ML20205G172

Forwards Revised Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms,Revising Dose Calculations to Reflect That Tritium Deemed as Critical Isotope for Util Plan to Evaporate Water.W/Svc List.Related Correspondence

ML20205G172
Person / Time
Site:	Three Mile Island
Issue date:	10/25/1988
From:	Baxter T GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Bloch P, Bright G, Paris O Atomic Safety and Licensing Board Panel
Shared Package
ML20205G177	List: ML20205G172 ML20205G185
References
CON-#488-7370 OLA, NUDOCS 8810280204
Download: ML20205G172 (5)

Text

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October 25, 1988 Peter B. Bloch, Esquire Mr. Glenn O. Bright Atomic Safety and Licensing Atonic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Consission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclesr Regulatory Commission Washington, D.C. 20555 In the Matter of GPU Puclear Corporation (Three Mile Island Nuclear Station, Unit 2)

Docket No. 50-320-OLA (Disposal of Accident-Generated Water)

Administrative Judges Bloch, Bright and Paris:

Licensee has discovered an inconsistency in its dose calcu-lations presented in the testimony of Dr. Baker and Mr. Cooper, filed on October 11, 1988. The error produced higher estimates of the doses associated with particulates (such as strontium-90) than are actually expected. While Licensee's prior calculations dro Conservative, bounding the dose consequences of evaporation, the overestimate of doses from particulates impacts the testimony on the relative contributiens of tritium and strontium-90 to the dose estinatas. Consequently, an amendment to Licensee's prefiled testimony is necessary. Based on the reviscd dose cal-culations, Licensee agrees with the NRC Staf f that tritium is the critical isotope -- that is, tritium is the greatest contributor to doses relating to GPUN's proposal to evaporate the accident-generated water.

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. SHAw, FITTMAN, PoTTs & Tmowomoot

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Peter B. Bloch, Esq.

Mr. Glenn O. Bright Dr. Oscar H. Paris October 25, 1988 Page 2 Licensee's over-estimate of the doses associated with particulates stems from GPU Nuclear's original July 1986 proposal on disposal of the AGW. At that time, GPUN did not have a spe-cific disposal system design and therefore selected a decontami-nation factor of 100 to generically and conservatively bound the dose consequences of evaporation. As GPUN developed more in-formation, it was determined that the evaporator can easily achieve a decontamination factor of 1,000 (or more), and the NRC Staff's dose calculations are based on this greater decontamina-tion factor. The reasonableness of this decontamination factor was endorsed by the Board in its summary disposition ruling on contention 4b. Yet TMI Environmental Controls lost sight of the fact that its original dose calculations had assumed a decontami-nation factor of only 100 Jor particulates.

The consequences of this oversight are as follows: Lince tritium is not reduced by evaporation, the doses associated with tritium in the AGW remain the same. However, the prior estimates of the doses associated with particulates, and in particular strontium-90, were overestimated by a factor of 10. Thus, with a decontamination factor of 1,000, the bone dose to the maximally exposed individual due to strontium-90 in evaporator effluent is estimated to be approximately 0.4 mrem (0.36 mrem rounded off) rather than 3.6 mrem. The whole body dose to the maximum indi-vidual is now 1.3 mrem (of which 1.2 mrem still is attrjoutable to tritium), instead of 2.0 mrem.

Reflecting these changes, attached is a revised copy of Licensee's Testimony of Dr. Gary G. Baker and William J. Cooper on Dose Assessments and Microorganism (Contentions 2, 3, and 5d).

Changes have been made to Q/A Numbers 6, 12 through l's, and 17.

The dose estimates presented by Dr. Baker And Mr. Cooper are also used in the tritium health effects testimony by Dr. Fabrikant and Dr. Auxier. The necessary mathematical adjustments to their testimony are a)Lo enclosed in the form of replacement pages 87 through 92 te their testimony of October 11, 1988. Mr. Weaver (at Q/A No. 8) and Mr. Buchanan (at Q/A No. 18) repeat a few of the dose figures presented by Dr. Baker and Mr. Cooper. These obvious changes will be made orally by the witnesses as technical corrections.

, SHAw, PITTM AN, PoTTG & TAow3 RIDGE

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Mr. Glenn O. Bright Dr. Oscar H. Paris .

October 25, 1988 '

Page 3 i

In order to minimize inconvenience, Licensee is filing these  !

corrections promptly upon discovery of the error, and in advance of the hearing. Copies of this revised testimony are being de- i livered by Federal Express to Joint Intervenors and the Common-wealth of Pennsylvania and are being hand delivered to the NRC Staff and the Board.

Sincerely, i m= : : ,

Thomas A. Baxter a

Counsel for Licensee f

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Enclosures

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16 DCT 26 P5:41 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 06n "4'u 60Chilo.h'.o~t'o FRt BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of ) ,

)  ;

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

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

Station, Unit 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing letter from Licensee's counsel to the Licensing Board, "Licensee's Testimony l

of Dr. Gary G. Baker And William J. Cooper On Dose Assessments +

And Microorganisms (Contentions 2, 3 and 5d)" and pages 87 l through 92 of "Licensee's Testimony Of Dr. John A. Auxier And Dr.

Jacob I. Fabrikant On The Health Effects Of Tritium (Contentions P

3 and 5d)" were served this 25th day of October, 1988, by Federal i j

l

! Express upon the parties identified with one asterisk, by U.S.

mail, first class, postage prepaid, upon the other parties iden-tified on the attached Service List, and by hand delivery on October 26, 1988 upon the parties identified with two asterisks.

I l

/f _ I Thomcs A.' Baxter, P.C t

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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 ) Generated Water)

Station, Unit 2) )

SERVICE LIST

• • Peter B. Bloch, Esquire

• Richard P. Mather, Esquire Atomic Safety and Licensing Department of Environmental Board Panel Resources U.S. Nuclear Regulatoxy Commonwealth of Pennsylvania Commission 505 Executive House Washington, D.C. 20555 Harrisburg, Pennsylvania 17120

• • Mr. Glenn O. Bright

• Ms. Frances Skolnick Atomic Safety and Licensing 2079 New Danville Pike Board Panel Lancaster, Pennsylvania 17603 U.S. Nuclear Regulatory Commission Ms. Vera L. Stuchinski Washington, D.C. 20555 315 Peffer Street Harrisburg, Pennsylvania 17102

• • Dr. Oscar H. Paris Atomic Safety and Licensing Adjudicatory File Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Panel Docket Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

• • Stephen H. Lewis, Esquire Colleen P. Woodhead, Esquire office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Services Branch Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555