter.
0078H/3H 17 t
O TA8L'E 3-2 CONTINUQUS CYCLE EV4PORATOR INFLUENT / EFFLUENT CRITERIA l
Influent l
Effluent l
l l
Quantity Concentration l Quantity Concentration Constituent l
Q wC1/ml Q
w(ifm_1, I
I Total volume l
2,300,000 gal.
l l
l Tritium l
l (Hydrogen-3) l 1.02 x 103 1.3 x 10-1 l 1.02 x 103 1.3 x 10-1 Cesium-137 l 3.2 x 10-1 3.7 x 10-5 l 3.2 x 10-4 3.7 x 10-8 Cesium-134 l 7.66 x 10-3 8.8 x 10-7 l 7.66 x 10-6 8.8 x 10-10 Strontium-90 l 9.6 x 10-1 1.1 x 10-4 l 9.6 x 10-4 1.1 x 10-7 Antimony-125/
l l
Tellurium-125m l 2.0 x 10-2 2.3 x 10-6 l 2.0 x 10-5 2.3 x 10-9 Carbon-14 l 8.7 x 10-1 1.0 x 10-4 l 8.7 x 10-4 1.0 x 10-7 Technetium-99 l 8.7 x 10-3 1.0 x 10-6 l 8.7 x 10-6 1,0 x 10-9 fron-55 l 4.2 x 10-3 4.8 x 10-7 1 4.2 x 10-6 4.8 x 10-10 Cobalt-60 l 4.2 x 10-3 4.8 x 10-7 l 4.2 x 10-6 4.3 x 10-10 Boron i 150 tons 3000 ppm 8 l
.15 tons 3.0 ppm 8 H 803 l
H 803 3
l 3
Sodium l
11 tons NaOH 700 ppm Na+
l
.011 tons NaOH
.7 ppm Na+
- !odine-129 l<5.2 x 10-3
<6.0 x 10-7 l<5.2 x 10-3
< 6.0 x 10-7
- Cerium-144 l<1.4 x 10-2
<1.8 x 10-6 l<1.4 x 10-5
< 1.8 x 10-8
- Man 9anese-54 l<3.5 x 10-4
<4.0 x 10-8 l<3.5 x.10-7
< *.0 x 10-11
- Cobalt-58 l<3.5 x 10-4
<4.0 x 10-8 l<3.5 x 10-7
< 4.0 x 10-11
- Nickel-63 l<5.2 x 10-3
<6.0 x 10-7 l<5.2 x 10-6
< 6.0 x 10-10
- Zinc-65 l<8.5 x 10-4
<t.8 x 10-8 l<4.5 x 10-7
< 9.8 x 10-11
- Ruthenium-106/ l l
Rhodium-106 l<2.9 x 10-3
<3.3 x 10-7 l<2.9 x 10-6
< 3.3 x 10-10
'511ver-110m l<4.9 x 104
<5.6 x 10 8
(<4.9 x 10-7
< 5.6 x 10-11
- Promethium-14 7 l<4,2 x 10-2
<4.3 x 10-6
[<4.2 x 10-5
< 4.8 x 10-9
[
- Europium-152 Ic3.3 x 10-6
<3.8 x 10-10
(<3.3
- t 10-9
< 3.8 x 10-13
- Europium-154 l<3.8 x 10-4
<4.4 x 10-8 l<3.8 x 10-7
< 4.4 x 10-11 I
- Europium-155 l<t.6 x 10-4
<1.1 x 10-7
(<f.6 x 10-7
< 1.1 x 10-10 i
"Uranium-234 l<8.7 x 10-5
<1.0 x 10-8 l<8.7 x 10-8
< 1.0 x 10-11
- Uranium-235 l<1.0 x 10-4
<1.2 x 10-8 l<1.0 x 10-7
< 1.2 x 10-11
' Uranium-238 l<1.0 x 10-4
<1.2 x 10-8 l<1.0 x 10-7
< 1.2 x 10-11
- Plutonium-238 l<1.0 x 10-4
<1.2 x 10-8 l<1.0 x 10-7
< 1.2 x 10-11
- Plutonium-239 l<1.2 x 10-4
<1.4 x 10-8
(<1.2 x 10-7
< 1.4 x 10-11
- Plutonium-240 l<1.2 x 10-4
<1.4 x 10-8
[<1.2 x 10-7
< 1.4 x 10-11
- Plutonium-241 l<5.7 x 10-3
<6.5 x 10-7 l<5.7 x 10-6
< 6.5 x 10-10
' Ame ri c i um-241 l<1.0 x 10-4
<1.2 x 10-8
(<1.0 x 10-7
< 1.2 x 10-11
- Curium-242 l<8.7 x 10-4
<1.0 x 10-7
(<8.7 x 10-7
< 1.0 x 10-10 l
Effluent Totals Particulate Concentration:
2.61 x 10-7 wci/ml.
Continuous Rate of Particulate Release at 5 GPM:
8.23 x 10-5 wC1/sec.
- Denotes assumed constituents
< Oenotes less than level of detection l
18 0078H/3H l
l
3.0 PROCESS CONTROL AND OPERATIONAL OPTIONS 3.1 Process Control The process control of atmospheric releases during the evaporator and vaporization process will be implemented via the radiation monitoring and radiochemical sampling of the influent to the vaporizer section.
Establishing process control at the vaporizer influent conservatively assumes a 100% carry-over fraction through the vaporizer assembly.
There is no credit for plate out or solids separation in the heaters, flash tank or exhaust stack.
To establish a basis for this influent acceptability the criteria established in Section 2.0 of the PEIS Supplement !! was used as a basis for comparison of the radiological constituents and l
respective concentrations acceptable for release to the atmosphere f
during operation of the vaporizer assembly.
The average influent to the vaporizer assembly, noted in Table 3-1 is approximately I
2.61E-7 wC1/m1.
This concentration, discharged at a rate of 5 GPM limits the continuous release of non-tritium radioactive l
material, principally cesium-137, strontium-90, and carbon-14 to approximately 8.23E-5 vCi/sec. This rate is less than 0.4% of the continuous particulate release rate p#rmitted by the TMI-I Recovery Technical Specifications (0.024 uCi/sec.) when averaged 19 0078H/3H
I over any calendar quarter.
It is 7.lso less than the rate of release stated in the PEIS Supplement !!, section 3.1.1.2 (0.00028 wC1/sec. (2.8 E-4)) which was calculated at a flow rate i
l of 20 GPM.
The radionuclides and their permissible level of concentrations as influent to the vaporizer assembly for atmospheric release are listed in Table 3-1. This table conservatively assumes that certain radionuclides, not positively identified in the process water samples, nevertheless exist at the stated lowest limit of j
detection. These assumed radionuclides, identified by an asterisk, are included in the table.
3.2 Operational Options The designed flexibility of the evaporator / vaporizer equipment permits the evaporator assembly to be de-coupled from the vaporizer assembly.
In this configuration, the evaporator operates independent of the vaporizer and processes the water in a batch cycle method of operation. Conversely, if the vaporizer is coupled to the evaporator during operations, the water will be processed in a continuods type method of operation. The operational options addressed in this section describe these two methods of process operations.
I 20 0078H/3H
3.2.1 Batch Cvele Operations In this configuration, the evaporator assembly will process water independent of the vaporizer assembly.
The product distillate from the evaporator will be collected in a staging tank for sampling and radiochemical analysis.
The benefits realized by this operational method are primarily in the area of radiological waste volume and occupational exposure reductions.
By using the evaporator assembly as a pretreatment technique for certain of the volumes of water, pretreatment by one of the ion exchange systems and the resulting contamination of domineralizer resins would be eliminated.
- Thus, the handling and shipping of the resin liners for discosal purposes is eliminated.
i The collected product distil14tes, sampled at the staging tank, will be radiochemically analyzed for compliance with the controlling concentrations noted in Tables 3-1 or 3-2.
Process operations by the evaporator coupled to the vaporizer assembly or Dy the vaporizer assembly independent of the evaporator, will not be permitted until after it has been analytically determined by NRC approved process control procedures that the controlling constituents of the distillate are at or below those levels of concentrations noted in the influent column of the applicable table, (i.e., Table 3-1, vaporizer influent criteria, and Table 3-2, continuous cycle evaporator influent criteria).
21 0078H/3H
3.2.2 Continuous Cvele Operations In this configuration, the evaporator and vaporizer assemblies will be couplod and operate as a continuous cycle unit.
The control of this operation will be initially established by the isolation of the body of water scheduled for continuous cycle evaporatio6.
Once this isolation is complete, a physical radiochemical analysis will be performed on the water and compared to the controlling radioactive constituents notad in Table 3-2.
Process operations by the evaporator and vaporizer equipment will not be permitted until after it has been analytically determined by NRC approved process control procedures that the controlling constituents are at or below those levels of concentration noted in the influent column of.
the table.
The imposition of these evaporator influent limits coupled with a conservative carry-over fraction of 0.1% asrumed during evaporator operations, will assure that the rate of itmospheric release of f
particulate radioactive material will be in compliance with the normissible release concentrations established in Section 3.1.
Operational experience and historical data accrued during actual operations (i.e., batch and continuous cycle operations) will provide a sound basis for the continued use of a 0.1% carry-over i
fraction for operational limits.
Development of an operational 22 0078H/3H l
+
data base using physical sampling and radiochemical analysis may demonstrate that a less conservative carry-over f raction may be applied and the operational procedures modified accordingly.
However, until compilation of this data base during actual system operations, the 0.15 carry-over fraction will be assumed as the procedural control limit for continuous cycle operations.
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[VAPORATOR PROCESS FLOW DIAGRAM fre, O Y
S W-
s
' s' 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)
)
AFFIDAVIT OF DR. GARY G.
BAKER (Contentions 4b in part and 6 on Chemicals)
County of Dauphin
)
)
ss.
Commonwealth of Pennsylvania
)
DR. GARY G. BAKER, being duly sworn according to law, de-poses and says as follows:
1.
My name is Dr. Gary G. Baker.
My business address is Post Office Box 48v, Middletown, Pennsylvania 17057.
I am em-ployed by GPU Nuclear Corporation as Manager, Environmental Con-trols.
In this position, I am responsible for the environmental monitoring and evalua*. ion of activities at Three Mile Island (TMI).
I hold a doctorate degree in microbiology and have ten years experience in the utility industry, eight of which have in-volved both radiological and non-radiological environmental moni-toring.
A summary of my professional qualifications and experi-ence is attached hereto as Exhibit A.
monitoring.
A summary of my professional qualifications and ex-perience is attached hereto as Exhibit A.
2.
I make this Affidavit in support of GPU Nuclear Corpo-ration's Motion for Summary Disposition on Chemicals (contentions 4b in part and 6).
I have personal knowledge of the matters stated herein and believe them to be true and correct.
In my af-fidavit, I will explain why the chemical constituents of the evaporator effluent vill have no significant environmental im-pact.
3.
As discussed in the Affidavit of Kerry L.
Harner, the chemistry of the accident generated water processed by Submerged Demineralizer System (SDS) and EPICOR II has been assessed.
When this water is evaporated, the decontamination factor of 1,000 achievable with the particular type of evaporator being procured by GPUN vill apply to non-volatile chemical constituents as well as to radionuclides.
Thus, concentrations of chemical substances in the evaporator effluent vill also be 1,000 times smaller than the concentrations in the processed water.
4.
Other than boron and sodium, chemical constituents in the processed water (as described in the Affidavit of Kerry L.
Harner) are already at trace levels.
For example, on average only about 15 ppm Total Organic carbons (which would include any oil, grease, hydraulic fluid and organically-based additives) are present in the accident generated water; and after reduction by a.
r factor of 1000, only about 15 parts per billion (ppb) would be expected in the evaporator effluent.
In comparison, the NPDES permit from TMI allows 15 mg/l (ppm) oil and grease in liquid effluent from various discharge points within the plant based on a monthly average.
Levels of other trace contaminants are even smaller.
Total suspended solids in the accident generated water are below 2 mg/l (ppm); and after reduction by a factor of 1000, only about 2 ppb would be expected in the evaporator effluent.
None of the trace constituents in processed accident generated water is a hazardous or toxic waste.
5.
Thus, the chemical constituents that will be discharged to the atmosphere during the proposed evaporation of the TMI-2 processed water will for all practical purposes be in the form of sodium borate and boric acid, which exist as dissolved solids in the processed water.
These by-products result f rom ';he neutrali-zation process using boric acid and sodium hydroxide.
The neu-tralization process vill result in a slightly basic pH yielding mainly salts of a weak acid in the form of sodium.
The design criteria for the evaporation process specifies that 0.1% of the total (suspended and dissolved) solids, conservatively rounded up l
to 200 tons for the purposes of this analysis, vill be released l
to the atmosphere over a two year period.
This equates to a 0.0028 g/see particulate release rate or an average concentration l
of approximately 6 x 10-6 mg/m off-site (based on an approximate 3
i annual average dispersion of 2 x 10-6 see/m cited in the TMI 3
l l
t offsite Dose Calculation Manual -- OCDM).
This concentration vill have no significant, adverse environmental impact on plant and animal life in the TMI vicinity.
As a vorst case scenario, the particulate concentration for this process vould be approxi-mately 2 x 10-3 mg/m3 (based on TMI-2 FSAR accident dispersion of 3
6 x 10-4 sec/m ) which also is non-threatening to plant and ani-mal communities.
6.
These assessments are based in part on the threshold limit value (TLV) of 10 mg/m3 (eight-hour time weighted average) for nuisance particulates including boron oxide recommended for the human environment.
The calculated average concentration of particulates (6 x 10-6 mg/m ) which will be released during the 3
proposed evaporation process vill be more than 1,500,000 times below the TLV.
The vorst case scenario release concentration vill be approximately 5,000 times below the TLV.
7.
Another comparative approach to assessing the impact to the environment can be actual particulate concentrations.
Per NUREG/CR-3585, the.nisance dust loading in the Central Atlantic 3
States is 0.258.ng/m.
This value is over 40,000 times greater than the calculated average release of particulates from the pro-posed evaporation.
Relative to impacts on plant species, the Air Pollution Control Association (1970) documents the following:
"Partleulate emissions are not generally considered to be harmful to vegetation unless they are highly caustic or heavy deposits
_4
occur."
The evaporator effluent is not caus, tic, and deposition vill be extremely light.
8.
The insignificance of the evaporator effluent can also be demonstrated by comparison to cooling tower emissions.
NRC Regulatory Guide 4.11 (Rev. 1, 1977) advises that chemical studies of cooling tower drift are usually unnecessary when the dominant salts are harmless mixtures of biological nutrients, the expected peak deposition beyond the site boundary is less than 20 kg/ha-yr, and the drift does not contain toxic elements or com-pounds in amounts that could be hazardous to plants or animals either by direct or indirect exposure over the expected lifetime of the facility.
9.
Boron is a micronutrient with no hazard within the range of concentrations found in nature.
In nature, it is usu-ally found as sodium or calcium borate salt and exists in river i
)
and lake waters at concentrations averaging 0.1 mg/l but ranging i
up to 5 mg/1.
U.S. EPA, Quality Criteria for Water (1986).
Studies have shown that boron in irrigation water at concentra-l tions of about 1 mg/l can have a deleterious effect on the most j
sensitive plants (such as citrus plants), but it presents far less biological risk than chlorine, which is a biocide present in l
cooling tower emissions.
In NUREG-0555 (the NRC's Environmental 1
l Standard Review Plan), the NRC states that deposition of salt drift (Nacl) at rates of 1 to 2 kg/ha-mo (12 to 24 kg/ha-yr) is 5
l l
l r
generally not damaging to plants; and past studies by NUS Corp.
(1980) have shown that operation of the cooling towers at TMI has not caused vegetative stress.
10.
With respect to the evaporator emissions, deposition of total solids (including sodium borate and boric acid) is conser-vatively calculated to be approximately 6 x 10-2 kg/ha-yr (based 2
on the highest annual deposition factor of 7 x 10-8/m cited in the TMI OCDM), which is 200 to 400 times smaller than the amount of salt deposition generally assumed not to be damaging to plants.
This small amount which will be deposited is considered insignificant, especially since the element boron is relatively immobile in plants (NUREG/CR-3332).
11.
For these reasons, it is clear that the chemical con-stituents of the evaporator effluent will have no significant im-pact on the environment.
C f%h gapf G'.
Baker l
Subscribed and sworn to before me this 13th day of May, 1988.
I LNS.A %hh>
Notary Pub'lic l
l My commission expires August 21, 1989 i
i
( i l
t t
EXHIBIT A o
GARY G. BAXER, PH.D.
PROFESSIONAL BACKGROUND 1983 to Manacer of Environmental Controis-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 /Reviev...Public Relations...Offsite Emergency Plan Response... Environmental / Radiological Surveys Prograns...
- 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, Middletcvn. PA Designed and implemented radiological monitoring programs.
Evaluate Exisiting Systems... Evaluate Data... Monitor Commercial Laboratories... Management Reports...
0 e
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, Indiana, 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 Microbioloav WEST VIRGINIA UNIVERSITY. Morgantown, WV 1971 B.S.-Bioloov MORRIS HARVEY COLLEGE, Charlestown, WV 1966 to Biolooy 1968 UNIVERSITY OF UTAH, Salt Lake City, UT 2
.