ML20155H128

Licensee Testimony of Dr Buchanan on Evaporation Proposal & Joint Intervenors Alternative (Contentions 2 & 3).* Related Correspondence

ML20155H128
Person / Time
Site:	Three Mile Island
Issue date:	10/11/1988
From:	Buchanan D GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20155H117	List: ML20155H114 ML20155H128 ML20155H140 ML20155H153 ML20155H166 ML20155H175 ML20155H190
References
OLA, NUDOCS 8810180275
Download: ML20155H128 (18)

Text

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October 11, 1988 UNITED STATES OF AMERICA  !

NUCLEAR REGULATORY COMMISSION  ;

BEFORE THE ATOMIC SAFETY AND LICENSING '30ARD In the Matter of )

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

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

Station, Unit 2) )

LICENSEE'S TESTIMONY OF DAVID R. BUCHANAN ON THE EVAPORATION PkCPOSAL AND HE JOINT INTERVENORS' ALTERNATIVE (CONTENTIONS 2 and 3) i j

8810180275 881011 PDR ADOCK 05000320 C PDR

l Q.1 Please state your name.

A.1 David R. Buchanan.

Q.2 Mr. Buchanan, by whom are you employed, and what is your position?

A.2 I am employed by GPU Nuclear Corporation ("GPUN") as Manager, Recovery Engineering, at Three Mile Island Nuclear Sta-tion, Unit 2 ("TMI-2").

Q.3 Please summarize your professional qualifications and experience relevant to this testimony.

A.3 I have a B.S. degree in Mechanical Engineering and earned a professional engineer's license from the State of Pennsylvania. From 1959 through 1963, I worked for the U.S.

Steel Corporation. I then spent 16 years in engineering work at Westinghouse Electric Corporation's Bettis Atomic Power Laborato-ry. Since July, 1980, I have worked in various engineering posi-tions for GPUN (and its predecessor) in support of the recovery effort at THI-2. In my present position, which I have held since August, 1986, I am responsible for all engineering support, ex-cept for defueling, to the TMI-2 Division. A complete statement of my professional qualifications is appended as Attachment 1 to this testimony.

Q.4 What is the purpose of this testimony?

A.4 I will explain the GPUN proposal to evaporate the TMI-2 Accident-Generated Water ("AGW") and address the alternative raised by the Joint Intervenors, involving on-site storage fol-loved by disposal. In particular, in response to Contention 2, I will compare the resources necessary to implement the GPUN pro-posal and the alternative put forward by the Joint Intervenors.

In addition, in response to Contention 3, I will address the con-cern raised in Joint Intervenors' Material Statement of Fact 4(xiii) that the evaporator's batch cycle operation might have an effect on the dose to the public.

Q.5 How is your testimony organized?

A.5 First, I will describe briefly what AGW is and what has happened to the AGW since the TMI-2 accident. Second, I will explain the GPUN proposal for disposition of the AGW. Third, I will address the Joint Intervenors' alternative for disp?sition of the AGW. ,

, Q.6 What is Accident-Generated Water ("AGW")?

A.6 On February 27, 1980, an agreement executed among the

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City of Lancaster, Pennsylvania, Metropolitan Edison Company, and the NRC defined "Accident-Generated Water" as

a. Water that existed in the THI-2 Auxiliary Fuel 4

Handling, and Containment buildings including the primary system as of October 16, 1979, with the exception of water which as a result of decontami-nation operations becomes comingled with non-accident generated water such that the commingled water has a tritium content of 0.025 uci/ml or less before processing.

! b. Water that has a total activity o' greater than 1

> uCi/ml prior to processing except where such water is originally nonaccident water and becomes contaminated by use in cleanup.

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

Q.7 What has happened to the AGW since the TMI-2 accident?

A.7 Following the accident, GPUN installed three separate treatment systems to remove radionuclides and other contaminants from the AGW. The first was EPICOR II, which was placed into operation in October 1979 and employs ion-exchange media (organic as well as inorganic) coupled with particulate filters. The sec-ond was the Submerged Demineralizer System ("SDS"), which was I placed into operation in June 1981 and employed inorganic cesium and strontium specific ion-exchange media coupled with particulate filters to remove cesium and strontium ions from the water. The third system was the defueling water clean-up system

("DWCS"), which consists of filters and inorganic ion-exchange media.

Through mid-1981, when SDS began processing water contained in the Reactor Building ("RB"), approximately 1.3 million gallons of AGW existed at TMI-2. Of this volume, about 640,000 gallons were located in the RB. Direct release from the Reactor Coolant System ("RCS") contributed 69% of this water. An additional 28%

was river water introduced via leaks in RB air coolers at the time of the accident and the temaining 3% was added via the con-tainment spray system during the first sevetal hours of the acci-dent. Subsequent to 1981, most of this water was processed by both SDS and EPICOR 11 to reduce radionuclide levels to very low concentrations.

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0 In addition, approximately 570,000 gallons of water existed in the auxiliary and fuel handling building tanks, most of which had been processed through EPICOR II by mid-1981. The RCS contained an additional 96,000 gallons which also required pro-cessing by the SDS and the DWCS.

Since 1981, the total inventory of AGW has increased to the current volume of approximately 2.1 million gallons due to con-tinued additions from support systems and condensation from the RB air coolers during the summer months. Considerable care has been exercised to minimize the additions of new water and to en-sure that the commingling of non-contaminated water with the AGW is restricted. Even with exercising care to minimize additions of new water, the final volume of water will increase but is not expected to exceed 2.3 miilion gallons.

Q.8 What is the GPUN proposal for disposition of the AGW?

A.8 On July 31, 1986, GPUN filed with the NRC a report on the disposal of the processed, AGW at TMI-2. In the report, GPUN identified and evaluated three disposal options on the basis of relative technical feasibility, regulatory compliance, environ-mental effects, costs, vaste generated, and time required to ac-complish. On the basis of the evaluation documented in that report, GPUN selected and proposed for NRC approval the option of 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 collected during the evaporation process and the preparation of '

the resulting vaste product for shipment and burial at a commer-cial low-level vaste facility. GPUN has entered into a contract with Pacific Nuclear Systems, Inc., to supply the disposal sys-tem. In February, 1988, GPUN authorized the vendor to proceed to final design and fabrication of the disposal system for the spe-cific THI-2 application. A detailed description of the systems and evolutions which will accomplish the controlled disposal of 4 the AGW is contained in GPUN's Technical Evaluation Report for i

Processed Water Disposal System. A copy of that report is pro-vided as Licensee's Exhibit No. __.

Q.9 Please describe the AGW disposal program. '

A.9 The processed water disposal program consists of: (a) a l dual evaporator system designed to evaporate the processed water at a rate of five gallons per minute; (b) an electric powered va-porizer designed to raise the evaporator distillate temperature ,

to 240'F and to release the resultant steam to the atmosphere via l a flash tank and exhaust stack; (c) a vaste concentrator designed i

! to produce the final compact vaste form, and (d) a packaging sec- ,

t I tion designed to prepare the resultant vaste for shipment consis-tent with commercial low-level vaste disposal regulations.

Q.10 Mr. Buchanan, in Joint Intervenors' Material Statement ,

1 l of Fact 4(xiii) under Contention 3, the Joint Intervenors assert  ;

. the NRC's dose calculations are inadequate because the water  !

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entering the evaporator in batch cycle vill deviate from the con-centrations listed in Table 2.2 of NUREG-0683, Supp. 2. What is the batch cycle mode of operation? ,

A.10 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 independently of the vaporiz-er, and processes the water in a batch cycle method of operation.

The distillate from the evaporator is pumped to a separate staging tank and the feed to the vaporizar is supplied from an independent staging tank. Conversely, if the vaporizer is cou-pied to the evaporator during operations, the water is processed in a continuous flow operation. The distillate from the evaporator is fed directly to the vaporizer for atmospheric dis-charge.

Q.ll Are the Joint Intervenors' correct in their assertion that batch cyle operations will invalidate the NRC's dose calcu-lations?

A.11 No. Table 1, Columns 1 and 2 show the projected aver-age activity levels for the total 2.3 million gallons of AGW as-suming preprocessing of approximately 31 percent of the invento-ry. This data appears in NUREG-0683, Supp. 2, Table 2.2 and is identified as "Base Case" water. These activity levels formed the basis for the NRC Staff's analysis of the environmental effects of evaporator discharges. The activity releases occur-ring from evaporator discharges of "Base Case" water result in releases that are a small fraction of the releases permitted by existing regulatory requirements.

Since the PEIS analysis assumed processing "Base Case" water with a vaporizer discharge to the atmosphere containing 0.1 per-cent of the radioactive particulates from the intluent, that value vill be used as the system operating limit. Thus, when operating the processed water disposal system in the coupled mode 4

(evaporator and vaporizer in continuous operation), the volume of i vater being processed will be isolated from all sources of con-tamination. Its radionuclide content will be verified to be within limits so that quarterly average concentrations of all water processed in this mode vill be no greater than the concen-trations listed in Table 1, Column 2. When processing water i through the vaporizer in the decoupled mode (independent of the evaporator), the quarterly average vaporizer influent concentra-tions will be no greater than 0.1 percent of the values in j Table 1 Column 2. These limits equate to an atmospheric release rite for particulate radionuclides of 8.23E-5 uCi per second if i

j processing water containing the maximum limits at a rate of five gpm. In short, the system operating limit vill be the same for j all methods of operation, and the batch cycle operation of the 1

evaporator will not affect the resulting dose calculations, i

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Q.12 What is the estimated cost for the evaporation propos-al?

A.12 Based upon vendor price quotes, the evaporation and vapori?ation of 2.3 million gallons of processed water and the packaging of the resulting evaporator bottoms is estimated to cost $1.7 million. The transportation and disposal of the pack-aged evaporator bottoms vill cost an estimated $293,700.

Preprocessing approximately 31% of the water volane 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 the evaporation proposal is esti-mated to be approximately $4.1 million. Itemized cost estimates are presented in Table 2.

Q.13 Please describe the Joint Intervenors' alternative for water disposition.

A.13 It is not clear that the Joint Intervenors propose any option, since in discovery they stated they did not have suffi-cient information to select a preference. They have urged that further study be given to what Joint Intervenors call, in Contention 2, the "no action" alternative. However, the term "no-action" alternative is really a misnomer. Under this alter-nativo, as defined by the Joint Intervenors, the AGW vould be

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stored in tanks on the TMI site for some period of time, followed by disposal of the AGW in some manner. The Joint Intervenors vould not specify an eventual disposal method. It is clear, how-ever, that both the storage and the eventual disposal would re-quire action.

During discovery, the Joint Intervenors were asked the length of storage they proposed for their alternative. They would not provide a quantitative answer, but responded that the AGW should be stored on-site until THI-1 is decommissioned.

While TMI-l's operating license is scheduled to expire in 2008, I have assumed a potential plant life extension of 10 years. For purposes of this assessment, then, the period of storage under the Joint Intervenors' alternative is assumed to be 30 years.

Presently, the AGW is stored in two approximately 500,000

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ga11on Processed Water Storage Tanks ("PWSTs") and various tanks and systems throughout TMI-2. In order to complete the cleanup l

of the plant, the approximate 1y one million gallons of water in

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l the various plant systems such as the RCS and the Fuel Transfer Canal must be drained. Therefore, the Joint Intervenors' alter-native would require the construction of additional tanks en the TMI site at a cost of between $1.3 million and $9.1 million.

The above estimate includes the cost of heat tracing four i

500,000 gallon tanks for 30 years. Heat tracing protects the tanks from the inclimate weather of the winter months and pre-vents the AGW from freezing and damaging the structure of the storage tanks.

Q.14 Why is there a range for the cost of the Joint Inter-venors' alternative?

A.14 The cost of Joint Intervenors' alternative vill depend upon the assumptions made for the design criteria used for the storage facilities. One set of assumptions vould require the construction of two additional 500,000 gallon tanks to be co-located with and designed to the same standards as, the existing PWSTs. It is estimated that it will cost $1.3 million, excluding piping, monitoring, and pumps, to build two such tanks.

Another set of assumptions, put forward by the Joint Inter-venors in response to Licensee's Motior for Summary Disposition, would require constructing new tanks to the standards of Generic Letter 81-38 for temporary vaate storage. The criteria in Gener-ic Letter 81-38 are predicated on a five-year storage period.

However, the duration of the intended storage, the type and form of vaste, and the amount of radioactive material present dictate the actual procedures necessary to implement the standards of Ge-neric Letter 81-38. As the length of storage increases, the nec-essary controls and systems for implementation of Generic Letter 81-38 also increase.

Q.15 What standards are set forth in Generic letter 81-38?

A.15 Generic Letter 81-38 includes provisions which would have the tanks designed to:

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(a) seismic criteria; j (b) withstand the corrosive nature of the wet vaste stored; i (c) have curbs or elevated th'resholds with floor drains and sump to safely collect wet waste assum-ing the failure of all tanks or containers; (d) remove spilled waste to the radwaste treatment systems; (e) monitor liquid levels and to alarm potential over-flow conditions; (f) control, if feasible, and monitor all potential release pathways of radionuclides pursuant to 10

C.F.R. 50, Appendix A (General Design Criteria 60 and 64);

1 (g) integrate the required treatment with the vaste

)l processing and solidification systems; j (h) have the same level of security as exists for the i plant protected areas; and (i) be heated electrically for freeze protection.

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Q.16 What is your estimate of the costs of constructing new tanks to the standards of Generic Letter 81-38 for the storage of 1

2.3 million gallons of processed water?

A.16 It is estimated that it will cost $9.1 million to con-i struct tankage meeting the standards of Generic Letter 81-83 i (5-year storage period) and capable of holding 2.3 million gal-

! lons of AGW. A detailed cost breakdown is contained in Tcble 3.

i Q.17 In response to summary disposition motions, the Joint l

Intervenors speculated that new technology may develop which will 1

l reduce storage costs. What do you believe the potential is for i

, new technology which will reduce the storage costs?

A.17 Scientific research and development always give reason to hope that technological advances vill bring safer and cheaper technology. However, at the present time, I am not aware of any new or developing technology which would result in decreasing the costs associated with storage of the AGW for thirty years.

Q 18 Mr. Buchanan, in conclusion, how do you compare the evaporation proposal and the alternative identified by the Joint Interveners, from the standpoint of costs?

A.18 If our proposal is approved, GPUN vill have spent about $4.1 million to lover the level of radioactivity and to dispose of the AGW by evaporation, a process which, according to the testimony of Dr. Baker, vill reduce the off-site doses to the bone to 3.6 mrem for the hypothetical maximally exposed individ-ual, and to 0.011 mrem for the everage person within a 50-mile radius. It has been difficult to estimate the costs of Joint In-tervenors' alternative because it remains so ill defined. If one makes the simplistic, but conservative, assumption that the costs of disposal now and after 30 years cancel each other out, one is lef t with the additional $1.3 million to $9.1 million cost of the storage period. The expenditure of such funds to achieve what, according to Dr. Baker, might be a reduction in these extremely small doses by one-half, is unjustified in my view on ALARA or 1

any other cost / benefit bases.

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TAtt.t 1 1AINIlflCA710ff M RADIQNUCLIDr$ IN PROCE13E0 WATER Column 1 Column 2 Column 3 Coluem 4 Column 5 Curies Concentration Specific total Grams PreSent in in vC1/m1 Activity in A-2 Present in Nuclidas M in 2.3 M6AL _

C1/aram l y.gijtt, 2.3 M4AL l 1 I I l Ce s i um-137 l 3. 2 C-1 l 3.7t-5 l 9.8t+1 l 10 l 3.7t-3 Cesium-134 l 7.66t-3 l 8.8[-7 l 1.!!+3 l 10 l 6.38t-6 Strontium-90 l 9.6E-1 l 1.1 t -4 l 1.St+2 l 0.4 l 6. 4 t -3 Antimony-125/ l 2.0E-2 l 2.3C-6 l 1.4t+3 l 25 l 1.43t-5 Tellurium-125m l l l 1.8(t4 l 100 l Carbon-14 l t.7E-1 l 1. 0E -4 l 4.6 l 60 l 1.49t-2 Tecnnetium.99 l 8.7E-3 l 1. 0E-4 l 1.7t-2 l 25 i S .12 t-1 tron-55 l 4.2E-3 1 4.8E-7 l 2.2t+3 l 1000 '

).91t-4 Cob 41t-60 l 4.2E-3 l 4.8t-7 l 1.1t+3 l 7 3. ett-4 todine-129 l <5.2C-3 l <6.0t-7 l 1. 4 L-4 l 2 l.<3.Ht+1 Cerium 144 l <1.4E-2 l <1.8t-6 l 3.!E+3 l 7 l <4.368-4 Manganese-54 l < 3. 5 E -4 l <4.0C-8 l 8.3t+3 l 20 l <4.2t-8 Cobalt-58 l <3.St-4 l <4.0E-d l 3.1C+4 l 20 l <1.13C-8 Nickel-53 l <5.2[-3 l <0.0E-7 l 4.6t+1 l 100 l < 1.1 t -4 Zinc-45 l < 8. S t -4 l <t.8t-8 l 8.0t+3 1 30 l <1.06L-7 Rutheniam-106/ l <2.9t-3 l <3.3t-7 l 3.4E+3 l 1 l <8.53E-7 Rhodium-106 l l l l l 511ve r-110m l <4.st-4 l <5.6E 8 l 4.7t+3 l 7 l <1.04E-t Promethium-147 l <4.2t-2 l <4.St-6 l 9.4E+2 l 25 l <4.47E-5 i Europium-152 l <3.3E-6 l <3. S t -10 l 1.9t+2 l 10 l <1.74L-g Europium-154 l < 3 . 8 E -4 l <4.4t-8 l 1.3E+2 l 5 l <2.531-6 1

Europium-ISS l <f.6t-4 l 41.It-7 l 1.4E+3 l 60 1 <6.56E-7 Uranium-234 l <8.7t-5 l <1.0E-8 l 6.2t-3 l 0.1 l <1.40E-2

, Uranium-235 l <1.0E-4 l <1.2t-8 l 2.lt-6 l 0.2 l <4. 7 6 E +1 Uranium-tas l <1.0E-4 l <l.2t-e l 3.3E-7 Unlimited l <3.03E.2

{ Plutonium-238 l <1.0E-4 l <1.2t-s l 1.7E+1 l .003 l <5.esE-6

Plutonium-239 l < 1. 2 C -4 l <1.4t-5 l 6.2E-2 l .007 l <l.94E-3 Plutonium-240 l < 1. 2 E -4 l <1.4C-8 i 2.3E-1 l .002 l <5.22t-4 Plutonium-241 l <5.7t-3 l <6.5C-7 l 1.1E+2 l 0.1 l <b.16L-5 Americium-241 l <1.0t-4 l <1.2t-8 l 3.2 l .008 l <3.13E-5 l Curium-242 l <8.7t-4 l <1.0C-7 1 3.3t+3 l 0.2 l <2.64L-7 l l l l 1 i Total l <2.27 Ci l <2.6t-4 wCi/mi l l<384.66 grams t

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• I TABLE 2 {

ITEMIZED COSTS FOR THE EVAPORATION PROPOSAL  ;

. I Distillation & Packaging of Bottoms Preliminary Design S 36,000 Fabricate, Test & Install Equipment $801,000 l Training & Psychological Screening S 5,000 l Distillation of 2.3 MG Processed $735,000 Water .

Packaging of Evaporator Bottoms S 80,000 Demobilization 1_33.000 ,

Subtotal $1,690,000 l Disposal of Evaporator Bottoms .

17 C 55-gallon Drums (590) $ 24,000 Truck Shipments (8) $ 40,000  !

GPUN Loading Operations $ 10,000 Disposal of Class A Drums $220.000 Subtotal $ 294,000 Preprocessing 31% PW Volume $2,100,000  ;

(Total cost, including all operations j

& handling resin, liners, transportation

& burial) l TOTAL COST: / S4.084.000/ ;

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TABLE 3 ITEMIZED COSTS FOR GENERIC LETTER 81-38 TANKAGE Direct Costs Labor $1,800,000 Materials $4,700,000 Subtotal S6,500,000 Indirect Costs Construction Management $1,630,000 Engineering / Administration S 175,000 Subtotal $1,805,000 Contingency at 10% s 830,000 TOTAL ESTIMATED COST / $9,135,000/

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s RESU E i

David R. Buchanan P.O. Box 440 .

Middletown, PA 17057 WORK H!$70RY 07/80 - Present GPU Nuclear Corporation /GPU service Corporation Current

Title:

Manager, Recover Dep t./ Loc. : Site Or.erattons.yTMI-2 Engineering TM!-2 1

! Responsible for all engineering su defuelfng, to the TMI-2 Ofvisfon. pport, except for Activities include plant modiffeatfons, support to Operatfons and Maintenance, Radfocheetcal Engineering, Start-Up and Test, ar.4 Fire Protectien. The' section was formed September HM, by contr.ing the

$1to Engineering and Plant Engineering sectfons, i 02/M - 04/M - Manager, site Engineering, TMI-2. Provided on-site i.

1 engineering support to ensure technical adeguacy of recovery efforts. Prepared and revfewed safety evaluations and modiffcation packages, plus developed and managed the progree for Important to Safety (ITS) deterstnetton to correctly classtfy ,

! recovery programs work. Also, responsible for

! TM1-2 start Up and Test activities.

12/84 - 2/M - Task Leader, Reactor Of sansembly and Defuelino.

Responsible for providing progrise:ette direction '

and technical overview for on-site recovery

, activities related to reactor defueling/disassently j j as assigned by the Manager, Recovery Programs, Assignments included defueling plus defueling water '

clean-up systees, Waste Handling and Packaging Facility, and the sediment Transfer System.

09/82 11/M - Manager $1te Engineering, TM!-2. Same as during I February 1984 through August 19M,  ;

04/81 - 09/82 - Manager, Project Engineering. Managed the Project Engineering section to include direction of 4

tec*inical work, sonttoring attainment of department

! cost / schedule goals and managing projs:ts such as RCS Processing, Ep!C0A Yenting, and engineering involvement in the Quick Look Entry, i

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D. R. Buchanat Pan 2 y 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 Egloyed at Bettis Ateetc Power Laboratory in the positions of Associate Engineer, 'tefueling Equipment Design and Operations; Senior Engineer, Fluid Systems; Supervisor / Manager, Manual Welding Support; Materials Evaluation Laboratory Engineering Manager; and Decontaminetton Engineering Manager.

07/59 - 12/63 - LS.SteelCorporation Entered management training program. Majority of experience as Roll Designer for structural and I

plate mills. -

EDUCATION l.S., Mechanical Engineering, Lehigh University,1959 LICENSES AND CERf!FICATES -

P.E. License, state of Pennsylvania,1965 I

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