ML20196F118

Responses to NRC Interrogatories.* All Responses Re Disposal of Accident Generated Water by Intervenor F Skolnick. Certificate of Svc Encl.Related Correspondence

ML20196F118
Person / Time
Site:	Three Mile Island
Issue date:	02/22/1988
From:	Skolnick F SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#188-5700 OLA, NUDOCS 8803020037
Download: ML20196F118 (12)

Text

___ __ _.

c __

atnTro comseoNMNJB UNITED STATES OF AMERICA '

00CMETED USNRC NUCLEAR REGULATORY COMMISSION 2 FEB 29 P3 54 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD (rr y ; .,

u0Cn t i oiG .s

[, e,'i ' ..

In the Matter of )

Docket No.50 320*0LA GPU Nuclear Corporation Disposal of Accident Three Mile Island Nuclear

} Generated Water Station, Unit 2.

SVA/TMIA'S RESPONSES TO NRC'S INTERROGATORIES Following is the SVA/TMIA's reponses to the NRC's Interrogatories.

A11Eresponses were made by the Intervenor, Frances Skolnick, B.A (Econ). These responses are expected to be supplemented at a later date.

8803020037 080222

{DR ADOCK 05000320 PDR 9

3)

o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

Docket No.50-320-OLA GPU Nuclear Corporation )

Three Mile Island Nuclear Station, )

) Generated Water Unit 2 AFFADAVIT OF FRANCES SKOLNICK I. Frances Skolnick,being first duly sworn, deposes and says that:

1. I am a member of The Susquehanna Valley Alliance and Three Mile Island Alert and represent those organisations as an intervening party in the above captioned matter.

2. I have read the foregoing responses to Interrogatories,and the same are true to the best of my knowledge.

^ 'aneo r / C Frances Skolnick DATED: February 22nd,1988 Sworn and subscribed before me on this 22nd day of February,1988.

SO v NOTARY PUBLIC m s.nat setAav Pusuc Lancastes.tAncastas comuff av commisse tmett mt 8. test peeser.P,essyken:a Assessette of 584anet

February 22nd.1988 UNITED STATES OF AMERICA 00ggE0 NUCLEAR REGULATORY COMMISSION 118 FEB 29 P3:54 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '[g'yd, hip-fj.? '

ax.n In the Matter of )

)

GPU Nuclear Corporation ) Docket No 50-320-OLA

)

Three Mile Island Nuclear ) Disposal of Accident

)

Station, Unit 2. ) Generated Water i

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing SVA/ THIA's Responses to the NRC's Interrogatories were served this 22nd. day of February upon the NRC by U.S Postal Service Priority Mail and upon the remainder of the service by First Class mail.

l

,go/

Frances Skolnick e

I 4 t-I i

, t

\

SERVICE LIST Sheldon J. Wolfe, Chairman John R. McKinstry, Esq.

Administrative Judge Assistant Counsel Atomic Safety and Licensing Commonwealth of Penn.

Board Panel 505 Executive Houst U.S. Nuc1 ear Regulatory Commission P.O. Box 2357 Washington, D.C . 20555 Harrisburg, Pa. 17120 01enn O. Bright Thomas A. Ba,ter, Esq.

Acknini strat ive Judge Shaw, Pittmari, Potts &

Atomic Safety and Licensing Trowbridge 2300 N Street, N.W.

Board Panel Washington, DC 20037 U.S. Nuclear Regulatory Commission Washington, D.C. 20111 Stephen H. Lewis, Esq.

Dr. Oscar H. Paris Office of the General Adminisieative Judge Atomic Safety and Licensing Counsel U.S. Nucle ar Regul ator y Board Panel Commission U.S. Nucl ear Regul atory Comni ssion Washington, D.C. 20555 Washington, DC 20555 Dr. William D. Travers Ms. Vera Stuchinski Dir. Three Mile island Three Mile Island Alert Cleanup Project Directore 315 Peffer Street Harrisburg, Pa. 17102 P.O. Box 311 Middletown, Pa. 17057 l

Docketing & Services Brarrh R. Rogan, Director Licensing and Nuclear Safety Secretary of the Ccrmission TMI 2 U.S.N.R.C.

Middletcm, PA 17057 Washington,DC 20555.

hMW w (

Frarces Skolnick

Interroaatory 1 State the names, addresses and professional qualifications of the persons intervenors will present as expert witnesses at he4 ring.

Answcr At this time Intervenors have not yet determined who their witnesses will be. This in6rmation will be provided as soon as possible.

Dr K.Z.Horgan will be a witness. He resides at:

1984 Castleway Drive Atlanta, Georgia 30345.

Professional Qualifications:

Chairman of the Internal Dose Committee of both I.C.R.P and N.C.R.P Worked with and researched ionizing radiation and health physics problems for over 50 years.

Interrogatory 2 State by author, title date of publication and publisher all books texts and papers upon which each person named in the response to Interrogatory I relies to support that person's testimony.

Answer This information is not yet available to Intervenor.

Interrogatory 3 Describe and provide all independent calculations, physical and

=athematical models upon which each person named in Interrogatory I relies.

Answer This information is not yet available to the Intervenor.

Interrogatory 4 In regard to Contention 1, a) state all methods of disposal of the accident generated water (AGW) at TMI-2 which you claim would result in lower releases of tritium and other radionuclides than the evaporation method and b) what radiological doses you claim will occur from the evaporation of the AGW7 Provide all calculations which cupport your claim.

Answer Those methods of disposal which would result in lower releases 6f tritium and other radionuclides include:

a) Temporary monitored storage in tanks on site b) Long-term monitored storage in tanks on site c) Trucking water off-site to Nevada d) Distillation with solidification of condensate and bottoms and removal to a Low Level waste site.

e) Distillation and removal of condensate and solidified bottoms to a Low Level waste site.

b) It is our opinion that the analysis of water samples is not complete. Further information about the water has been requested in SVA/ THIA's Interrogatories to the NRC and GPU. We are not therefore able at this time to calculate the dose from evaporation. l I

Our position is that the NRC and the Licensee may have under-estimated the dose from the evaporation of the AGW.

t Interrogatory 5 _

In regard to Contention 2.please explain a) why you claim that leaving the AGW on site is environm entally preferable to disposal b)for what length of time you claim the water should remain on site,and c)what impact would occur if the tanks containing AGW rusted and ruptured. Provide all calulations to support your answers.

Answer We claim that leaving the AGW on site is environmentally preferable to evaporation because evaporation will entail the dispersal of radionuclides and other contaminants into our air, j food and water. Maintaining the water on-site will allow for the radioactive decay of the radionuclides,particularly tritium. l It is our position that the-impact from evaporation is compounded by other radiological releases and where possible it is more prudent to contain low-level waste than to disperse it into our environmnent.

b) It is expected that the water may remain on-site at least until Unit 1 is decommissioned and for as long as Unit 2 remains in Post Defueling Monitored Storage. Dr Travers recognises the costs and benefits particularly dose savings to workers derived from placing the Unit 2 in Post Defueling Monitored storage.

(Citizens' Advisory Panel Meeting, February 1987. This same philosophy could be applied to the storage of the water since the ,

radionuclides in the water are derived fromthe same source and have the same half lives. The dose savings to both workers and public could be recognised. <

c) It is understood that tho tanks may rust.howaysr.we demand that storage on site would be required to meet all necessary NRC regulations for the storage of low level waste on-site.

On site storage of the water would entail monitoring which would include the monitoring of the capabilities of the tanks to hold the water.

It is impossible to determine the dose from a ruptured tank without knowing a) the size of the tanks and their contents b)their placement c)the degree to which the water will be decontaminated assuming that it could be decontaminated even more than the achievable case.

Interrogatory 6 In regard to Contention 3,specify a) the dose and the physiological harm to the public you claim will occur as a result of the radioactive releases from the evaporation of the accident-generated water and b) the risks to the public from removal of the i solidified waste remaining after evaporation. Provide all

' calculations and references to support your claim.

a) the dose to the public is a function of the radionuclide d-content of the water and the ability of the evaporator to operate.

! It is our position that the influent to the evaporator has not

! been adequately characterised and also we need more information about the evaporator to determine if it can 6perate effibiently, b) The risk to the public from the removal of the solidified waste l remaining after evaporation lies in the ability / inability of the Licensee to keep the generation of low level waste to those levels where it can be accommodated by the DOE.

4

Interrogatory 7 l l

In regard to Contention 4, explain a)the basis for your claim that the evaporator cannot be designed and constructed so as ,

)

to effectively filter transuranics.other radionuclides,and chemicals !

b) what safeguards you believe should be installed in the evaporator j and c)what harm you claim will result from a variance of 3-20 gallons per minute of influent to the evaporator.

~ '

Answer ,

al We are piesently in the process of hiring a consultant who will respond to this, b) See a) c) See a)

Interrogatory 8 In regard to contention 5d.specify a)the basis for your claim that the 1987 EIS underestimates the effects of tritium and alpha emitting radionuclides on human beings and b) the exact amounts of plutonium and other transuranics which you claim will be released by the evaporator. Provide all calculations and scientific references to support your claims.

Answer The basis for our claim that the EIS underestimates the effects of tritium and alpha emitting radionuclides include:

1) the NRC did not undertake its own independent evaluation of the water,instead it relied on 1979 estimaces of the tritium inventory and the Licensee's analysis of the water.

2) The NRC in calculating effluents from the evaporator relies on averages.

4

- 3) The NRC rscognises that tritium is "most hozardous as a critiated organic compound". The discussion does not lend itself to a complete evaluation of this property and the effect of the release of over 1000 curies of tritium.

4) The NRC underestimates the length of time tritium will remain I

in the body.

5) We question the form of tritium when released by evaporation.

If tritium is released as a vapor and not a gas it is much more hazardous. (See EIS,P.A.27-letter from Dr Carl Johnston).

6) the effect of alpha emitting radionuclider are dismissed by the conclusionary statement that "chemical toxicity of the transuranics is negligible"at the environmental concentrations l expected"(EIS P.7.6). This statement is made even though the NRC did not evaluate its own samples of all the accident generated water. Furthermore from the one sample analysis undertaken by the NRC,it is shown that Plutonium is detectable and that the analysis results by Westinghouse and the NRC show a considerable variance for Plutonium.

b) We have not analysed samples of the water and therefore we are unable to determine the amount of plutonium 238 and other transuranics which might be released by the evaporator.

The basis for the above claim are to be found within the EIS, Supplement #2 June 1987

Interrogatory 9

' in regard to Contention 6 specify a)the types and amounts of chemicals you claim have been added to the AGW and b) what effects you claim will occur from these chemicals to the Epicor 11,SDS and evaporator systems. Provide the scientific basis for your answers.

Answer We are unable to answer this question before receiving answers to our Interrogatories and hiring a Consultant.

The basis for our concerns lie in EIS Vol 1, March 1981,Section 7.

Integregatory 10 In regard to Contention 8 a)specify the financial cost 6f closed cycle evaporation,b) explain the basis for your claim that the water can be stored in tanks inside Unit 2 without accidental release of the AGW from deterioration of the tanks, amd c)specify the benefits of closed cycle evaporation and transport of the bottoms and condensate over the Licensee's proposal.

Answer a) We are not able to specify the financial cost of closed cycle evaporation and feel that our inability to do this has no relevance to this contention.

b) We expect that since the Licensee has stored the water for 8 years and the NRC has regulated this activity that they also monitor the capabilities of the tanks. We would expect that if the water remains on site that it would receive the same attention as the rest of Unit 2 while it is in Post Defueling Monitored Storage.

c) The benefits are derived from the decreased dose 6btained ,

by operating the evaporator in a closed cycle.

Interrogatory 11 Specify the benefit of placing tanks of AGW in Unit 2 in regard to the radiation exposure to personnel and risk of mishap when >

moving the tanks.

Answer The workers will receive exposure whether they are moving the tanXs to sit..inside Unit 2 or making the water availabic to the ,

evaporator. The workers will therefore face risks no matter which method is chosen. We are not in the position to evaluate which risk is greater.

Respectfully Submitted,.

r r~g ,\ Q 3 ,/d. U ' #

Frances Skolnick r

t F

-...,-es. , -