ML20154E368
| ML20154E368 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/13/1988 |
| From: | Harner K GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20154E212 | List: |
| References | |
| OLA, NUDOCS 8805200194 | |
| Download: ML20154E368 (13) | |
Text
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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
)
Genersted Water)
Station, Unit 2)
)
AFFIDAVIT OF KERRY L.
HARNER (Contention 5d)
County of Dauphin
)
)
ss.
Commonwealth of Pennsylvania
)
KERRY L. HARNER, being duly sworn according to law, deposes and says as follows.
1.
My name is Kerry L. Harner.
My business address is Post Office Box 480, Middletown, Pennsylvania 17057.
I am em-ployed by GPU Nuclear Corporation at TMI-2 as Radiological Chem-istry Manager.
My responsibilities include providing chemical and radiochemicL1 technical expertise to all projects supporting defueling, plant operations, radwaste processing, and accident generated water disposal.
A statement of my professional quali-fications and experience is attached hereto as Exhibit A.
2.
I make this affidavit in support of GPU Nuclear Corpo-ration's Motion For Summary Disposition of Contention 5(d) pgg52Of 080516 0
05oooapo.
e concerning evaluation of tritium and alpha emitters such as transuranics in accident generated water.
I ha e personal knowl-edge of the matters stated herein and believe them to be true and correct.
In my affidavit, I will describe the radiological anal-yses of processed accident generated water, which are the bases for the evaporator influent criteria.
As my Affidavit demon-strates, the radionuclide constituents of processed accident gen-erated water, and in particular transuranics, have been fully as-sessed and are well characterized.
3.
Both GPUN and the NRC have evaluated the accident gen-erated water to determine its radionuclide constituents.
While there have been numerous, routine analyses by GPUN, the principal evaluations relied upon to characterize the water that will be evaporated consist of (1) samples of the Processed Water Storage Tank #2 (PWST) and several other processed water sources, which were analyzed by the Westinghouse Advanced Energy Systems Divi-sion Laboratory on behalf of GPUN; (2) a technical evaluation un-dertaken by GPUN which provides conservative upper bound esti-mates of radionuclide that could not be detected by normal gamma and alpha spectroscopy; and (3) samples from PWST #2 which were analyzed independently by GPUN's chemistry department and by the U.S. Department of Energy's Radiological and Environmental Sci-ences Laboratory (RESL), Idaho Falls, Idaho, on behalf of the NRC.
PWST #2 has a capacity of nearly 465,000 gallons, approxi-mately 20% of the total accident generated water.
Because of its -
t large volume and because it had been preprocessed, its content is representative of the radionuclide levels that are achievable in processed water.
Many additional analyses of batches of accident generated water processed through SDS and EPICOR II have con-firmed that the results of the analyses above are representative.
4.
The evaluation by Westinghouse was performed on samples taken by GPUN at the.end of 1985 from PWST #2 and also from PWST #1 (an additional 109,000 gallons), the Chemical Cleaning Tank (CCT-1, approximately 20,000 gallons), and CCT-2 (approxi-mately 17,000 gallons).
The sampling was performed under strict procedural controls.
Each source was circulated to ensure mixing prior to sampling.
The samples were then analyzed by Westing-house with the following results:
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WESTINGHOUSE ADVANCED ENERGY SYSTEMS DIVISION ANALYSIS CCT-1 CCT-2 PWST-1 PWST-2 uC1/mi 25 uC1/ml 25 uC1/mi 25 uC1/ml 25 Co-60' 1.2E-7 8.4E-8
<4.5E-8
/1.0E-7 1.8E-7 5.2E-8 Ag-110m
- 3.6E-7 41.2E-7 42.3E-7
<l.lE-7 Sb-125 (3.3E-7
<l.lE-7 42.7E-1 3.4E-7 1.lE-7 Ru-106 (1.lE-7 (5.3E-7 49.eE-7 45.2E-7 Cs-134 3.2E-7 1.2E-7 1.2E-7 4.5E-8 2.4E-7 8 J E-8 2,lE-7 4.4E-8 Cs-137 6.5E-6 2.5E-7 2.8E-6 7.6E-8 6.4E-6 2.2E-7 4.8E-6 9.9E-8 Ce-144 (7.8E-7 43.0E-7
<5.7E-7 42.8E-7 Sr-90 9.0E-6 1.8E-7 1.8E-7 3.6E-8 7.9E-6 1.8E-7 2.lE-5 2.9E-7 I-129 (4.8E-7 45.3E-7 46.2E-7 (5.9E-7 Ni-63
( 5. 4E-7 45.2E-7 P.4E-7 6.5E-7 45.6E-7 Tc-99 42.6E-7
<2.7E-7 9.9E-7 3.2E-7 42.5E-7 C-14 1.4E-4 9.8E-f 1.lE-4 1.lE-5 5.lE-5 6.2E-6 3.0E-4 1.lE-5 U-234
<l.lE-8
/1.4E-8 41.6E-8 41.5E-8 U-235 (6.2E-9 46.9E-9 41.2E-8 4 8.7E-9 U-238
<0.4E-9 48.lE-9
<1.2E-8 (1.4E-8 Pu-238
<l.1E-7 (1.2E-8
<l.2E-8
<l.lE-8 Pu-239/240
<3.7E-8
<1.3E-8 (1.4E-8
<1.2E-8 Am-241 44.6E-8 41.2E-8
<1.2E-S
<l.lE-8 Cm-242 41.lE-7 4 8.6E-8 (6.3E-8 46.lE-8 Cm-243/244 (2.0E-8 cl.0E-8
<l.lE-8
( 8.6E-9 5.
In addition to this analysis, GPUN undertook a compre-hensive review of the radionuclides potentially present in the processed water to determine what might be a constituent of the evaporator influent.
This evaluation did not rely on the capa-bility to detect radioisotopes in samples.
Instead, a list of radionuclides that might be present was developed using the fol-loving criteria.
a.
Radionuclides specifically identified in 10 C.F.R. Part 61, which are the long-lived radionuclides which the NRC requires to be assessed in evaluations of vaste burial; b.
Radionuclides comprising greater than 0.1% of the core isotopic content, on a curie basis, j
eight years following the TMI-2 accident as determined by the ORIGEN computer code;
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Radionuclides greater than 0.1% of the core transuranic inventory, on a curie basis; and d.
Reactor coolant system activation products of l
practical interest as. identified by the Babcock and Wilcox Water Chemistry Manual.
6.
The ORIGEN code referred to above is a computer code that calculates the isotopes produced in a reactor based on plant operational history.
The nuclear process involved in a reactor produces predictable fission products, activation products, and transuranics, and the rates of decay, and decay products are also known.
Thus, the isotopic inventory can be calculated; and ra-dionuclide constituents of any significance and their relative abundance can be determined.
7.
For each of the radionuclides determined by the criteria above to be potentially present in the evaporator influent, GPUN calculated an average concentration (i.e. total curie concent of the various water sources divided by the total volume of processed water).
GPUN used the lower level of detec-1 j '
tion (LLD) or the actual measured activities in processed water i
for the radionuclides listed.
The activities of radionuclides for which no data (no actual measurements or assigned LLDs) were available were estimated by means such as comparison of their relative abundance with similar radionuclides for which data was available.
For example, the europium, samarium and promethium i
values were based on a ratio between the core isotopic ratios given by ORIGEN and the known LLD of Ce-144 in processed water,
since all these isotopes are rare earths and are chemically simi-lar.
The results of GPUN's evaluation are shown below:
AVERAGE CONCENTRATION OF RADIONUCLIDES POTENTIALLY PRESENT IN TMI-2 WATER FOR EVAPORATION Radionuclides Concentration (uCi/ml)
H-3 1.3 E-1 C-14 1.0 E-4 Mn-54
<4.0 E-8 1
Fe-55 4.8 E-7 Co-58 4 4.0 E-8 Co-60 4.8 E-7 Ni-63 46.0 E-7 Zn-65
( 9.8 E-8 Sr-90/Y-90 1.1 E-4 Tc-99 1.0 E-6 Ru-106/Rh-106
< 3.3 E-7 1
Ag-110M
<5.6 E-8 Sb-125/Te-125a 2.3 E-6 I-129 (6.0 E-7 Cs-134 8.8 E-7 Cs-137/Ba-137m 3.6 E-5 Cs-144/Pr-144
<2.1 E-7 1
Pm-147 (4.9 E-6 1
Sm-151
( 1.1 E-7 1
Eu-152
<3.8 E-10.
Radionuclides Concentration (uCi/ml) 1 Eu-154
<4.4 E-8 Eu-155
< 1.1 E-71 l
U-234 41.0 E-8 U-235 (1.2 E-8 U-238 t1.2 E-8 l
Pu-238 41.2 E-8 l
Pu-239 4 1.4 E-8 Pu-240
< 1. 4 E-8 1
Pu-241
<6.5 E-7 Am-241
<1.2 E-8 Cm-242
( 1.0 E-7 1.
Calculated concentration 8.
There are other transuranics on the Periodic Table that have not been determined to be present in the accident generated water.
Simply put, not every transuranic is produced by a reac-tor to an appreciable extent.
Those transuranics that are de-tectable or analytically identifiable have been evaluated and are included in the table above.
9.
The concentrations in this table represent the levels achievable for each radionuclide by processing the accident gen-erated water by the SDS and EPICOR II systems end form the basis for the influent criteria that GPUN has developed.
The.
__m. _
__m_
s evaporator effluent criteria reflect a further reduction of 1,000 for each radionuclide except tritium.
- 10. In early 1987, PWST #2 was again sampled to characterize the constituents of accident generated water that had been pro-cessed by SDS and EPICOR II.
Once more, the sampling followed strict procedures.
Before the sample was drawn, PWST #2 was recirculated to provide adequate mixing and the sample line was purged to ensure a representative sample.
The aampling process was overseen by an NRC inspector.
- 11. The sample from PWST #2 was then split and analyzed in-dependently by GPUN and RESL Laboratories.
The final results were reported in an NRC Memorandum dated January 11, 1988 as fol-lows.
The RESL data includes the estimated random uncertainty at one standard deviation and the estimated overall uncertainty (the last number in the parentheses); and a negative number in the I
RESL data is considered to be not present, as indicated for C-14 and U-235.
GPUN CHEMISTRY RESULTS Isotooe Concentration (uCi/ml)
Co-60 2.8 E-7 Cs-137 7.0 E-6 Cs-134 1.5 E-7 Sr-90 (5.8 1
- 17) E-5 0
H-3 (1.90 1 045) E-1 0
Sb-125 less than 4.0 E-7 Co-58 less than 4.6 E-8 Ag-110m less than 6.5 E-8 i
Ru-106 less than 7.8 E-7 t l
7 Isotope Concentration (uCi/ml)
Ce-144 less than 7.6 E-7 RESL SAMPLE RESULTS Isotope Cgncentration (uci/ml)
(1.90 0.03;0.05) E-1 uCi/ml H-3 1
I-129 (1.110.5;0.5) E-8 uCi/ml Co-60 (3.210.5;0.5) E-7 uCi/ml Ni-63 (2.010.2;0.3) E-7 uCi/ml Sr-90 (2.5510.07;0.07) E-5 uCi/mi Cs-137 (8.010.2;0.3) E-6 uCi/ml Am-241 (2.410.3;0.3) E-9 uCi/ml (1.391 09;0.09) E-8 uCi/ml Pu-239/240 0
Pu-238 (1.210.3;0.3) E-9 uCi/ml Sb-125 (612;2) E-7 uCi/mi C-14
(-213;3) E-7 uCi/ml Tc-99 (1.610.8;0.8) E-8 uCi/ml U-234/233 (613;3) E-10 uCi/ml
(-1.01 5;1.5) E-10 uCi/ml U-235 1
U-238 (212;2) E-10 uCi/ml (11 ;8) E-ll uCi/ sample Cm-244/243 8
Cm-242 (418;8) E-ll uCi/ sample 12.
As can be seen from these results, RESL had the capa-bility to detect radionuclides at considerably lower levels than the normal lower level of detection in conventional gamma and alphi spectroscopy.
RESL did detect uraniums and transuranics, but in each case the concentration was below (usually orders of magnitude below) the levels conservatively established by GPUN, as listed in paragraph 7 above.
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13.
In conclusion, the radionuclide constituents of pro-cessed accident generated water have been determined empirically s.nd analytically.
The data is more than sufficient to character-ize the evaporator influent.
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,c Ker y L. Jrarner Subscribed and sworn to before me this 13 % day of May, 1988 Cr -
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D Notary Public g,gggggg gee, unwry Pueuc geassageggtIUP,BADMBEC0 gun My commission expires:
W C0W18Bign anets sm. it. im w, Pusesytrusts Asestietos of 8M*n**
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Exhibit A-NAME:
KERRY L. HARNER ADDRESS:
P.O. Box'480 h
- Middletown, PA 17057 TELEPHONE:
717-948-8709 f
c EMPLOYMENT HISTORY:
CURRENT TITLE:
Radiological Chemistry Manager DEPT./ LOC.:
Site Operations - TMI-2 SUPERVISOR:
Dave Buchanan, Manager, Recovery Engineering s
Provide Chemical and Radiochemical technical expertise to all projects supporting Defueling, Plant Operations, Radwaste pro-l cessing, accident generated water disposal and Post Defueling Monitored Storage.
Manager, Plant Chemistry - Planned, directed 1/82 - 1/88 t
and managed the activities of technical and supervisory personnel in implementing the plant.
chemistry program.
This included training, j
quality control, labor relations, department administration, chemistry analyses,.ra-diochemical analyses, and research and develop-i ment activities.
[
Special activities:
Managed all laboratory i
l support for recovery from microbiological i
fouling during defueling activities.
Chemistry Supervisor - Organized and directed
[
7/79 - 1/82 l
the efforts of the TMI-2 chemistry department
}
l including Chemists, Sample coordinators and r
L Chemistry Foremen.
i Chemistry Foreman - Supervised bargaining unit i
L 7/76
,7/79 chemistry technicians and laboratory activities L
for plant start-up and commercial operation.
t Provided system / chemistry operational guidance l
and expertise for plant operations.
l Special activities:
Corrected and improved the
[
condensate polisher performance through equip-ment modifications and special prc:edures.
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7/75 - 7/76 Chemist - Responsible for review and analysis of chemistry results performed at TMI-1.
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O KERRY MARNER Page 2 1/74 - 7/75 Chemistry Technician - member of the Met Ed bargaining unit responsible for performing ana-lytical chemistry for startup and operation of TMI-1.
EDUCATION:
B.S. Chemistry Major - Lebanon Valley College - 1974 Certificate in Management - Messiah College (AMA) - 1984 Wastewater Plant Operators Training - Commonwealth of Pennsylvania - 1978 Company Sponsored Courses:
Manager Development Program Basic Supervisory Development Progr Leadership Effectiveness Training Decision Analysis l
l Kepner Tregoe Problem Solving l
Radiochemistry Course for Superviso (B&W)
Labor Relations Training for Supervisors Seminars in Labor Relations, Qualit l
Control Time Management, Franklin Institute Senn Delaney Managing for Productivity situational Leadership Laboratory Quality Assurance /Qualit i
Control Practices (NUS)
Managing Differences and Agreements PROFESSIONAL MEMBERSHIPS:
Member American Nuclear Society Licensed Wastewater Treatment Plant Operator PUBLTCATIONS:
Use of H2 2 As A Biocide In Spent Fuel Pool At Three Mile Island -
0 t
Unit 2, October 1987.
K. J. Hofstetter, K.
L. Harner
[
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KERRY HARNER Page'3 Chemistry Support For Submerged Demineralizer System Operation at Three Mile Island, September 1981.
K. J. Hofstetter, C. Hitz, K. L.
Harner, P. S. Stoner, G.
E. Chevalier, H.
E. Collins, P. Grahn, W.
F.
Pitila Condensate Polishing Experience.at Three Mile Island - Unit 2, October 1979.
K. L. Harner, K. H. Frederick.
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