ML20205Q644

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Transcript of 881101 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 288-572.Supporting Info Encl. Witnesses:K Hofstetter,Kl Harner,L Thomas & M Masnik
ML20205Q644
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 11/01/1988
From:
Atomic Safety and Licensing Board Panel
To:
References
CON-#488-7512 OLA, NUDOCS 8811090306
Download: ML20205Q644 (288)


Text

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i lO UNITED STATES l NUCLEAR REGULATORY COMMISSION  !

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ATOMIC SAFETY AND LICENSING BOARD li j

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r j In the Matter ofi )

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i i GENERAL PL3LIC UTILITIES NUCLEAR ) l l CORPORATION. et al. 1 Docket Number I

) 50-320-OLA (THREE MILE ISLAND. UNIT 2) )

LICENSE AMENDMENT APPLICATION )

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Pages: 268 through 572  ;

l Place: Lancaster. Pennsylvania I I

Date: November 1. 1988 l 1

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th \ i O HERITAGE REPORTING CORPORATION om*t A,== l 1224 L 54reet, N.W., Seine 6M i

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-l 288 r UNITED STATES NUCLEAR REGULATORY COMMISSION

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(_ - ATOMIC SAFETY AND LICENSING BOARD  !

Tax 50Ttl l t

In the Matter oft ) l

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GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-320 OLA CORPORATION, 21 alu )

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(THREE MILE ISLAND. UNIT 2)  !

LICENSE AMENOMENT APPLICATION ) l i

Tuesday, November 1, 1988 l

i Courtroom A & Sixth  !

Floor Hearing Room )

Lancaster County Courthouse  ;

50 North Duke Street r

() Lancaster. Pennsylvania 17603 {

The above-entitled matter came on for hearing.

4  !

i pursuant to notice, at 9:i00 e.m. {

1 i BEFORE: JUDGE PETER BLOCH. Chairnen f Atomic Safety & Licensing Board [

U. S Nuclear Regulatory Commission i Washington, D.C. 20555 i

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JUDGE OSCAR PARIS. Member Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission j j WashinEton. D.C. 20555 .

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l JUDGE GLENN O. BRIGHT, Member l Atomic Saf ety & L icensing Board l

U. S . Nuclear ReCulatory Conmission j l

Washington, D.C. 20555 i -

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APPEARANCES:

On behalf of the Licensee. GPU Nuclear Coro.:  ;

THOMAS A. BAXTER. Esquire '

DAVID R. LEWIS. Esquire MAURICE A. ROSS. Esquire l Shaw. Pittman. Potts & Trowbridge. P.C. l 2300 "N" Street. N. W. t Washington. D. C. 20037 '

[

ROBERT E. ROGAN l Director of Licensing & Nuclear Safety '

for GPU Nuclear Corp. l Three Mile Island Unit 2 {

On behalf of_the_U.S. Nuclear Regulatotg  !

Commission Stafft l l

STEPHEN H. LEWIS. Esquire r COLLEEN P.WOODHEAD. Esquire [

U. S. Nuclear Regulatory Commission  ;

Office of General Counsel L Washington. D.C. 20555 [

pn behalf of the Connnnwealth of Pennsv1vanina

- () RICHARD MATHER. Esquire Assistant Counsel I Department of Environmental Resources [

- and -  ;

AJIT BHATTACHARYYA  ;

Bureau of Radiation Protection l Department of Environmental Resources [

505 Executive Building }

P.O. Box 2357 L Harrisburg. Pennsylvania j t

Qp behalf of the I nt e rve no r s. Susquehanna Vality j Alliance & Three Mile Island Alerta j i

FRANCES SKOLNIX t 2079 New Danville Pike i Lancaster. Pennsylvania 4

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290 CONTENTS WITNESSES.: DIREC_T CROSS REDIRECT _ RECROSS _ LVM Ennel:

KENNETH HOFSTETTER Y,ERRY L. HARNER by Mr. Baxter 325 by Ms. Skolnik 340 Etulelt 344 LEE THOMAS

, MICHAEL MASNIX by Ms. Skolnik 355 by Mr. Mather 429 by Ms. Skolnik 434 Panel:

DAVID BUCHANAN 439 WILLIAM WEAVER JAMES TARPINIAN by Ms, Skolnik 483 O

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l 291 l CONTENTS EEHIBITS: IDENTIFIED _ RECEIVED DESCRIPTJQR  !

NRC Staff 355 355 NRC NUREG-0683 Programmatic l Exhibit Environmental Impact Statement l L icensee 's 448 470 Processed Water Disposal Exhibit i System Technical Evaluation ;

Report '

JHSERTS:

Descrip*1cn: Pace:

TMI-2 Processed Water Source 336 Terms '

Tostimony of Lee Thonus and 346 Michael Masnik O Licensee 's Testimony of James E. Tarpinian on 441 Occupational Dose Assessments (Contention 2)

Licensee 's Testinony of 452 David R. Buchanan on the Evaporation Proposal and the Joint Intervenors ' Alternative (Contentions 2 and 3)

Licensee 's Testirony of 473 l William W. Weaver on Accident Risks (Contention 2)

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I i PROCEEDINGS 1 2 JUDGE BLOCH: Good morning. With deep respect I i 3 welcome you all to the second day of hearings on accident 4 generated wates. j 5 I'd like to note for the record that Ms. Skolnik [

6 is not here. Dr. Paris also will bc ar/iving late.

7 In the absonce of Ms. Skolnik, we will now I i

8 immediately recesu for some time until she arrives. Thank i e

i 9 you. [

4 j

10 (Whereupon. a short recess was taken.)

l 11 JUDGE BLOCH: Let the record show that it 's eight 12 after nine. We vill resume. With deep respect I welcome 13 you wholeheartedly to our session. Ms. Skolnik. l lO f

14 15 Wouid you iike 1e sex e werd eboet vour ietenees?

MS. SKOLNIK: Yes, I was going to start w!th that, l

j 16 I wonder if it might be possible to start the hearings at f E 17 9:30 just because I'm going to find it pretty impossible to j I. ,

18 get here by nine, by the time I get my children out to [

19 school.

20 I know half an hour would make a lot of dif ference j

, 21 for me.  !

02 JUDGE BLOCH: Ms. Skolnik, did you know that

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23 yesterday? l 24 MS. SKOl.NIK : I didn 't realize that it would be so 25 difficult to get here by 9:00, no.

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L 293 l JUDGE BLOCH: Let 's consider your motion at the

(]) 1 2 end of today. I 'm not cetisfied that that 's an adequate  ;

i 3 reason for you to be late.  !

4 You kept a lot of people waiting. But we 'll  :

I 5 continue. l l

6 Whereupon.

l 7 KERRY HARNER f I

8 KENNETH HOFSTETTER i i 9 having been previously duly sworn, were called as witnesses (

I 10 herein and were examined and testified as follows: i 11 CROSS EXAMINATION (RESUMED) I i

i 12 BY MS. SKOLNIK l l  !

13 Q Mr. Harner, the base case of table 2.2 represents j l () 14 the concentration of the water if the 40 percent of the 15 total content of the water is re-treated by the EPICOR SDS. f 1

16 But isn't it true that there's no table which j:

17 reflects the average concentration for the influent to the [

i 18 evaporator if the evaporator is used to decontaminate the 40  :

l 19 percent of water? l l

20 JUDGE BLOCH: Ms. Skolnik, could we go slower l I

21 because I don't understand all of the premises?

e 22 MS. SKOLNIK: Okay. j l

23 JUDGE BLOCH: Could we take a part of the  !

i 24 testimony and address it ? Is there a part of the testimony l 25 that you 're t alking about ?

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() i MS. SKOLNIX: Yes.

2 BY MS. SKOLNIK i 3 Q Page nina of your testimony. Mr. Harner. )

4 A (Harner) Okay.

S Q You -- the question directed to you by the 6 counsel, by Mr. Baxter was in reference to Table 2.2 of 7 NUREG-0683 8 And he had asked if that Table 2.2 reflected the i

9 maximum concentration of the water. i 10 Does that table reflect the maximum concentration l 1 .

of the water if the 40 percent of the water is not '

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12 decontaminated by EPICOR SDS. but rather. it is

. 13 decontaminated by the evaporator?

q () 14 A (Harner) No, If the 40 percent of the water has ,

15 not been processed through EPICOR then that table does not

]i 16 represent the maximum value. [

17 The table represents using the evaporator in a (

l 10 coupled mode with the vaporizer wnere the influent to the j i

19 evaporator would go through the evaporator and then  !

20 innediately go through the vapori=er to the atnosphere. l 21 When we would use the evaporator in another mode.

22 it would not be coupled to the vaporiser. j 23 So that any water that we would feed to it would f 24 go through the evaporator and then to a holding tank. not to 25 the vapori=er in which case this table would not app l y .-

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(]) i It 's what 16 known as a ciecoupled mode of 2 operation.

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3 MR. BAXTCR I think the record is confused. It j l

4 wouldn 't apply -- '

5 JUDGE BLOCH: Okay. You're asking her to ask 4 6 question.right now? i 7 MR. BAXTERr Well, I would object to the question.

8 I think there 's confusion as a result of the question. I  ;

I 9 didn't understand where they were talking about whether it }

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10 would apply when the influent goes back into the evaporator i 11 after batch cycle or simply applies going into the batch 12 cycle. Which did you mean?

13 JUDGE BLOCH: Maybe Ms. Skolnik can just clarify

() 14 that in a further question. Do you understand the problem?

10 MS. SKOLNIK No.

16 JUDGE BLOCH: What is the mode of operation of the 17 eveporator to which yyou 're ref erring?

18 MS. SKOLNIK I'm referring to the influent to the 19 evaporator at any point in time.

20 JUDGE BLOCH: Whether it 's operating in batch trode i

21 or whether it 's coupled to the --

22 MS. SKOLNIK: Okay. If it 's not coupled. If it*s 23 decoupled f rom the veporizer.

24 JUDGE BLOCH: Which means there 's not going to be 25 a release. If it 's decoupled. it 's not going to be released O Heritage Reporting Corporation (202) 628-4888

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to the atmosphere.

MS. SKOLNIX* Yes. But what I'm trying to 3 determine is whether or not the table represents the maximum 4 going into the evaporator. j l

5 JUDGE BLOCH: Which table now?  !

6 MS. Sr.0LNIX t PEIS. Table 2.2.  ;

7 JUDGE Bl.OCH: Page 0.3. PEIS. Supplement Two.

l 8 MS. WOODHEAD Mr. Chairman. I don't believe that 9 this witness is qualified to testify on the contents of the 10 PEIS since it 's not his document.

11 MS. SKOLNIK: However, the reason I'm using the {

12 PEIS because Mr. Harner's testimony refers to the --

13 JUDGE BLOCH: The objection is waived because the O 14 testimonx is in evieence end 11 wes not 083ected te ex Stef f .

15 as an improper question by Counsel.

16 So please continue. You want to know whether 2.2 1

17 shows the releases that would occur in a decoupled mode?

18 MS. SKOLNIX: No. not the releases.

19 JUDGE BLOCH: The input --

20 MS- SKOLNIK The 2 2 shows the radionuclide

! 21 concentration for the evaporator.

22 JUDGE BLOCH: Inf luent ?

23 MS. SKOLNIK: Influent and I 'm asking, does that l

f 24 table reflect the ir. fluent to the evaporator at all times?

25 JUDGE BLOCH: Can you answer that. Mr. Harner?

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297 1 THE WITNESS: (Harner) That table represents the

' 2 input to the evaporator when it is operatinh in a c.oupled j l

3 mode through the vaporizer.

I j 4 MS. SKOLNIK Okay.

l 5 BY MS. SKOLNIR:

6 Q In other words. it doeu not reflect the  !

i I l 7 concentration of the water which will not be pre-treated in l 8 the EPICOR SDS?

9 A (Harner) That 's t rue. Water that is not -- some

10 of the water that is not pre-treated through EPICOR would 11 have a dif ferent concentration than what is listed in Table 12 2.2 13 Q Ian 't that amount 40 percent which is over one O 14 mu uon eenone2 15 A (Harner) Yes.

l 16 Q in your statement on page 10. you say. "the final

! 17 co1 centration" -- line 11. "the final concentration in each 18 storage location af ter processing can be no greater than the 19 t rit ium influent concentration".

20 Isn 't it true that, that statement would be 21 incorrect if varicus tanks were mixed together? And that 22 indeed the tritium influent of one tenk. if mixed with 23 another tank, could be exceeded?

24 A (Harner) The statement is assuming that the 25 water, a batch of water is being processed and put into an Heritage Reporting Corporation (202) 628-4888

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l 2 It doesn 't say, being mixed eith other water.

I 3 It 's a statement saying that the influent tritium will be 4 the same concentration as the ef fluent tritium.

5 Q But the water will be mixed -- won't tanke of 6 water be mixed in order to make up the influent for the L 7 evaporator if the PWST-2 tank is being used to hold the 8 water which will go into the evaporator?

9 A (Herner) Not in this statement. In thin 10 statement that is made, it 's talking about going to a 11 storage location.

12 I t 's no t talking about -- it does not say being 13 mixed with other water in a storage location.

() 14 We 're talking about the evaporutor process itself 15 will not change the tritium concentration.

16 If the water is put into a tank that has other

, 17 water in it, then the resulting concentration would be a i

18 mixture of whatever tritium that went in plus the tritium 19 that was already there would come up with a new value.

20 I believe there are other places where that 's 21 explained, the mixing of the various sources.

22 Q So if there*s mixing of various sources. 1 sn 't it 23 true then that the base case reflects, does not reflect any 24 utorage location?

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t 1 storage locations, what exactly is the base case 2 representing? I I

3 MR. BAXTER: We 're talking about tritium now?

4 MS. SKOLNIK: Tritium. yes. You can talk about j 5 tritium.

f 6 JUDGE BLOCH: Ms. Skolnik, we would take notice [

7 that if you mix eny two locations, the resulting value is 8 going to be somewhere between the two of them. l 9 So they establish limits. I don 't see what the 10 problem is.

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1 11 MS. SKOLNIK: We l 1. the problem is that the base f 12 case is supposed to be establishing maximums. j i

13 JUDGE BLOCH: It 's going to. If you take tritium  !

O 14 mixtures from eny two iocesione end you mix them together, j 15 the resulting mixture is going to be between the l

1 16 concentrations of the two that were mixed. [

17 MS. SKOLNIK: But that's -- what I'm trying to J 18 point out is that, that concentration could be nore than the l t

19 concentration listed in the base case which is supposed to

{

20 be the maximum concentration in any storage location. f 21 JUDGE BLOCH: Is that true. Mr. Harner? Would it 22 be trore than the base case? Could we have an influent that 23 has more tritium than the base case? That 's 1 a first 24 question. )

l 25 THE WITNESS: (Harner) More tritium, yes.

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/" 1 JUDGE BLOCH: More tritium.

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2 THE WITNESS: (Harner) A single location may have 3 a higher level of tritium --

4 JUDGE BLOCH: Than the base case.

5 THE WITNESS: (Harner) Than the base case, than 6 the average.

1 7 JUDGE BLOCrP And wouid that make any dif ference l

j 8 in terne of the amount of tritium that 's released to the l l

9 atmosphere? I 10 THE WITNESS: CHarner) No. The calculations for j 11 the doses were done on total tritium released.  !

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12 JUDGE BLOCH: So some of the releases might be j r

! 13 more because there would be a higher concentration if you l

() .14 started with mixtures. Obviously others would be less?

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! 15 THE WITNESS: (Harner) Yes.  !

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l 16 BY MS. SKOLNIK: }

j 17 Q However, isn 't the release rate important because 18 it refers to your technical specifications which are set out i

19 in order to protect the people from a dose that might be 20 incurred over a certain period of time? [

21 A (Harner) It 's t rue, but the numbers are so very  !

I 22 low compared to our technical specifications that none of l 23 the storage locations that we have being released would come 24 close to violating the technical specifications even though 25 the tritium may be slightly higher than the base case

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l 2 The base case average is only a percentage of 3 those technical specification numbers. l l

4 JUDGE BLOCH: Mr. Harner. I take it there's i 1

5 nothing here that would waive your technical specifications l J J 6 on total release. is there?

l 7 THE WITNESS: (Harner) Pardon?

8 JUDGE BLOCH: There is nothing that would change  !

9 your corranitment on total release out of the regulations in {

10 this amendment. is there? f i

11 THE WITNESS: (Harner) No. The activity that we {

12 are talking about releasing through this evaporator process j 13 is well below our technical specification. j O 14 auwe BloCH: And inere is no cnenge in the f 15 technical specifications under this amendment, either? f f

16 THE WITNESS: (Harner) No.

17 BY MS. SK ')LN IK :

f 18 Q However, you did estimate the continuous release 19 rate based on the average concentration that was shown on f l 20 Table 2.2?  !

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21 A CHarner) Yes. To the best of my knowledge.

22 that'a the way it was done, yes. I did not do the l

23 calculations but I think that is the way it was done.

i 24 Q And you 're saying that even if the concentration 25 of tritium, of the influent to the evaporator was increased O Heritage Reporting Corporation

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by a factor of five, that it would not affect jour technical specifications?

3 A (Herner) I 'm not sure about the factor of five.  !

4 There are no tritium concentrations that are a f actor of i S five higher than the 1 1 E to the minus 1 i

l 6 We do not have any bodfes of water that are higher l l i 7 than that. l 8 Q But could a mixture of -- no. that's okay. Strike 9 that, please.

10 (Continued on the next page.)

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() 1 BY MS. SKOLNIX:

2 Q Do you know what the maximum of tritium would be 3 to stay within your technical specifications for a release 4 rate of. I believe it 's 570 microcuries per second?

5 A (Harner) No. I am not familiar with what that 6' number would be. But looking at the tritium concentrations 7 f rom Table 2-3 of our July 1986 proposal, those s 8 concentrations if you look at those, the highest 9 concentration is 3.0 E to the minus 1. which is just barely 10 a factor of 2 higher than the 1.3 E to the minus 1..

11 JUDGE BLOCH: Ms. Skolnik. I am not aware that 12 this is part of this hearing, as to whether they are 13 exceeding their maximum release rate. I don't reccll

() 14 anything that we declared to be a genuine issue about that.

15 nor anything that called it in question.

l 16 MS. SKOLNIK: Well. the dose from tritium is

! 17 called into question.

! 18 JUDGE BLOCH: But not whether their allowed l

19 release rate under the technical specifications is going to l

20 be exceeded. Nothing that you introduced suggests that.

21 WS. SKULNIK: I thought it was also important to l

22 leek at the base case and to see how much it represented the l

l 23 influent to the evaporato

  • because of the testirony that Mr.

l 24 Harner presented.

25 JUDCE BLOCH: If the influent from the evaporator l

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okay. But the technical specification limit has not been questioned.- It 's okay to ask ablJt the influent, but not to

ask about the technical specification, because that 's a new point.

6 BY MS. SKOLNIA:

7 Q Mr. Harner. I'm looking at Page 16 of your 8 testimony. You state on Line 18 that similar processing has 9 been given or will be given to the AGW. You are referring n

10 to EPICOR SDS. But isn't it true that 40 percent of the 11 water will not be processed to EPICOR SDS?

12 A (Harner) The remaining 60 percent has already

, 13 been processed by EPICOR SDS. That is the reasori why the 40

() 14 percent number is there, that it still needs to be 15 processed. The other 60 percent has already been processed 16 through SDS and/or EPICOR.

17 Q So the 40 percent that has not, will not be 19 processed by EPICOR SDS is presently used in the cleanup?

19 MR. BAXTER: Obj ect ion. He did not say there 's 40 20 percent that will not be processed. To the contrary. he 21 asid there is 40 percent that is yet to be processed and it 22 will be. That is misstating :he testimony.

23 JUDGE BLOLH That was the testimony. He said L i

24 that they will process the 40 percent. That they haven 't 25 yet but that they will. [

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2 Q And will they process it by EPICOR SDS?

3 JUDGE BLOCH: That 's what he said. Is that t 4 correct. Mr. Harner?

5 THE WITNESS: (Harner) It will be processed by 6 EPICOR-2 SDS is no longer in service.

7 BY MS. SKOLNIK 8 Q So whca the water comes out of the reactor vessel

9 arn the fuel tanks, this 40 percent. I was of the 10 understanding, am I wrong, that this water is going to go 11 straight into the evaporator in batch cycle?

12 A (Herner) The way the information was gathered for l

13 our July 1986 proposal, in there we state that 40 percent of

() 14 the water would be processed before _t wo."d be ready for 15 the evaporator. That 's where the nuthbers come f rom for 16 Table 2.2 in the PEIS as well as our table 2.7 I think it 17 is in the July 1986 proposal. When the water is processed 18 through EPICOR-2, it then has a lower radionuclide content i

19 except for tritium. That is the water that is then 20 represented as a base case for feeding to the evaporator.

21 JUDGE BLOCH
Mr. Harner, j ust to clarify, you
2. . said 40 percent would be processed throup,h EPICOR-2 Is 23 that corre;t? i 24 THE WITNESS: (Harner) It depends on what numbers 25 you are looking at. It 's 40 percent --

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1 JUDGE BLOCH: I'm not pinning it down on precisely 2 the percentage. But it 's roughly 40 percent?

3 THE WITNESS: (Harner) Between 30 and 40 percent.

4 JUDGE BLOCH: And the consequence of that is that 5 before you go to the evaporator, all of the water will have 6 been processed through one of the pre-treatment systems. Is 7 that correct? 60 percent is already processed. Is that 8 right?

9 THE WITNESS: (Harner) Yes. And depending on 10 what we need the water for, in the defueling process between 11 now and the time it 's being fed to the evaporator, some of 12 it will be processed many times. Others may not need to be 13 processed again. They are already low enough

()

14 concentrations. So it is not an exact thing. We have water 15 stored in many locations and it has many uses.

16 JUDGE BLOCH: But is it correct to say that all of 17 the water will have been processed at least once?

18 THE WITNESS: (Harner) Will have been processed.

19 JUDGE BLOCH: Before it goes to the evaporator?

20 THE WITNESS: (Harner) At least once before it 21 goes to the evaporator.

22 JUDGE BLOCH: Does that clarify the problem. Ms.

23 Skolnik?

24 MS. SKOLHIK: I 'm going to have to find the 25 reference to information UMut was given in previous GPU

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,()_ i- answers to interrogatories because it states in there that 2 the EPICOR SDS could be replaced by the evaporator as a 3 means of decontaminating the water. ,

4 THE WITNESS: (Harner) Could be, yes.

1 5 JUDGE BLOCH: The witness agrees, it could be.

6 BY MS. SKOLNIX:

1 7 Q Will it be?  ;

8 A (Harner) Pardon? ,-

t 9 JUDGE BLOCH: Will it be, is the question.

10 THE WITNESS: (Harner) I can 't answer that.

11 JUDGE BLOCH: Now, I don 't understand. I thought 12 you already answered it. You told me that all of the water 13 would be processed at least once, preprocessed. Now you say

() 14 you 're not sure if that 's true.

15 MR. BAXTER: The question was will it all be i

16 preprocessed by EPICOR. I think the witness is saying 17 there 's two ways of preprocessing. One is with EPICOR and 18 the other is with a closed cycle evaporation before you use

19 the vaporizer. That is considered preprocessing as well. I l

20 believe that 's his testimony.

21 JUDGE BLOCH
Mr. Horner, is that correct? Is i

22 that your understanding? Because that wasn 't what I think 23 you said to me a few moments ago.

24 THE WITNESS: (Horner) Those are the two methods 25 of preprocessing water before it reaches the concentrations Heritage Reporting Corporat ion (202) 628-4888

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(} 1 that are listed in the base case.

2 JUDGE BLOCH: Will any of the water to your 3 knowledge be processed solely by the evaporator without 4 EPICOR or SDS?

5 THE WITNESSt (Herner) To my "nowledge, I do not 6 know.

7 JUDGE BLOCH: The witness does not know.

8 MR. BAXTER: I think there is confusion. Judge 9 Bloch. I mann, the evaporator operates in two different 10 nodes.

11 JUDGE BLOCH: No, I do know that. But the witness 12 says he doesn't know if any of the water will be 13 preprocessed only by the evaporator, either in single

() 14 runthrough or batch mode. That 's what the witness said.

15 MS. SKOLNIK In Licensee 's answers to SVA. TMI A 's 16 second set of interrogatories, this was the basis for my 17 believing that the water, 40 percent of the water which is 1e now being used for cleanup would go into the evaporator so 19 that in effect the evaporator is not only a disposal unit.

20 it is also a decontamination unit.

21 JUDGE BLOCH: Okay. We have to ask questions of 22 witnesses. Your statement doesn 't do anything. There is an 23 answer there. This witness apparently isn't able to respond 24 to that.

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(). 1 BY MS. SKOLNIK:

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2 Q But then I don 't understand why. Mr. Harner, why

'3 in your testimony do you make the statement then that the 4- influent to the evaporator will-not exceed the meximum shown 5 in Table 2.2?

A 6 A (Harner) When the water is being released.

7 Q But the influent to the evaporator is the water 8 that'goes into the evaporator at any point in time. It 's not 9 juct the influent that 's going into the evaporator before it 10 goes to the vaporizer.

11 JUDGE BLOCH: Ms. Skolnik, may I ask? I think I 12 understand this. Maybe we can clarify it. Do you measure 13 the amount of tritium coming out of the evaporator before

() 14 it 's released into the atmosphere, before you take the step 15 of putting it through the --

16 THE WITNESS: (Harner) Yes, that can be done, 7 17 before you put it through the vaporizer. But it would be

, 18 the same as we analyzed the tritium before it went into the 19 evaporator.

20 JUDGE BLOCH
The tritium never is reduced. The 21 other stuff is reduced by putting it through multiple times 22 if necessary. Is that correct?

23 THE WITNESS: CHarner) R igh t .-

24 JUDGE BLOCH: So what is the problem, Ms. Skolnik.

< 25 about the tritium? The tritium doesn 't get reduced no i i  !

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( J-2 MS. SKOLNIK: Right.

3 THE WITNESS: (Harner) Or any other pretreatment 4 process.

5 MS. SKOLNIX: I thought it was important to 6 establish exactly what is going into the influent in the 7 evaporator.

8 JUDGE BLOCH: In terms of tritium.

9 MS. SKOLNIK: Perhaps it should be directed to the 10 person, the technician in charge of the evaporator.

11 JUDGE BLOCH: In terms of tritium, the influent is 12 the output. So just take that as given.

13- (Pause)

() 14 BY MS. SKOLNIX:

15 Q I have another question. Mr. Harner, concerning 16 carbon 14 Did you rely, in order to estimate the 17 concentration of carbon 14. which the NRC then used in Table r 18 2.2 in the EIS. from what samples of which tanks did you t 19 estimate the average?  ;

i l 20 A (Horner) The tanks and the results that were used l t

21 to estimate that average were from four samples token from i 22 processed water from the CCT-1 tanks. CCT-2. PST-2 and PWST- l 23 1. Those are all tanks that have had processing through 24 EPICOR-2, very representative of processed water. Those l 25 four samples and their carbon 14 results were the basis for j O Heritnge Reporting Corporation f (202) 628-4888 ,

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-() i the carbon 14 number of i E to the minus 4.

2 Q So you sampled four out of 25 locations to get an 3 average estimate for carbor 14?

4 A (Harner) Tweni five locations is not really ,

l 5 relevant here. The water that we're talking about going to  :

P 6 the evaporator is processed water which has a very low 7 concentration of nuclides. It 's not the same as the other 8 25 locations such as the reactor coolant system which has a 9 higher concentration of radionuclides. So we looked at the 10 samples that were representative of processed water which 11 would be headed for the evaporator, not water that 's located 12 in the plant performing defueling activities. L 13 Q But if you take an average of four tanks. 4 t 's not

() 14 the same as taking an average of 25 tanks.

1P; A (Harner) In this case it 's better because we 're 16 looking at processed water which is the final stage before 17 the evaporator. If we added in the other locations. it 18 would not be very representative.

19 Q However, in one of the tanks you did find, or 20 Westinghouse found that the concentration of carbon 14 was s 21 3.0 E to the minus 4 and yet, in spite -- that was one. ,

22 That was 25 percent of the tanks that you analyzed for 23 carbon 14 and reflected a higher value, and yet you chose to 24 select the lower value to reflect the total concentration of ,

i 25 tritium in the 2.3 million gallons of water. Is that i

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312 i correct?

( })

2 A (Harner) As we discussed yesterday, yes. It 's a 3 mathematical average of those numbers.

4 JUDGE BLOCH: Mr. Harner, what would be the 5 consequence if it actually was 3.0 E to the minus 4 instead 6 of the average?

7 THE WITNESS: (Harner) That single concentration, 8 as it -- just as we discussed with the tritium. i 9 JUDGE BLOCH: Suppose it was all that, as it  :

10 actually arrived, as input. What would happen?

11 THE WITNESS: (Harner) You would have to adjust 12 the dose calculations for that increase between the i E to 13 the minus 4 and the 3 E to the minus 4. From what I

() 14 understand of the dose calculations, that again is so very.

15 very small that difference would not, it would be 16 inconsequential.

17 BY MS. SKOLNIK:

18 Q If an average concentration of carbon 14 yields a k l 19 total of .176 curies of carbon 14 in the total accident- l l 20 generated water, the Westinghouse sample is going to show at i l

i 21 least, if that was present in all the other parts, it would  !

22 show like three times the curie contcnt of the average that 23 you are using. 1 sn 't it true that all the carbon 14 will be 24 released into the atmosphere?

25 A (Harner) During the evaporation process, all of l

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() i the carbon 14 will not be released into the atmosphere.

2 Carbon 14 that will be released ini.o the atmosphere is l 1

3 associated with CO-2, which is a gas. The other carbon 14 '

4 would be associated, tied up as a salt or as an organic l l

5 which would be lef t behind in the bottoms of the evaporator.

)

6 And in addition to that, one tank was 3 E to the minus 4.

7 Another tank was something E to the minus 5 If all of the  :

6 water were E to the minus 5. it would be much less than the 9 dose that was calculated.

10 Q However, all of the water is not E to the minus 5.

11- is it, because the Westinghouse sample showed that one tank i 12 was 3.0 E to the minus 4?

13 A (Harner) but there are three other Westinghouse

() 14 samples that also show that all the water is not 3 E to the 15 minus 4.

16 JUDGE BLOCH: I 'd like to ask. Mr. Harner. if you 17 would try to answer the question and then we won 't get into 18 a back and forth dialogue. You don 't have to def end other

19 portions of your testimony or explain it, because Mr. Baxter

)

4 20 can do other questions and I think if we just stick to the I

21 question we 'll go much f aster.

22 MR. BAXTER: I would ask. Judge Bloch, then, that 23 the questions be much less argumentative. [

[

24 JUPGE BLOCH: We con see if that will happen. My i

~

20 guess is it will happen that way.

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i BY MS. SKOLNIX: .

2 Q Mr. Harner, just one other question about the 3 tritium. Is it true that you are saying that all the 4 tritium that is left in Unit 2 is in the water?

5 A CHarner) Yes.

6 Q Did your samples of fuel and core bore f rom th 7 walls in Unit 2 show that there was no tritium in the core 8 in the walls or in i.ne fuel?

9 A (Hofstetter) I think that what we have seen is 10 that in the water that encompasses the core sampling, as I 11 testified yesterday, there 's been no increases in the 12 tritium which would indicate that releases were continuing 13 from the fuel.

() 14 A (Harner) A tritium analysis is not done on a 15 solid sample, 16 Q How would you find out then if there was tritium 17 in the fuel? I 'm sorry. I didn 't quite understand what Mr.

18 Hofstetter said.

19 A (Harner) He said that they didn 't measure any 20 increase in the samples they took after they had been 21 workind the core. That was the testirrony yesterday evening.

22 Q By what method do you look for tritium in those 23 anmples?

24 JUDGE BLOCH: I 'm sorry. You 're now asking how 25 they'look for tritium in the samples they take? Because we O Heritage Reporting Corporation (202) 628-4888

315 talked about the samples nuite a bit yesterday.

({J 1 2 MS. SKOLNIK: Yes. And I didn 't ask that 3 question.

4 JUDGE BLOCH: That 's correct.

5 THE WITNESS: (Hofstetter) My statements were 6 that of' course as we had not seen any tritium increases in a 7 the water, in the reactor coolant system, as a result of the 8 defueling operations, making a measurement and assaying of 9 the tritium in a core debris sample. I 'm not sure that 10 those analyses were performed. I'm not aware of any analyses 11 that were performed after the sample was removed from the 12 core, dried out and then taken to a laboratory for 13 examination. I'd be very suspect that you would see

() 14 anything just because of the drying out process, that any 15 water associated with those samples would have been gone.

16 We are relying on the fact that we can measure the tritium 17 increases or changes in the tritium concentration in the 18 reactor coolant as these activities are going on.

19 JUDGE BLOCH: So how do you do that?

20 THE WITNESS: CHofstetter) By collecting the 21 samples as Mr. Harner said yesterday on a frequent basis and 22 measuring those samples for tritium concentration. l 23 JUDGE BLOCH: Do you really want to go into the f 24 details of how you measure the tritium?

~

25 MS. SKOLNIK: Well. I think -- no. I think I 've ;

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316 made the point that it 's impossible to actually measure for

-( ) i 2 tritium in the fuel and the concrete. Or perhaps it 's 3 possible, but it 's not done.

4 BY MS. SKOLNIK:

5 Q Is that true?

6 A (Hofstetter) No, i t 's no t . Because I think that 7 the point I 'm trying to say, that I 'm trying to make is that 8 the technique we used for measuring the amount of tritium in 9 these solid samples would be to look at the tritium in the 10 water which is in intimate contact with these samples, at 11 various times throughout the various operations. And that 's 12 the way we would measure the actual quantity of tritium that 13 might be released from these solids. A leaching type of a

() 14 measurenent, if you will.

15 JUDGE BLOCH: So the daily measurements that are 16 made of the water would indicate whether there was tritium 17 released from the core?

18 MS. SKOLNIK: Yes.

19 BY MS. SKOLNIK:

20 Q So your techniques will measure the tritium as 21 it 's released into the water at this time --

22 JUDGE BLOCH: Wait. The witness indicated yes by

23 nodding his head.

24 THE WITNESS: (Hofstetter) Yes.

25 MS. SKOLNIK: Oh. Yes.

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({';_ i JUDGE BLOCH: The record has to show that, or you 2 can 't use it, you see.

3 MS. SKOLNIK: Oh. Okay.

^4 BY MS. SKOLNIX:

5 Q So is it true then that since cleanup of the walls 6 and'the defueling will continue and the walls must be 7 cleaned by flushing with the accident-generated water. 1sn 't 8 it possible that there could still be tritium in the fuel or 9 the wallu which could in the next year be released into the

.10 accident-generated water?

11 A (Hofstetter) You are asking again a hypothetical

. 12 question that the scientist in me says I can't answer, that ,

13 it 's impossible, but it 's extremely improbable.  ;

() 14 JUDGE BLOCH: I think that 's also redundant from  ;

15 yesterday. We could check the record but I believe you 16 asked exactly that question yesterday. And you got the same 17 answer.

18 MS. SKOLNIK Did I? I don 't remeniber getting r

19 that answer. j 20 JUDGE BLOCH: It is possible, f

End 1721 (Continued on the next page.) l 22 [

23  ;

24 25

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-318 BY MS. SKOLNIK:

.( ) i 2 Q So if it is possible the total amount of tritium 3 which you state is 1.020 could change could be increased by 4 further decontamination activities at Unit 2?

5 A '(Hofstetter) Improbable is still the word I would 6 use because of our past history of over the last nine years  ;

7 and all of the aggressive defueling. scrabbling techniques 8 and decontamination methods and we haven't seen any 9 increases to date.

10 Q But it 's true to that some of the decontamination 11 activities have not yet been undertaken?

12 A (Hofstetter) Certainly there*c work to be done.

13 Q Yes, and new work that has to be done that has not

{

() 14 been done in the past?

15 A (Hofstetter) Well. certainly there 's things that 16 remain to be done and therefore there 's new work to be done.

17 Q And isn 't it indeed true that the work is so new 18 that you 're still developing the program?

19 A (Hofstetter) There is constant development on 20 defueling methods, certainly.

21 But I don't anticipate they 're to be much more

, 22 aggressive than the techniques that we have tried already to i

23 date.

24 Q Why do you say that. Mr. Hofstetter?

25 A (Hofstetter) Well. I think that the plasma arc.

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[() i underwater plasma arc torch cutting is a very aggressive 2 technique for cutting metals underwater which involves very 3 high temperatures, very high localized conditions which 4 certainly are chemically and physically disturbing to the 5 system.

6 Q However, the plasma are torch is strictly in the 7 reactor vessel?

8 A (Hofstetter) Yes. That 's correct.

9 Q So those conditions are only conditions within the 10 reactor vessel? Don't you have other decontamination 11 techniques for other areas which could perhaps -- if the 12 conditions are completely dif ferent ?

14 A (Harner) The decontamination activities that are

() 14 done other places do not come in contact with the type of 15 fuel and the type of debris that is in the reactor vessel.

16 So it 's two completely dif ferent scenarios about 17 what you 're -- the line of questioning you 're asking.

18 Q But there could be tritium in the other areas?

19 JUDGE BLOCH: Ms. Skolnik, is there a specific 20 area you would like to ask about? Obviously there could be 21 anything anywhere. Is there a particular --

22 MS. SKOLNIK: Right. Okay. Well, let 's look at 23 the reactor building basement.

24 BY MS. " 'OLN IX :

25 Q That could require techniques to decontaminate it O Heritage Reporting Corporation (202) 628-4888

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'J(~\ 1 which have not yet been developed?

%)

2 'A (Hofstetter) Yes, but you have to look at the i 3 source of where the tritium came from.in the reactor 4 building basement, the leaking pressurizer during the .

5 accident, coolant escaping, tritium being in the form of 6 water. .

7 So the tritiated water being very mobile and as t

8 Mr. Harner testified yesterday, very -- mixing very quickly 9 with the liquid that 's in the bottom of the reactor building ;

10 basement presents a pretty uniform system which we don't 11 anticipate any strange chemical phenomena associated with i

12 water in the reactor building basement.

13 So I think the answer there is, it 's even less t

() 14 likely that anything would occur in the reactor building 15 basement due to the source.

16 Q However. is it true that the water did penetrate 17 the concrete? ,

18 A (Hofstetter) Certainly.

19 Q So the concrete is contaminated?

20 A (Hofstetter) Certainly. I 21 4 With all radionuclides? l 22 A (Hofstetter) Yes. l 23 Q And there will be flushing and other  ;

24 decontamination techniquen used in the basement?

25 A (Hofstetter) There already has been, yes.

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1 Q So isn't it possible that tritium could be

' - (])

2 released f rom the basement? From the concrete, from the 3 various decontamination techniques which you 've still to  ;

4 undertake?

5 A (Hofstetter) Tritium is like as we 've said ,

6 before, tritiated water is like ordinary water. It dries 7 out and consequently goes into the atmosphere. It soaks 8 into pores. It moves back and forth and exchanges with the 9 various components that are in the basement.

10 And consequent ly I wouldn 't. anticipate. I don 't --

11 it would not be any different than normal water, i t 's 12 chemical properties interacting with the material 's 13 construction.

() 14 A (Harner) One additional point, the amount of 15 water that's located in walls or whatever you 're theorizing I' 16 that it 's soaked into, is very, very small compared to the

17 bulk water that is in the reactor building basement.

i 18 So the amount of tritium that would be located in 19 there would be the same concentration as in the basement i 20 water which we know.

! 21 And it 's a very, very small amount.

22 Q But it would --

23 A (Harner) It would not account very much at all.

4 24 Q Okay. But it 's an addition to the total tritium 25 content. isn 't that correct?

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(). 1 A~ (Harner) A very minute addition.

2 Q Okay. So yesterday we had a ministe addition from t

-t 3 the river intake. We have another minute addition from the 4 errors that it 's made in the sampling and now we have 5 another minute addition from the wall?

6 I mean it does add up. I think --

7 MR. BAXTER: Can we have a question, please?

8 BY MS. SKOLNIX:

9 Q Doesn 't it add up?

i 10 JUDGE BLOCH: Can you place any bounds on the 11 total amount of minute addition? ,

12 THE WITNESS: (Hofstetter) Well, I think that the 13 question is such that we 're looking at, if you look at the

() 14 table in back of our testimony, you 'll see that we estimate 15 that the concentration or the total quantity of tritium in 16 the reactor building basement is 3.5 curies.

17 So we 're looking at a source which is relatively 18 cmall to the 1,020 to begin with.

19 The additional tritium that is bound up in the 20 water that is in the basement that might have soaked into 21 the walls would depend, the concentration will be the same 22 as what 's in the reactor building basement water itself.

23 The addition will be the volute that we 're talking 24 about, the volume addition, the concentration will be the 25 same.

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() i But the volume addition. relative to the 43,000 2 gallons that we estimate is down in the basement, there will 3 be a small amount due to the volume of water in the pores of 4' the concrete or whatever, holding it back.

5 So it 's a very small quantity. And I 'd hate to 6 estimate it, but micro-curies come to mind at the most.

7 So now we 're looking at micro-curies, one l 8 millionth of a curie compared to the total inventory of 3 or 9 3. 5 curies that 's down there.

10 BY MS. SKOLNIK:

4 11 Q However. Mr. Hofstetter. isn 't it true that if you 12 didn 't take samples of the concrete, you do not know the 13 total amount of tritium in the concrete walls of the

() 14 basement ?

! 15 MR. BAXTER: Mr. Chairman, at this point this

! 16 question has been asked and answered several times. I 1

!, 17 obj ect to the repetitiousness.

. 18 JUDGE BLOCH: I sustain the obj ection. It has

] 19 been asked and answered.

l 20 MS. SKOLNIK: I 'm corry. I can 't hear, i 21 JUDGE BLOCH: It has been asked and answered. He I"

22 already said that they don 't know specifically how much 3

g 23 there is in the basement walls.

i 24 He 's given you reasons to believe it 's small, but 25 they haven 't measured the enount s of the basement walls.

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324 Sec. once you get your-answer you can use it in

( ). 1 i 2 your findings. What you say here doesn't matter. The only 3 thing that matters is the testimony.

4 Ms. Skolnik. I 'd like to clarify that. I want to 5 make it clear beCSJse when you file findings, you'll be  !

6 filing findings about what the witr. esses have said. .

i 7 You 're not even permitted to state what you said.

8 The only thing that matters is the answers. Do you  !

, 9 understand that?

10 So making a debating point doesn 't af fect the -

11 findings at all. f i

12 BY MS. SKOLNIX:

13 Q One other question I think, on page 19, Table 1 L

() 14 We talked yesterday about the sample points for the reactor 15 vessel and the basement.

1 16 Does each of the tanks listed here have more than 17 one sample point?

! 18 A CHarner) No. the maj ority of the tanks listed .

l 19 have a single sample point located usually on the  ;

20 recirculation line as it mixes the tank.

! 21 G Could you identify the ones that have nere then l 1

i 22 one since those are the least placed?

t 23 A (Harner) Those that have more than one?  !

l 24 Q Yes. More than one sample point. [

4 25 A (Harner) The reactor coolant system and spent I

1

(~)

\/

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l 325 1 fuel pool B. The reactor building basement can have more

(}

2 than one sample point, spent fuel pool A, deep end to the 3 transfer canal.

4 MS. SKOLNIK: That concludes my cross examination 5 of these two witnesses. Thank you.

6 JUDGE BLOCH: Thank you. Ms. Skolnik.

7 MR. STEPHEN LEWIS: The Staff has none.

8 JUDGE BLOCH: Mr. Baxter, redirect? t 9 MR. BAXTER: If the Board has no questions at this 10 time. I'd like to have a 10 minute recess before redirect.

I 11 but I 'd welcome the Board.

l 12 JUDGE BLOCH: The Board has no questions.

13 MR. BAXTER: Could we have a 10 minute break I

() 14 before redirect?  !

t i 15 JUDGE BLOCH: Yes. let 's take a 10 minute break.

i 16 It 's now 10 o ' clock. We 'll be back at 10:10 precisely, t

17 10:10 we 'll be back in session.

18 (Whereupon, a short recess was taken.)

19 JUDGE BLOCH: It's now 10:10 Mr. Baxter.

l 20 REDIRECT EXAMINATION f

I 21 BY MR. BAXTER:

22 Q Gentlemen. I 'm going to work backwards f rom i l

23 today 's examination. l 24 Mr. Buchanan is really going to be the witness who 25 can address the operation of the evaporator in detail but O HeritaEe Reporting Corporation (202) 628-4888

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} 1 let 's return for j ust a moment to Table 2.2 in PEIS 2 Supplement Number 2.

3 The base case, the achievable, you know, the base 4 case concentrations for the influent there. Would you 5 relate that, Mr. Harner, to the operation of the disposal 6 system in the batch cycle mode?

l 7 A (Herner) When the evaporator is operated in the 8 batch cycle. there is no release to the environment.

9 It would go from a cource tank, through the 10 evaporator. The distilic would go to a storage tank. The bottoms would remain to waste solidification, whatever the I 11 12 waste disposal is.

13 So that these number listed in Table 2.2 only l

O 14 erg 1x to the weier tnet e seine into the evegeretor emd then i 15 immediately through the vaporizer and released to the

, 16 atmosphere. ,,

1 l 17 Q The water that you just discussed that is (

18 processed through the evaporator in closed cycle batch mode 19 is sent to a holding tank. What happens to it then. i t 's  ;

20 ultimate disposition?

(

21 A (Herner) Once it 's in the holding tank, we can  :

i

! take a look at it and recirculate it, analyze it.

22 l

! 23 If it then meets these numbers 2.2. base case i 24 water, it would then be good enough to go through the .

t 20 vaporizer and be discharged.  ;

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() -1' If it does not meet the criteria listed, it could 2 then be reprocessed through the evaporator again until.it 3 does meet the requirements of that table.

4 Q Thank you. This morning Judge Bloch asked you a i

5 question that you may have misunderstood.

6 We were talking about the carbon 14 value of 3-E 7 to the minus 1 measured by Westinghouse. E to the minus 4.

8 I 'm sorry, carbon 14 value.

9 And he asked if that were the measurement for 10 carbon 14 when you were ready to process influent to the it evaporator, what would you do?

12 I believe I heard you answer, you would 13 recalculate the doses, is that correct?

() 14 A (Harner) No, if when we were operating 15 evaporotor, if we would end up with a tank that did not meet 16 the criteria for carbon 14 in that particular tank. then it 17 would have to be processed through the evaporator in a batch 18 mode to lowe that concentration down to 1-E to the minus 4 19 that is listed in base case table.

20 Q v er,terday. gentlemen, there was some examination 21 about the notice of violation issued to GPU Nuclear on the 22 strontium 90 betes trometry calibration error.

23 Who identified that error?

24 A (Harner) GPU Nuclear found the error and 25 identified it to the NRC.

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() 1 Q Did the error apply to liquid samples?

2 .A (Harner) No.

3 Q What was the scope of the incorrect waste 4 classification which resulted from the error?

5 A (Harner) Once we found the error, we tried to 6 determine what analyses that we did and what they were used 7 for.

8 And we found that they were used for solid waste 9 disposal calculations.

10 We then went back and reanalyzed the calculations 11 for the wastes that were shipped offsite. By doubling the 12 number we had been low by a factor of one-half of the true 13 value.

() 14 So we then doubled the number and reren the 15 calculation and we found that out of over 1,000 drums of 16 solid waste that we had shipped, we found two that were 17 misidentified.

I 18 Did the tJRC notice of violation apply to the Q

19 procedure or to the drums?

j 20 A CHarner) The violation sce on shipping those two 21 drums with a misrepresentation of the a.nount of activity 22 that was in them.

23 Q And has the company 's corrective action

24 subsequently been reviewed by the NRC?

25 A (Harner) Yes, we through a process, on internal I

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() i process of reviewing our procedure. he then went outside 2 and got a set of consultants from Oak Ridge National 3 Laboratory.

4 They came in, reviewed all of our radiochemistry 5 instrumentation, our procedures, our method, interviewed our 6 technicians, went over our training program.

7 They came out with a report which had a number of 8 recommendations. What the recommendations basically were to 9 improve our procedure since the error was in a procedure, to 10 make our procedures mores specific.

1 11 They did not .ind any discrepancy with the method 12 itself or any of our other methods for analyzing tritium 13 strontium 90 or any of the other radionuclides we looked

.() 14 for.

) 15 We then made those corrections, improved our i

.; 16 program and subsequent to our improvement we were evaluated 17 by an NRC inspection and found that we had instituted the 1

l 18 recommendations and had improved our program and found 19 acceptable.

20 Q Yesterday, Ms. Skolnik asked you about background 21 levels of tritium in the Susgaehanaa River and --

22 JUDGE Bl.0CH: Let 's otop for just a second. I 1

i 23 want to go back to the carbon 14 just briefly. Is the 24 amount of carbon 14 in the influent to the evaporator 25 measured each time?

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() i THE WITNESS: (Harner) It 's going to be 2 evaluated, measured before we start feeding a batch of water 3 through the evaporator.

4 JUDGE BLOCH: And at what point would you decide 5 that you had to run it throt*dh the evaporator more than l 6 once?

7 Is there already a limit placed on the limit on l 8 the amount that you have to go back and place through the  !

9 evaporator more than once?

I 10 THE WITNESS: CHarner) The limit is the base case [

11 water listed in Table 2 2 of PEIS Supplement.

12 JUDGE BLOCH: So if it is higher than that at all.

13 you have to run it through the evaporator more than once? [

() 14 THE WITNESS: (Harner) If it is higher than that 15 we have to run it through the evaporator in a batch mode.

16 It would have to be more than once. -

17 JUDGE BLOCH: Thank you.

I

' t 18 BY MR. BAXTER: ,

19 Q Or through some other pretreatment mechanism? i

)!

i 20 A (Harner) Yes, that 's also a possibility.

l t ,

21 JUDGE PARIS: I 've got a question. Did you say ,

! 22 there was no error in regard to the strontium 90 problem? E 23 There was no error in the procedure itself? {

24 THE WITNESS: (Harner) Right. The method van f 25 found to be correct. The wording --  ;

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331 JUDGE PARIS:

l( ) i But the error was in the 2 instructions you were giving your technicians?

3 THE WITNESS: (Harner) The wording in the 4 procedure and misinterpretation of that wording.

5 JUDGE PARIS: Okay. Thank you.

6 BY MR. BAXTER:

7 Q Yesterday Ms. Skolnik asked you about the 8 background levels of tritium in the Susquehanna hiver and  !

m l 9 you indicated you didn't know a precise number. )

10 But it was your understanding that they were in .i i the picoeurie level. Do you have more information on that 12 today?

13 A (Harner) Yes. I checked with the environmental  ;

() 14 people that run the analysis on the river frequently.

15 And it 's in the range of 100 to 200 picoeuries per <

16 liter background tritium in the Susquehanna River. .

17 JUDGE BLOCH: Who are these people?  !

18 THE WITNESS: CHarner) We have an environmental 19 Eroup that works through GPU Nuclear. g 20 JUDGE BLOCt: Thank you. i 21 THE WITNESS: C Har.1e r ) Okay.

22 BY MR. BAXTER: t t

l 23 Q On the bot to.n of page 14 of your testimony.

l 24 gentlemen, there was a eross examination yesterday about a l

l 25 comparison of the GPUN and RESL data for strontium 90 in the (

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( 1 PWST-2 sample.

2 And you discussed yesterday orally and there on 3 that page, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and rapid methods used by GPU l

4 Nut ear.

5 My recol1ection of the testimony yesterday is that 6 at times you spoke of an error band around the number and 7 about errors of plus or minus.

8 Would you clarify for us what direction these 100 9 percent and.40 percent error lies in for these two methods?  !

10 A (Harner) The meth')d. a3 we t.ated ear 1er. Is not j 11 an exact method. There is an error aesoci.'od with it.

12 Through quality control samples that we do, we are And what 13 able to see what the method is capable of doing.

O 14 we have found to thet our revid methee is coneisteativ too ,

15 percent on the positive. ,

16 The numbers are always overestimated. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ,

t 17 method we have found is consistently on the high side also  !

i 18 by 40 percent.

19 JUDGE BLOCH: Let me ark. If they 're se i 20 consistent, why don't you j ust consider that it 's half the 21 amount that you measure? f 1

22 THE WITNESS: HJfstetter) I think that the  :

23 intent of the procedure of course in to make the i f

24 measurements in a relatively rapid turnaround time. l 25 Mr. Harner testified yesterday. he normal i

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333 1 procedure is 14 days which is not really acceptable for a l (]J l 2 processed control sample.

3 But there are interferences. And the relative or 4 the average bias, if you will, of a 100 percent and 40 l 5 percent in the methods are based on quality control semples 6 which are relatively pure samples.

7 Interference is in the method naturally incurring 8 radioactivity and what have you would also, in a real l 9 sample, would also interfere.

10 And consequently we 've chosen not to remove that 11 bias on the side of conservatism. That there are situations 12 and there are certain interferences which in fact if we l 13 would renove the conservatism based upon these quality

() 14 control samples, would give us an erroneously low result of 15 strontium 90.

16 JUDGE BLOCH: So it 's not consistently 100 percent 17 nore than the amount of strontium 90?

18 THE WITNESS: (Harner) We cannot guarantee thet 19 it 's always 100 percent. That 's right.

20 JUDGE BLOCH: If I do understand though, you 've 21 established through the tests what the maximum strontium 90 22 would be.

23 And it could be as much as half of that?

24 THE WITNESS: (Hofstetter) That is correct.

25 JUDGE BLOCH: What was half of that ?

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(~) 1 THE WITNESS: (Hofstetter) For the rapid method s-2 and 40 percent for the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

3 JUDGE BLOCH: Is the overstatement for the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 4 method 40 percent or is the amount that could be. 40 5 percent?

6 T.32 WITNESE: (Harner) The result that we report 7 is 40 percent higher than the actual.

8 BY MR. BAXTER:

9 Q Yesterday Ms. Skolnik was asking you about the 10 dates of the various measurements taken on Table 1 of your 11 testimony. the tritium source terms.

12 Actually the testimony was that there were some 13 samples made in 1983 and 1985.

() 14 I have put on the table of all of the counsel and 15 the Board members and provided the court reporter with a 16 copy of a page labeled. Table 2-4 TMI-2 Processed Water 17 Source Terms. It 's page 13 of the July, 1986 proposal.

18 Does the column labeled date there --

19 JUDGE BLOCH: Before you proceed I 'd like to ask 20 that it be bound in as an exhibit but not as evidence. just 21 for reference purposes. Would that be appropriate?

22 MR. BAXTER: After I had established what it was.

23 I was going to move its admission into evidence.

24 JUDGE BLOCH: As evidence. Let 's continue then.

25 BY MR. BAXTER:

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() 1 Q Is the column under, date, represent the dates 2 that various samples were taken reported on Table 1 of your.

3 testimony?

4 A (Harner) Yes, those are the dates of the samples 5 of the analysis report.

6 MR. BAXTER: For completeness. Mr. Chairman.

7 rather than just having partial information in the record. I 8 would nove that this table be incorporated into the 9 transcript and received into evidence.

10 JUDGE BLOCH: Any obj ections?

11 MS. SKOLNIK: No.

12 JUDGE BLOCH: There being none, then the table 13 shall be bound in and receive the next page number.

() 14 (TMI-2 Processed Water Source s

15 Terns was received and 16 inserted into the record and 17 follows:)

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o o TABLE 2-4 Tr11-2 PROCESSED WATER SOURCE TERrts .

-- = ACTUAL SOURCE TER15 * *

  • 10'AL RADICACTIV:IY 1

Vaur1E H-3 Sr-90 Cs-137 Cs-134 Sb-125 Co-60 l GALLONS DATE Cl Cl Cs Cg (e (l TAME DESCRIPTIO6 AIACTS COG.AflT SYSTEtt 67.206 3/7/86 3.06E*01 4 58E*02 6.6X+0 8 8 00E+00 917E+00 2.39t+00 l RCS l

PWST-1 PROCESSED WATER STORAGE 109.068. 2/22/06 1.24 02 6AIE-03 2 8tE-03 I

P90CESMDWATER STORAGE 400.834 2/24/06 5,09t+02 9 AX-02 8.00E-03 PWST-2 CGSENSATE STGRAE 101.586 3/3/86 2.15E *01 6.9X-02 8.69E-03 CO-T-IA 5.610 4/12/63 2.76E+00 5.4eE-04 2.00E-04 2 00E-05 1.9 IE-05 WDL-T-9A EVAP.COS. TEST TAlet (VAP.Cee.1EST TAlet 2.231 4/87/83 1.10E*00 7.4X-04 42X-05 2 96E-06 WOL-T-98 EPICORilWF-SPEC 20.500 3/5/86 1.0lt+0! 450E-02 1.40E-02 3 88(-04 3.00E-03

) CC-T-3 EPICS tlCLEAll 16.867 81/15/85 5 6X+00 1.9X-02 9 59E-03 7 OX-03 4 ISE-04 CC-T-2 SFP-0 SPENT FLEL POlX. T 241.690 3/2/86 4.lM *01 3.0X-02 3.29E-03 i

SD5 elecim 373 3/7/06 1.0M-0 8 7.4eE-03 13dE-03 93Nd4 505-T-IA 1.77E-03 1.30E-04 505-T-IS 9 5 flGIIT Gt 497 10/10/85 1.3M-01 IDX-43 1.0lE-03 RC ELEEDielMRP 3.810 2/24/06 1.2X+00 4.7tE-41 1.34-03 3 89E-04 6 6K-03 1.30E-03 WOL-T-IA l

WOL-T-It RC SLEED DIEStp 4.420 3/7/06 2.lM+00 2A4+0s 3.35E+00 9.37f-02 5 69E-03 3.80E-01 57.116 10/31/85 34eE+01 5.40E+02 3 eeE*01 8.75E*01 148E*00 WOL-T-IC RC asselectair 458.915 3/4/06 8.15E+02 640E-Ol 2 26E-08 155E-02 4 69E-03 SWST SGIATEDWATER STGIAE IEU15tALest SA75 2/28/86 2.9eE+0e 4AeE+00 6.24+00 1.74-01 het-T-0A WDL-T-OS IGf1RAList 8A05 3/l/06 2.28t+00 258E+00 Se6E.00 1.7X-O f '

9A9E-01 1. lee +00 2JO00 6 88E-02 i

WOL-T-2 fir $CRIAIECUS WASTEIIR$UP 3.712 2/28/06 WDL-T-IIA CCIITArelt41ED SRA#t5 3.933 3/l/96 1.5X-04 1.9X-04 3.0X-04 6 80E-06 820 3/s/36 435E-05 3.4 K 415 WOL-T-lis CollTAfsleATED BRASES 1Aeo 3/2/06 2.86E-08 6.90E-03 5 ACE-03 2.86E-02 5 OX-05 f DErlC11Afteteelse SurP

} AssasAfly gLSS Stes 5.917 80/4/55 2.9K+0e 2A9E+00 5.IE-08 l 8EACTGt SLDSSAmteet 43Ae2 4/26te5 4.24+00 2AIE+02 7.99E*02

$rp-A $fBIIflEL7012.*A* 205.234 2/27/06 2 02E+02 2.4EE+01 634+00 186E-01 2.0X+00 t 94-0I ,

ottp flew 11tAfGFERCAllAL 58A85 3/12/06 6A6t+0s 5.7K+00 1.9 E.00 4 89(-02 6.44-0 8 555E-02 ,

[

t f.908.417 8882.75 .1331.17 929.49 l TOTAL ASOF 3/I/86 t

a 13 i

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r 337 BY MR. BAXTER:

({} 1 2 Q Now, Mr Harner, for those cases where samples were 3 taken in 1983 and 1985, why weren't samples taken at a later 4 point in time closer to the July. 1986 report?

S A (Harner) As we have discussed at various times l 6 the wtter in these locations is not in continuous use.

7 At certain times we 're using the tanks for a L

8 particular job that 's going on in the defueling process and 9 then that tank may no longer be needed for quite some time. )

10 That 's the case for the evaporator -- test tanks.

11 They were in use in 1983 for some job. I do not know -

12 exactly which job they were in use for.

13 The water that remained in there was just sitting

() 14 there and we then no lenger used those tanks.

l 15 So the data, the latest data that we had for the 1 r

16 water contained in there was 1983 Still'the same water and  ;

still the same analyses with nothing done to it between 1983  ;

17 18 and 1986 ,

19 Q There has been a lot of examination yesterday and  ;

20 this morning about potential minute uncertainties in the  ;

e 21 tritium source term. l 22 Your testimor.y telks about a conservatism in that [

23 you haven't take a count of evaporative losses.

t 24 Could you give the Board some quantitative sense  :

25 of what that conservatism represents?

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() i A (Harner) We have, we analyzed the air that leaves 2 the station. Those analyses analyze it for tritium. Those l 3 tritium numbers are then reported, tritium release numbers j 4 are then reported through the Nuclear Regulatory Commission 5 as releeses from the station.  !

6 The data that has been collected on a historical l

'i 7 basis from 1979 through 1986 which was reported in our July, 8 '86 proposal shows that except for the first two quarters of  ;

'l 9 1980 where we were doiqg specific processes, there was an  !

10 average of about 12.5 curies of tritium released per 11 quarter, per three months of each year. [

12 So that is an estimate of the amount of tritium 13 that 's being released through evaporative losses over time. }

() 14 JUDGE BLOCH: And how is that number derived?

i 15 THE WITNESS: CHarner) It 's to a station, what we j l 16 call a station vent. The air cones into this station and it  ;

17 all leaves at the same place.

('

18 It has a radiction monitor on it where we can take 19 local samples and do tritium analyses and per technical [

20 specifications, we have to do that.

, 21 And those are the numbers then that we use to f I I 22 generate a calculation of the amount of tritium released [

t 23 from the station.

24 JUDGE BLOCH: Then it 's an average of 12 5 curies  !

i 25 per quarter? (

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c& .e 339 i THE WITNESS: (Harner) The data that 's on the lVl 2 table, yes. averages about 12.5 per quarter.

3 JUDGE BLOCH: And is that fairly stable or does it 4 fluctuate quarter to quarter quite a bit?

w 5 THE WITNESSs (Harner) It fluctuates. That 's an 6 average. Again it would be connected to weather conditions.

7 Whether it was humid would affect the evaporation  !

l 8 rate.

9 (Continued on the next page. )

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b, 340 i MR. BAXTER: That's all I have.

2 JUDGE BLOCH: Ms. Skolnik?

3 MS. SKOLNIr.: Yes. i 4 RECROSS EXAMINATION 5 BY MS. Sr.0LNIX:  !

6 Q Mr. Harner, you were talking about the carbon 14  ;

f 7 and that you would analyze the influent to see how much

-8 carbon 14 was in a particular batch of water. How long 9 would it take for that analysis to be done and will you 10 specifically look for carbon 147 .

11 A (Harner) Carbon 14 is a specific analysis. It 's 12 not combined with any other analysis. And the method would i t

13 take I think approximately a day to do the chemical l O 14 segeretion in ine ceue11na.  !

15 Q You can do that analysis on site?

16 A (Harner) Yes. We are gearing up to do that l 17 analysis on site.  ;

18 Q You mean the --

19 A (Harner) Today we cannot do that analysis on  ;

20 site.  !

21 Q Okay. You already have that in your plan to put  !

l 22 carbon 14 analysis facilities or instrumentation in your l

23 laborat ory ?

i 24 A (Harner) It uses the same instrumentation we ,.

25 already have. It uses a liquid sintillation counter which  !

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() i is the same instrument that you use for doing tritium.

2 Q So you just don't have the procedure? r i

3 A (Harner) Right. i 4 Q When you are talking about the tanks, and some of ,

5 them, the samples were taken back in 1983, could you clarify 6 for me. are different tanks used for specific ,

7 decontamination purposes. In other words, the evaporation 8 condenser test tank. is that always used for the same 9 purposes? Does it contain water only from certain  !

10 decontamination activities?

11 A (Harner) It normally contains water that has gone i

12 through the EPICOR-2 procesa. It is then put into those 13 tanks and distributed for any different type of activity.

() 14 That 's the current use of those tanks. At this particular -

15 time. I'm not sure exactly what those tanks were being used 16 for. We use, the water in the tanks can be used, goes in 17 many different directions and is used for many different 18 activities. ,

19 Q So in other words, any of the water in any of the  ;

tanks could find itself into either the reactor building I 20 f

i 21 basement or the reactor vessel 9 l

22 A (Harneri No. A lot of the tanks do not have 23 pathways. There 's only certain pipes and pathways that the .

24 water can take. Each tank cannot go to every other 24 j

! l i 25 locations on this chart. There 's only certain locations ,

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s 342 cach tank can find its way to.

-( ) i 2 Q Okay. So each, the 25 locations are piped to 3 different areas?

4 A CHarner) Yes.  :

5 Q And will they all be piped then to the PWST-2?

6 A CHarner) No. They definitely are not piped to  ;

7 the PWST-2. As I said, certain tanks go to certain places.

8 That excludes other places.

9 Q When you were talking about tritium evaporative ,

10 losses --

11 JUDGE BLOCH: One second. Ms. Skolnik. There was 12 no obj ection, so I didn't stop you. But redirect is 13 addressing questions that were raised by counsel on recross

() 14 and clarifying those. And I j ust didn't know if you knew 15 for sure that that 's what it 's limited to.

16 MS. SKOLNIK: Yes. I thought -- wasn 't my subj ect 17 matter directed to the subj ect matter of the cross 18 examination?

19 JUDGE BLOCH: Maybe there was some c'nnection. I 20 didn 't perceive how, where this water came f rom had anything 21 to do with what the recross was. Redirect.

22 MS. SKOLNIK: I guess it was concerning the 23 tankage that had been discussed in the cross -- in Mr.

24 Baxter 's questions.

25 JUDGE BLOCH: It was related to what?

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343 MS. SKOLNIK: The tanks, which have been the

. () i 1 2 subj ect of Mr. Baxter 's --

3 JUDGE BLOCH: But all of his questions were about 4 the date of the tanks. that 's all. Just the date. -

5 MS. SKOLNIK: Okay.  ;

6 (Pause)

7 MS. SKOLNIK Okay. That 's all. (

8 JUDGE BLOCH: Thank you. We will thank the 9 witnesses very much for their participation, and you are [

10 excused.

. 11 (The witness were thereupon excused.)

12 JUDGE BLOCH: I would like to go right to the two 13 staff witnesses, if we may.

j () 14 MS. WOODHEAD: The Staff calls Mr. Lee Thonus and 15 Dr. Michael Masnik as its witnesses for Contention 3 i

16 Mr. Thonus, will you give your full name for the  !

l 17 record, please? (

18 MR. THONUS: My name is Lee Henry Thenus. It 's  !

19 spelled T-H-O-N-U-S.

20 MS. WOODHEAD: Dr. Masnik, will you give your full k 21 name for the record?

i 22 DR. MASNIX: My name is Michael Thomas Masnik, i L

23 spelled M-A-S-N-I-K.

24 JUDGE BLOCH: Thank you. [

t 25 MS. WOODHEAD: I am going to hand you a document i

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~( ) i for identification, gentlemen. The document has the style 2 of this proceeding and is entitled "Testimony of Lee Thonus <

3 and Michael Masnik Concerning Contention 3." It consists of 4 five pages of testimony and two pages of professional 5 qualification.

6 JUDGE BLOCH: Before we continue. I 'd like to 7 welcome you to the proceeding, and I 'd like to inform you 8 that you are to tell the truth, the whole truth and nothing 9 but the truth, and the testimony that you are about to give 10 is subj ect to possible penalty for perjury. Do you both 11 understand the statement that I 've made?

12 DR. MASNIK: Yes, I do.

13 MR. THONUS: Yes, I do.

() 14 JUDGE BLOCH: Thank you.

15 Whereupon.

l 16 LEE H. THONUS 17 DR. FRANK T. MASNIK 18 having been first duly sworn, were called as witnesses 19 herein, and were examined and testified as follows:

20 DIRECT EXAMINATION 21 BY MS. WOODHEAD:

22 Q Will you each examine this document and state 23 whether this is t.he testimony that was prepared by you? Mr.

24 Thonus?

25 A (Thonus) Yes, it is.

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Dr. Masnik?

{-) 1 Q 2 A (Mannik) Yes, it is.

3 Q Are there any additions or corrections that you 4 wish to make to this testimony? i 5 A (Thonus) No. I don't have any additions or j

- 1 6 corrections to my testimony.

f 7 0 Dr. Masnik?

8 A (Masnik) Yes, I do. On my professional l 1

9 qualifications, my responsibilities have remained the same. [

I 10 However, my affiliation with the agency has changed. If we

) i 11 could strike the first sentence and replace it with: "I am i t

12 currently employed as Senior Proj ect Manager in Proj ect l l

13 Directorate 14. Office of Nuclear Reactor Regulation. U.S.

O 14 "aC. "  ;

15 And then in the second sentence. "TMI-2" should be }

16 stricken and the numbers "14" added af ter "PD. "

17 That is the extent of my changes. j r

18 Q Will each of you state if this testimony is true  ;

i 19 to the best of your knowledge and belief as corrected? Dr.

(

20 Masnik?  !

i 21 A (Masnik) It is. [

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. 22 Q Mr. Thonus? j i

23 A (Thonus) It is.

1 24 MS. WOODHEAD: Mr. Chairman, the Staff asked that 25 the testimony of Mr. Thonus and Dr. Masnik be received into l l

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() i the record as if read.

2 JUDGE BLOCH: There being no obj ections, it shall 3 be received into evidence and bound in and sequentially  ;

4 numbered.

5 MS. WOODHEAD: And I am giving the Court Reporter I

6 a corrected copy.

7 (The Testinony of Lee Thonus 8 and Michael Masnik concerning 9 Contention 3 is received and 10 inserted into the record and i

11 followst) l~

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

GENERAL PUBLIC UTILITIES Docket No. 50-320 OLA hUCLEAR CORPORATION, ET~~AL. 1 ASLBP No. 87-554-OLA (Three Mile Island Nuclear (Disposal of Accident-Station, Unit 2) Generated Water)

TESTIMONY OF LEE TPONUS AND MICHAEL MASNIK CONCERNING CONTENTIC." 3 Q.1. Please state your names and places of emplopent A.I. My nare is Lee Thenus. I am eeployed by the U.S. Nuclear Regulatory Comission as a project manager at the Three Mile Island Nuclear Plant site. My professioral qualifications are attached to this testimony.

My name is Michael Masnik. I am employed by the U.S. Nuclear Regulatory Corrission as a senior reactor project manager. Mv (c) professional qualifications are attached.

Q.2. Vhat is the purpose of yeur joint testimony?

A.2. The purpose of our testimony is to address the issues concerning Contentien 3 admitted by the August 25, 1953 Merorandur and Order.

Q.3. Flease respond to each of the folleming issues set out in the August 25, 1988 Memorandum and Order.

(1) The NFC analyzed a single 4 liter sample drawn from only one of 25 locations of the storage of the AGW, which is an inadequate sarplitig of the AGW; Answer: The NRC did not intend to use the sample to provide bounding radier.uclide limits on the AGW. GPUN's rore extensive sampling program provided the basis for the estimated influent to the processed water disposal system. The results of this sarple do support the information supplied by GPUN. The NRC does not develop data for environrertal statements. This is the responsibility of the applicant fer a licensing action. The NRC sample in questien here was taken only to audit the GPUN data.

b

348

  • (2) The NRC sampling procedure followed procedures outlined in 4212-CHM-3011.05 (D

v .

81-p5.0,6.1.7fl0/27/87);Rev. 0 (5/23/84) [instead of) 4212-CHM-3013

_ Answer: The NRC sample was drawn in February of 1987 Proce-dure 4212-CHM-3013 Revision 3 was not issued until Octobet 27, 1987 Procedure 4212-CHM-3011.05 is used for obtaining samples

-- which the NRC and GPU did. Procedure 4212-CHM-3013.81 is used for determining the amount of tritium in a sample; i.e., a counting procedure. The NRC sample was counted at RESL, using RESL procedures which were developed for the RESL equipment.

ASTM Method 3370 is titled "Standard Practices for Sampling Water." Procedure 4212-CHW3011.05 incorporated the applicable sections section. of ASTb D-3370-E2 and lists it in the reference (3) The analyses of the PWST [ Process Water Storage Tank) 2 sarples by the RESL for the NPC and b fur Co-60, Cs 137, and Sr-90,y Licensee gave differing results and neither detected C 14 whereas an aralysis by Westinghouse found C-14 at a concentration of 3.0 E-4, greater than average concentration listed in Table 2.2 of rthePE15)byafactorof3; Answer: The 1 E-4 uti/mi of C-14 from Table 2.2 in the PE!S is a censervative best estimate for the average influent from all sources at the tire of evaporation. The other Westinghouse

(,#-) sarple results for CCT-1, CCT-2, and PWST-1 are 1.4 E-4 uCi/nl, 1.1 E-4 uti/ml, and 5.1 E-5 uti/ml. The information in EG&G-PRS-6798 TMI-2 Isotopic Inventory calculations, and the results from the RESL analysis indicate lower amounts of carbor 14 present than the Westinghouse results. In any event, C-14 is a relatively minor contributor to exposur), so that even tripling the estinated quantity present would not affect exposure estimates by as much as 10 percent, nor would it chance the NRC staff's conclusions regarding the relative merits of evaporation.

The analysis results for PWST-2 by RESL and GPUN are in agree- <

nent for Co-60 and Cs-137 They de differ for Sr-90. However, both results are lower than the value used to evaluate environ-rental impact. .

(4) The NRC assures that the concentrations of radienuclides shown inTable2.2(ofthePEISlcanreasonablybeconsidereda '

maximum and upon this assumption based its dose calculations; Answer: The staff has considered the values in Table 2.2 to be maximum values for purposes of perforring dose calculatiers for a generic evaporator. Since AGW is stored in many locations within

' the plant, variations in radionuclide concentrations are to be expected, k

349 (5) TheaveragetritiumconcentrationpresentedinTable2.2of[the

( PE15) is 0.13 [u)Ci/ml, whereas the actuel data show a tritium '

concentration of 0.23 [u)C1/ml and the licensee has reported a i Q_ concentrationinPWST2of2.1[u]Ci/ml; Answer: The NRC staff is not aware of any sample results of  !

2.1 uti/ml in the AGW. There was an apparent transcription error in a GPUN bid procurement document which appeared after i the PEls was issued and reported a tritium concentration in the AGW of 2.1 uti/ml. The staff relied on data from various sources which support the average influent concentration to the evaporator of 1.3 E-1 uti/ml.

(6) The NRC relied on a RESL sample analysis which gave 3161 Curies  !

while Licensee relied on data from PE!$. 1981. EGG-P85-6798 to get 4231 Curies, whereas TP0/THI-043 Rev. 6 (1986) shows that a the cover inventory of tritium at the time of the accident was .

8.794Curiessothatnoconclusioncan60 source tem; drawn [about)the i l

Answer: The source term can most accurately be characterized by the series of sarples and measurements taken by GPUN. They i represent the current tritium inventory in the AGW. The other '

numbers are Supplement 2. not inconsistent with the 1020 curies used in PEIS Since hydrogen reacts chemically with zire. alloy fuel cladding, not all of the initial core inventory was released to the reactor coolant. Radioactive decay since the '

accident has resulted in a less of approxtr.ately 42 percent of bI the tritium. In addition, evaporative losses of tritiated water <

in the reactor building and the spent fuel pools have decreaset the current plant inventory of tritium.  !

f7) The NRC based its dose calculations on inadeovate data because of the foregoing facts plus the fact that water going into the  ;

evaporator in Batch Cycle will deviate from the concentrctions 1 listedinTable2.2of[thePE!S). j J

Answer: The staff's conclusions were based on average influent I concentrations. Deviations above and below the average, which  !

do not materially change the average, do not affect the staff's '

conclusions. As stated, the PE!S Supplement 2 conclusions are  !

i based or the licensee's samples and reasurerents, i l

) (B) The evaluation of microorganises in the AGW is a genuine issue '

which must be heard.

Answer: Neither the licensee nor the NRC has undertaken a

' detailed analysis of the organisms inhabiting the accident generated water. During the tire when microorganises were i

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4 M0 thought to be a problem in the reactor vessel a number of classes of organisms were identified including anaerobic and

>C . algae.

aerobic bacteria, yeasts, aquatic fungi, green and bluegreen The li'.ensee usvt hydrogen peroxide in calculated concentrations t

of up to 1000 ppm to mitigate the past problems of microorganisms.

Sinct tut tix the licensee continues to periodically add hydrogen peroxide prophyloctically to achieve a calculated concentration of ,

t 300 ppe. Microorganisms in the filled portion of the reactor vessel are water nocitanup longer system a oroblem affecting the water clarity or the defueling filters. -

I As noted above, the AGW in the reactor building has been treated to significantly reduce population levels of all nicrorganisms. Nevertheless, the NRC staff has considered whether it is likely that there are hazardous concentrations of pathogenic organisms in the AGW. Since the source of the AGV was initially the Susquehanna River, whatever pathogenic organisms were present in that water would have been introduced into the AGW. A variety of pathogenic organisms occur in surface waters. Typically, the mode of transmission of such microrcanisms to hurans is by direct contact with, or ingestion of, the contaminated water.

Disposal of AGW is prepesed to be by vaporization, with only a very small percentage of carryover as an aerosol.

If any pathocens were entrained in the water that entered the O reactor building during the accident there is a possibility that they may have survived for sore peried of time inside the containment. However, evidence from domestic wastewater studies indicates that r.ost pathogenic organisms survive less than four renths in a free living state. The likelihood that there is a significant concentration of pathogenic organists present in the accider,t generated water, nir.e ard one half years after the accident is remote.

Moreover, if there were waterborne pathogens in either the sludge or the accident gererated water the workforce inside the reactor building would have been exposed to the organises by breathing the atmosphere inside containment. No cases of water-born diseases traceable to the reactor butiding environment have been reported in the workforce. Clearly the workforce inside the reactor building was exposed to aerosol concentrations r.any times greater than any rerber of the public would be by the evaporation of this water.

The AGW will be subjected first to a temperature of 131'F (55'C) in the evaporator. Any microorganisms contained in the carry-over factor weuld be subjected to elevated terperatures of 176'F (80'C) in the evaporator before entering the vaporizer. Upon entering the vaporizer the AGW will be heated to a ranimum of 245'F (118'C) and cycled in a system for an average of 20 minutes experiencing an average temperature of 240'F (115'C).

O

.. 351 The vapori:er system should result in complete sterilization of the accident generated water. Sterilization by moist steam is O one of the most acceptable methods of achieving 1001 mortality of aii crianismi. The t o aarameters coatroiitas the stertiira-tion process are exposure time and final temparature. The goal is to bring the internal temperature of the organism above the boiling point 212'F (100'C) which denatures protein.

the terperature range of about 215'F (102'C) and 250'F Through (121 C) there is a fairly linear relationship between time and tempera-ture required to achieve sterilization. This relationship has been established sterilization for moist steam in an autoclave for of equipenent. For a temperature of 240'F (115'C) approximately 21 minutes would be required to sterilize any object within the system. Since comonly accepted startitration guidelines include additional time necessary to sterilize equipment that would have a lower initial surface temperature due to heat conduction, the guidelines are conservative relative to sterilization of water. ' be time temperature relationship in the proposed TMI ? vaporizer would be more than adequate to sterilire the AGW. This time / temperature regime is knewn to kill the spores of virtually every species of bacteria, parasitic and mycotic agents. and viruses. ,

Based on the design and anticipated creration of the vaporizer.

I conclude that evaporation of the accident generated water using the processed mater disposal system described by the licensee would not release hazardous levels of any pathogenic organism and does not represent any risk to the public.

b The presence of significant quantities of microorganisms could result in reduced life of resin liners in the SDS and EPICOR !!

system. This would result in the need for additienal liners.

It would not affect the radionuclide concentration of the feed-water to the evaporator. However, due to the addition of hydrogen peroxide on a periodic basis, the microorganism popu-1ations have been greatly reduced and is no longer a significant problem.

Altteugh high concentrations of microorganisms might result in increased use of resin liners, there would be no effect on the effectiveness of the evaporator to remove non-tritium radieruclides.

Q.4. In its Memorandur and Order (at 34) the Board left as an issue in the proceeding whether the NRC Staff's assurptions regarding the concentrations of radionuclides in the AGW were valid. In light of your responses, above, to the specific issues of fact are the staff's assumptions regarding the concentrations of radionuclides in the AGW valid.

A.4. Yes. We are confident that these assumptions are valid.

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7

.. 352 PROFESSIONAL QUALIFICATIONS OF LEE H. THONUS f )

Education: B.S., Applied Biology, Georgie Inst, of Tech. - 1971 M.S., Nuclear Engineering, Georgia Inst, of Tech. - 1972 A.A., Data Processing Harrisburg Area Comm. College - 1988 Affiliations: Nember, Arerican Nuclear Society (Standards Comittee and Local Sections Committee)

Member, Health Physics Society Member, American Association for the Advancement of Science March 19EE Project Manager - Manage all aspects of safety and environ-to mental evaluations related to Three Mile Island - Unit 2.

Present Develop and maintain schedules for technical reviews and licensing actions. Maintain liaison with headquarters, Region I, and the licensee and participate in inspection program. Perform technical review of safety analyses, systems descriptions, and technical evaluation reports submitted by the licensee.

November 1983 Systers Encineer - Reviewed and evaluated the design and to operation of reactor and auxiliary systems. Perforced March 1955 studies of technical and litersing issues at TMI and pro-vided technical advice and assistance to other NRC func-tional organizatier.s.

n (V May 1977 to Irtretter - Planred and coordinated overall inspection pro-gram of a licensed nuclear power plant, including integrat-November 19E3 ing efforts of specialist inspectors. Conducted inspections and investigations to evaluate plant safety and regulatory corpliance in the areas of plant operations, naintenance, surveillance, radiation protection, energency planning, red-waste, and effluent control.

November 1974 Health PFysicist/Radioloeiceal Engineer - Knolls Atreic to Power Laboratory - Kesselring Site - As radiological April 1977 engineer, respersible for radioactive raterial and waste shiprents, radiological skills trainino, radiological support facilities; e.g., decontamination faciities, venti-lation, and filtration systems. As health physicist, responsible for application of radiological controls during startup eperatinn, refueling, and raintenance of three pressurized water reactors.

December 1972 Licensinn Engineer - Southern Services - Responsible for to evaluating plant design against regulatory criteria, codes November 1974 and standards and preparation and review ef sections of environmental reports, safety analysis reports, and Technical Specifications for nuclear power statinns.

Provided technical support and evaluation in environmental

( ,_ and radiological matters for other engineering groups

(]. (prirarily in support nf power reactors).

l

. 353 t

( , Michael T. Masnik t f

  • STATEMENT OF PROFESSIONAL QUALIFICATIONS '

i n'UCLEAR REGULATORY COVMISSION Washington, D.C. -

.T aM s ,

l

~ as G u yW U 1sY MtM%CL %

r i et tre d (TC 4 YRNg F em fVd retty-employed _aL_TecbrJeaL_Assistent-te-the-Directorof the# ,) [

tar *+-We-Island-Cleenup-Project-Directorate-0TMtat-PDPNfice

% dear-Reseter RegulationrVSNAG1 r ef- f I As a member of Tfm*? PDf have responsibility for coordinating broad and technically complex projects 1 which have technical aspects encompassing all phases of the Three Mlle 4

i Island Unit 2 nuclear power plant cleanup operation. I wrve in a technical advisory capecity to the Director en technical issues particularly ,

these that deal with the environment.

Manager for TMI-2. As Project Manager iI prepare also serve as the Project license amendment i a

packages, make fee determinations, conduct environmental assessments.

publish and on occasion conduct safety review s . Additionally, I am l the lla! son between the NRC Commissionerr and the Advisory Panel for '

ths Decontamination of Threa Mile Island Unit 2,  !

i l i hold a Dachelor o' Science in Conservation from Cornell University (

(19f ei, a Master of Science in Zoology from Virginia Pelvtechnic Institute j

and State University (1971), and a Doctor of Philosophy in Zoology from (

i Virginia Polytechnic Institute and State University (1975).  ;

l While at Virginia Polytechnic Institute end State University, I undertook f 1

( research in a variety of arers, specializing in zoopeography and distri-bution of freshwater fis he s . Other areas of research which resulted in i

published papers incluele therral studies on fishes, recovery of damaged anuptic eco-systems, and c'evelopment of sampling methodology for fishes l i

and macroinvertebrates. I have authored or coauthored some 16 publica-

  • i tiens on the above areas of research. My formal education program has j encompassed and emphasized studies in Zootony. Aoustic Ecology, f j

t lehthyolc.gy. Evolutionary Biology, and corputer techniques for data  ;

l handling and analysis, j

i was a member of the scientific staff of a Duke University Caribbean  !

1 Cruise involved in oceanographic investigations and have served as a l consultant, through Virginie Polytechnic Institute and State liniversity.

for American Electric Power Company, Kerpers Company. Inc., U.S. l i

i Army corps of Engineers, and Tennessee Valley Authority.

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() i MS. WOODHEAD: Mr. Chairman, at this time. the 2 Staff would like to identify its exhibit. Are you numbering 3 exhibits? This will the Staf f 's Exhibit Number 1 if you are 4 using that method. This is the Environmental Statement.

5 JUDGE BLOCH: I think we are going to have so few 6 that are not bound in that we can just refer to it for what 7 it is.

8 MS. WOODHEADt All right.

9 BY MS. WOODHEAD:

10 Q Dr. Masnik, I am handing you a document entitled 11 "Programmatic Environmental Impact Statement Releted to 12 Decontamination and Disposal of Radioactive Wastes Resulting 13 from March 28, 1979 Accident at Three Mile Island Nuclear

() 14 Station Unit 2. " The Docket Number is 50-320 and it is also 15 designated as "NUREG-0683 Supplement Number 2 Final Report."

16 Dr. Masnik, was this dociment prepared under your 17 supervision?

18 A (Thonus) Yes, it was.

19 MS. WOODHEAD: The Staff submits it as its exhibit 20 ano I have three copies for the Court Reporter.

21 JUDGE BLOCH: Is all of it in evidence or is it an 22 exhibit for ref erence?

23 MS. WOODHEAD: This is an exhibit for ref erence.

24 JUDGE BLOCH: Thank you. It shall be received on 25 that understanding.

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2 marked for identification as l 3 an NRC Staff Exhibit and  !

4 received in evidence.)

5 MS. WOODHEAD Mr. Chairman, the witnesses are 6 available for cross examination.

7 CROSS EXAMINATION 8 BY MS. SKOLNIKt i 9 Q Mr. Wasnik -- ch. I guess you did not identify 10 which person answered the question. So should I just 11 address them to both of you?

12 A (Masnik) The questions pertaining or the answers 13 pertaining to the water sampling were handled by Mr. Thonus O 14 end 1 nendied the issue deelina with the microorcenisme.

15 JUDGE BLOCH: If you 'd like. Ms. Skolnik. you can 16 just address the question to the panel. If there is a 17 reason that you must have one of the people answer, you can l 18 address it to them specifically.

I 19 MS. SKOLNIX: Okay.

20 BY MS. SKOLNIK l

l 21 Q It is written in your testimony that the resulta 22 of this sample do support the information supplied by GPU 23 Nuclear. Could you please identify the information that was j 24 supplied by GPU Nuclear?

l 25 MS. WOODHEAD: Ms. Skolnik, when you are referring Heritage Reporting Corporation (202) 628-4888 l

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to.the testimony, would you provide us a page' number and paragraph number so that we can follow you?

3 MS. SKOLNIK Yes, I 'm sorry. I keep meaning to 4 do that and then I forget. It 's the first page. the fifth 5 line up from the bottom of Question 3.

6 MS. WOODHEAD: Would you mind repeating the 7 question, since I interrupted?

8 JUDGE BLOCH: Well. I 'll repeat it.

9 MS. SKOLNIK Geest.

10 JUDGE BLOCH: The question is, you 've stated that 11 the results of this sample do support the information 12 supplied by GPUN. The question is, which information?

13 THE WITNESS: (Thonus) The -- GPU Nuclear

() 14 submitted their original proposal and there was a letter 15 dated July 31, 1986, and then there was a second letter 16 dated February 3. 1987, and a February 18, 1987 letter with 17 an appendix and comments.

18 BY MS. SKOLNIK 19 Q Isn 't it true that the radioisotopes examined in 20 the proposal which was presented by GPU includes only six 21 radioisotopes, whereas the EIS. Table 2 2 shows 32, and 22 that even including --

23 JUDGE BLOCH: Can we stop there? You can ask more 24 later, 2$ MS. SKOLNIK: Yes. Okay.

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() 1 THE WITNESS: (Thonus) GPU Nuclear submitted us 2 more than one submittal and I guess I could riffle through  ;

i 3 these papres here and find that indeed more than six  ;

4 radionuclides were addressed in their letters. If you 'd I 5 like, I *11 do that now and I 'll look up their letters and  ;

6 find that there are more than six radionuclides. l t

7 I have in front of me now a copy of their letter 8 dated February 18, 1987 and as I look at it I would say 9 there are greater than 20. If you would like, I 'll take the  !

JO tine to either count them all or read them off one at a j 1

11 time, j 12 JUDGE BLOCH: Off the record. l 13 (Discussion off the record)  !

) () 14 JUDGE BLOCH: On the record. 2n the off the i

15 record discussions we discussed the materials that are being

{

j 16 ref erred to and one of the letters has been stated by Mr.

f 17 Thonus to be present in the PEIS. which is an exhibit, at ,

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18 Pages A-43 and A-44 And we can allow that exhibit to speak j 19 for itself as to what it shows. f i

20 THE WITNESS: (Thonus) The letters are also  !

t

, 21 referenced in the PEIS at the bottom of Page 2.3. at the 22 bottom of Table 2 0 They are both, actually 6: 1 three are  !

(

23 docketed correspondence f rom the utility to the NRC. which i 24 supplied the Licensee 's original proposal and additionel j

! 25 information, f 1

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358 JUDGE BLOCH: Mr. Thonus. when you say that the

(]T21/Blod  !

2 results support the Applicant, are you talking about some 3 kind of a statistical inference from the work you did or is 4 there some other way it supports it? f i

f THE WITNESS: (Thonus) Basically, the results of j 6 the sample we took would tend to confirm the results that  ;

i 7 the Licensee had on their sampling program and ...e numbers i

8 that they had given us as estimated amount of curies that .

r 9 would be in the water that would be going to the evaporator.

i 10 JUDGE BLOCH: I mean, supported in the sense that 11 it 's within the range of values you 'd expect?  !

12 THE WITNESS: (Thonus) Yes. Yes, it would be f i

13 within the range of values that we would expect.

() 14 JUDGE BLOCH: Okay. But as I understand the i i

15 testimony, it does not give the kind of support that you i i

16 might get if you did an audit and you established your own l i

1. error bounds about their measurements.  !

I 18 THE WITNESS: (Thonus) I 'm not sure I understand. j 19 There 's no conflict between our sample results and GPU's  !

i 20 sample results. l t

21 JUDGE BLOCH: I understand that. But on the other i 22 hand, have you gone so f ar ss to calibrate thair measurenent (

23 capability? Has what you've done checked as to whether f f

24 their measurement procedures and methods are accurate or is p 25 it just that you 're within the range of what they said they l 1

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f 359 i would have?

2 THE WITNESS: (Thonus) I would say the latter.

3 that we are within the range that they said that they would 4 ha 'e. From that standpoint. it tends to confirm their S numbers. We have another program where we, as part of our ]

6 inLpection effort, where we go out and independently bring a I

7 van on site where we split samples and confirm their l

8 laboratory analysis methods. And we also review -- (

9 JUDGE BLOCH: Has that been done at this plant? j 10 THE WITNESS: (Thonus) Yes. It has.  !

i 11 JUDGE BLOCH: And are the results of that 12 available?

f 13 THE WITNESSt (Thonus) The results of that are O 14 pubiished in the inege:11on renotte ee vert of our i 15 inspection program. j 16 JUDGE BLOCH: Can they be made available for us?  !

17 It seems to me that that 's a f ar more direct way of i

18 verifying the measurements taken by the applicants than i l

19 taking a sample that 's within ',he range?

20 MS. WOODHEAD: Mr. Chairman, could I remind you {

i 21 that the issue that Ms. Skolnik raised and that the Board 22 admitted was over the accuracy of one sample whisn was 23 mentioned only as an aside in the EIS. The issue is this }

24 one sample. not whether NRC has taker the responsibility to 25 verify GPU's nunbers.

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} 1 JUDGE BLOCH
Except that the Board suggested that 2 it was concerned about there only being one sample. I am 3 much more reassured if we actually have checked on the 4 measurement system out at the plant than if we just found a r

5 sample that was within the predicted range.

n

( 6 THE WITNESS: (Thonus) Not just TMI but all 7 plants, as part of our independent measurements effort, are 8 checked for their ability to do various radiochemical l' 9 analyses. It wasn't done for the purpose of accident-10 generated water, it was when we do independent measurements 11 we c..eck to see that they can measure anything in the plant 12 accurately. It wasn 't done as part of the review and 13 approval process for act ident-generated water. We would be

() 14 checking their ability to measure air samples and perhaps 15 check air quality where people might be working.

16 JUDGE BLOCH: But am I correct that it wasn 't for 17 that purpose but it would lend added credibility to the 18 process here, wouldn 't it, to know that that 's been checked?

19 THE WITNESS: (Thonus) Yes. It might do that.

1 20 But up until this point, no one has raised that issue.

21 JUDGE BuOCH: 1'ay I ask, Ms. Woodhead, how 22 difficu't it would be to have thic for our record when we 23 arr back in Washington the third week of hearing?

24 MS. WOODHEAD: It would not be difficult at all.

25 We 'd be happy to do so.

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() i JUDGE BLOCH: Okay. Thank'you. We 'd :3ppreciate i

2 that. Continue.

3 BY MS. SKOLNIK:

4 Q Mr. Thonus, when you made the reference, you said ,

5 the page on A-44 showed the radionuclides that have been 6 sampled by GPU Nuclear, in the PEIS?

7 A (Thonus) I referred to Pages A-43 and A-44, 8 that 's correct.

9 Q Correct me if I am wrong, but isn 't that table the 10 average concentration, but it doesn 't r ' lect sample 11 analysis?

12 A (Thonus) As I understood your question, you asked 13 me whether or not only six radionuclides had been addressed

/~T

(_) 14 and my response was that somewhat more than six had been 15 addressed. You asked me where and I found a reference for 16 you.

17 Q Well, perhaps my question wean 't clear enough.

18 What I need to know is how many of the 32 radionuclides 19 listed in Table 2 2 were analyzed in samples by GPU Nuclear 20 for information that was supplied to you in order for you to 21 make this statements the results of the sample do support 22 the information supplied c) GPU Nuclear?

23 JUDGE PARIS: i' would be helpful to me if you 24 would interpret the title of this table. It says: "Average 25 Concentration of Radionaclides Potentially Present in TMI-2 Heritage Reporting Ctrporation (202) 62, 4888

362 Water for Evaporation."

( )' 1 What do the numbers really mean?

2 Where do they come from?

3 JUDGE BLOCH: The question was not disallowed, but 4 we 'll take Dr. Paris' question first.

5 THE WITNESS: (Thonus) Correct me if I'm wrong 6 but I'm going to Pade A-44 and interpreting the GPU Nuclear 7 title on that table. And I feel a little bit uncomfortable 8 in answering for GPU Nuclear although I think I have a  :

9 pretty good understanding for what they_did. Dr. Harner or 10 Dr. Hofstetter had addressed this earlier. GPU Nuclear had 11 taken a number of samples f rom 25 tanks and based upon the 12 results of those samples and the given volumes of those 13 tanks they had developed these numbers for total curies in

() 14 the sum total of 2.3 million gallono of water and then you 15 can derive from that an average radionuclide concentration.

16 This does not represent any one particular tank. This is 17 the expected radionuclide concentration to be going into .ne 18 evaporator system. I didn 't find, unfortunately, the page 19 with the original submittal e neir letter of July of 1986.

20 And you are looking at potentially, and I guess GPU would 21 probably have been better to answer that than I.

22 JUDGE PARIS: Yes.

23 THE WITNESS: (Thonus) But I think we 're looking 24 that again the testimony of Dr. Hofstetter and Mr. Harner, 25 that there would in all likelihood be some additional O Heritage Reporting Corporation (202) 628-4888

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() i procassing occurring between the time they wrote their 2 letter and the time that the water was actually evaporated 3 and that there would in all likelihood be less radioactivity 4 going into the evaporator whenever, if and whenever that ji 5 occurs, than was measured at the time they took their

/g 6 samples.

7 JUDGE PARIS: Is that why they used the term 8 "potentially, " do you think?

9 THE WITNESS: (Thonus) I believe that 's the 10 reason why they used the term "potentially."

11 JUDGE PARIS: Okay. Thank you.

12 THE WITNESS: (Thonus) I gue.9r; I should add that.

13 as Dr. Masnik has reminded me, that some of these numbers in I) 14 the table were based on what we call LLDs and there was no 15 activity detected, and we assumed, the Licensee and the 16 Staff assumed that it was present at a concentration at the 17 lower limit of detectability even though it may have been 18 much less than that. We used the LLD for our assumptions (

19 and releases.

20 BY MS. SKOLNIK:

21 Q In the GPU proposal, on Table -- let me rephrase 22 that, please.

23 Did you receive all the information on sampling 24 which led GPU to present you with this average concentration 25 table?

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' x-f'] 1 A (Thonus) At the time we wrote the PEIS, as part 2 of their proposal. I don 't believe that we had received the 3 results of all the individual samples. Since then we have 4 received a great volume of information as part of the 5 discovery process, including the individual -- a lot of 6 information. So at the time we wrote the PEIS. I would say 7 that I don't think that we had received the results of all 8 the 25 individual samples that GPU Nuclear had t aken. I may 9 be wronc on that and someone else in the NRC may have ,

10 received those, but I am not aware that we received them. I -

11 mean, our inspectors, we had a rather large staff on site 12 and our inspectors coulo have been out there looking at 13 their chemistry results on any given day in the plant and

() 14 could have looked at every record. But I 'm not aware of it.

15 Q So if you didn't have all the information i

16 available to you, what exactly did the sample, the 1-liter, 17 or the single 4-liter sample prove to you?

18 A (Thonus) I don 't think the 4-liter sample was  ;

19 intended to prove anything. The basis for the EIS and our 20 review was the consolidated number given to us by GPU as the

. 21 result of their larger sampling program. The one 4-liter j 22 sample was just a single independent audit point. t 23 JUDGE BLOCH: So, Mr. Thonus, could you please 24 answer the question, though? What, if anything, did the 25 single 4-liter sample prove to you?  !

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365 1 THE WITNESS: (Thonus) I guess if the single 4-

. (])

2 liter sample, if our results were greatly different than 3 GPU 's results, we would have questioned their submittal, or 4 if our independent measurement program had shown previously 5 that their laboratory analysis was unreliable, we may have 6 questioned their number. But we had nothing. It was just a 7 point that showed that our two numbers were in reasonable 8 agreement. '

9 JUDGE BLOCH: But given the way statistics and 10 sampling works, how much comfort can you take from one 11 sample?

12 THE WITNESS: (Thonus) That 's a dif ferent 13 question. But that was the one I inadvertently answered s

14 first. And that there really was not intent for that one 15 sample to prove absolutely that their submission of July c?

16 '86 was correct. We had no intention of going out there and 17 replicating their entire sampling program.

18 JUDGE BLOCH: So just to be clear, how much did it 19 add that you had one sample point?

20 THE WITNESS: (Thonus) As a matter of engineering 21 judgment, I 'd have a hard time saying that that added 12 22 percent or 19 percent to my judgment. It was comforting to 23 know that the numbers were in agreement but I can 't say that 24 25 percent of our judgment was based on that. I can 't put a 25 number on that. I 'm sorry.

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I 366 JUDGE BLOCH: ~So just'a vague feeling of comfort, (f 1 2 but no scientific proof.- Is that correct?

3 THE WITNESS: (Thonus) It didn't prove that their 4 entire sampling program was accurate. It did show that on 5 that palticular day our results were in reasonable 6 agreement.

7 JUDGE BLOCH: Did it prove anything? Did it prove 8 anything?

9 THE WITNESS: (Thonus) Other than the specific 10 results of that particular tank on that particular day I 11 wo- d say - .

12 JUDGE BLOCH: So could you inf er anything f rom the 13 results of that particular tank on that particular day? Is

() 14 there really any sound conclusion you draw as a scientist 15 from that or as an engineer?

16 THE WITNESS: (Thonus) I could draw that there 17 was no significant disagreement between the results of our l

l 18 contractor laboratory and the lab results that GPU got. It

! 19 was a blind. They didn 't know our results, we didn 't know I ,

l 20 theirs.

l 21 JUDGE BLOCH: And affirmatively, can you conclude 22 anything from it? You can conclude that it wasn't 23 different. Can you conclude anything about their system 24 based on the single sample?

25 THE WITNESS: (Thonus) I guess that it confirmed 4

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1 367 I~'t i that GPU could do a valid radiochemical analysis on the v

.2 t ank.

3 JUDGE BLOCH: They could, that 's true. It 's  ;

4 possible.

5 ".ME WITNESS: (Thonus) And that in this 6 particular instance, they did.

7 JUDGE BLOCH: On that one-sample?

8 THE WITNESS: (Thonus) Yes.

9 JUDGE ELOCH: Okay. Off the record.

10 (Discussion held off the record) 11 (Continued on the next page) 12 13 j

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368 T' ') 1 BY MS. SKOLNIK:

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2 Q The sample which you took was from the same kind 3 that the GPU took it from? You always take the sample from 4 the PWST-2?

5 A (Thonus) Yes, it was a split sample.

6 Q Did you -- so what you did really with your sample 7 was prove the contents of the PWST-27 Or tried -- your 8 sample --

9 JUDGE PARIS: By split sample, you mean you took a 10 sample and sent one to RESL or to the NRC and you kept one?

11 THE WITNESS: (Thonus) Yes. We took a split 12 sample. GPU Rept a portion of it. The NRC Rept a portion 13 of it and our sample was then further sub-divided and sent

, () 14 to RESL.

15 JUDGE PARIS: I see.

16 BY MS. SK0LNIK 17 Q Did the radionuclides that you checked for in that 18 sample, was it the same number that 's used? Did it reflect

, 19 the number of radionuclides that you have in Table 2.2?

20 JUDGE BLOCH: What radionuclides did you check 21 for?

22 THE WITNESS: (Thonus) You'll have to give me n 23 minute to look that up. The radionuclides I don 't think 24 would correspond precisely to what 's in Table 2. 2.

25 But the radionuclides in the san 4e that was done

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.a 369-( )' 1 for us by our contractor included tritium iodine 129, cobalt 2 60.. nickel 63, strontium 90, cesium 137, Americum 241, 3 plutonium 239 and 240, plutonium 238, antimony 125, carbon 4 14, technesium 99, uranium 234 and 233, uranium 235, uranium 5 238 and curium 244 and 243 and curium 242 separately.

6 BY MS. SKOLNIK:

7 Q And, Mr. Thonus, that makes a total of 17 plus 8 your Table 2.2 upon which you base the dose, lists a total 9 of 32.

10 MS. WOODHEAD: Obj ec t ion. That 's a question 11 outside the scope of the testimony.

12 JUDGE BLOCH: Sustained. He 's not using it to 13 verify that table. He 's j ust using it as a single sample

() 14 point to check on how applicants did in their measurement of 15 that sample.

16 Could you tell me. Mr. Thonus, were all of the 17 measurements that you took in agreement with those that the 18 Licensee took or were there some disagreements?

19 THE WITNESS: (Thonus) In general they were in 20 agreement. Tne strontium was sort of marginally in 21 ogreement.

22 It was not strongly in disagreement by an order.

23 It was off by a factor of two. And there was some 24 radionuclides that didn't overlap in the analysis.

25 In other words, it wasn 't a one for ono

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370 correspondence in what the two laboratories analyzed for.

(vl i 2 JUDGE BLOCH: Was the only dis 6greement with 3 respect to the strontium 90?

4 THE WITNESS: (Thonus) It 's the only one that I 'm 5 aware of.

6 JUDGE BLOCH: And what was your conclusion as to 7 that particular disagreement since your purpose had to do 8 with verifying the data that was given to you?

9 What was your conclusion about that particular 10 disagreement?

11 THE WITNESS: (Thonus) Well, it could be caused 12 by any one of a variety of things.

13 But their number -- as it turns out the number

() 14 that they used in PEIS was higher than the number that we 15 used.

16 The assemptions that they submitted to us which we 17 then used in the PEIS were then conservative maybe by a 18 factor of two.

19 Their testimony has addressed why their numbers 20 might come out high.

21 JUDGE BLOCH: Did you hear the testimony 22 yesterday?

23 THE WITNESS: (Thonus) I didn't hear all the 24 testimon! yesterday but I heard it today and I 've also seen 25 the written testimony of Dr. Hofstetter and Mr. Harner.

(

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() 1 JUDGE BLOCH: Do you have a personal conclusior,as 2 to the reasons for the difference?

3 THE WITNESS: (Thonus) No, not a firm one. I 4 have several suspicions as to what they are. Any of the 5 beta analyses are going to be a little more difficult to do 6 with consistent accuracy unless you 're familiar and 7 practiced in the medium that you 're using.

8 JUDGE BLOCH: Can we infer anything about what you 9 think was the reason for the difference based on what you 10 just said?

11 THE WITNESS: (Thonus) Well, there are two 12 things. Well, first we 'll start with the GPU's number is 13 higher than ours.

TT And in their testimony, GPU tends, their system

(_) 14 15 tends to be conservative and they tend to overestimate.

16 There is also, they 're more f amiliar so that would 17 tend to bring our two numbers closer together to the point 18 of being no longer in disagreement, if their number was off 19 :)y the amount 40 to a 100 percent that they 're discussing.

20 The other thing is --

21 JUDGE BLOCH: Well, wait. You said you didn 't 22 have a personal conclusion and now I hear a personal 23 conclusion.

24 What happened between the first time and the 25 seiond time?

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() 1 THE WITNESS: CThonus) I 'm trying to get there.

2 That 's one possibility is that their -- if you just take 3 into account their conservatism and their techniques which 4 is their own, I guess, choice to err on the side of S conservatism and safety, that would bring you into the range 6 where the numbers no longer disagreed.

7 The numbers wouldn't be exactly the same. The 8 other thing is that there is some potentially some residual 9 zeolites in the sample.

10 And GPU Nuclear had at one point in time before 11 they became a little more adept at it, some difficulty.in 12 correcting for the possibility that the neolites may absorb 13 come strontium.

() 14 And our contractor laboratory may not have, early 15 on, been able to adapt their technique to that. They 16 probably used, you know, a standard method assuming it was a 17 standard sample without the interference of the zeolites.

18 JUDGE BLOCH: Now if I understand what you just 19 said, your laboratory might actually have underestimated the 20 amount of strontium?

21 THE WI"uESS: (Thonus) It 's possible that our 22 laboratory slightly underestimated the strontium and it 's 23 possible that most of the disagreement is f rom GPU 's 24 conservatism.

25 But in any case the number that we wound up ing Oa Heritage Reporting Corporation -

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373 1 in the PEIS was the more conservative numbers applied by

([ })

2 GPU.

3 JUDGE BLOCH: Do you have any reason to suspect 4 that the method used by GPU was inappropriate?

5 THE WITNESS: (Thonus) No. I don 't.

6 BY MS. SKOLNIK:

7 Q Your sample came f rom the PWST-2 tank. In what 8 way does that tank provide you with confidence that it 's 9 representative of all of the other tanks including the 10 reactor vessel?

11 MS. WOODHEAD: Obj ec t ion.

12 JUDGE BLOCH: Sustained.

13 MS. WOODHEAD:- That statement is not in the

() 14 testimony.

15 JUDGE BLOCH: They 're only checking the 16 measurement ability. They 're not checking actual samples.

17 They 're relying on the applicant 's, on the 18 Licensee 's measurements to know. That 's what the testimony l

19 clearly states.

20 The NRC is not relying on its own measurements.

21 They 're relying on the Licensee 's measurements.

22 And the only thing they did was to take this 23 single sample point which verified that there was agree nent 24 between what the Licensee did and what the NRC did, what the l 25 NRC 's cont ractor did.

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() i MS. SKOLNIX: Could I have a few minute break 2 please?

3 JUDGE BLOCH: How muchLtime do you need?

4 MS. SKOLNIK Three minutes.

5 JUDGE BLOCH: Okay. Let 's take a three minute 6 break in plece then.

7 MS. SKOLNIX Thank you.

8 (Whereupon, a short recens was taken.)

9 JUDGE BLOCH: Ms. Skolnik, are you ready?

10 MS. SKOLNIK Yes.

11 BY MS. SKOLNIK:

12 Q When you analyzed the sample, Mr. Thonus, for 13 tritium did you use liquid sentillation techniques?

() 14 A (Thonus) I didn 't analyze it. Our contractor 15 laboratory did. I would think that that 's the most likely 16 that they would use. But I can 't swear to that.

17 Q On page two of the testimony. you r;ake a reference

~

18 to a document EG and G PRS 6798. Could you just clarify for 19 me. should that be EG and G. PBS 6798 instead of or it would 20 be B7 21 MS. WOODHEAD: What paragraph are you referring 22 to?

23 THE WITNESS: (Thenus) I think she 's in paragraph 24 aix on page three, is that correct?

25

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[~')\ 1 BY MS. SKOLNIK:

w 2 Q Fifth paragraph.

3 A (Thonus) Fifth paragraph.

4 Q Answer to qt'.estion three.

5 A (Thonus) If that 's a typographical error I 6 couldn't -- that was a document which you had referred to.

7 Q Okay. So it was my, you got it from my reference?

8 A (Thonus) Yes. I believe it appears in the Board 9 order of August 25, 1988.

10 Q Okay. Well. that must be this document. EGG. PBS 11 6798 instead of R. Could you identify exactly what it is?

12 JUDGE BLOCH: May I just -- on my document it says 4

13 PBS.

(O

_j 14 MS. SKOLNIK: Does it? Mine says PRS.

15 JUDGE BLOCH: Okay. You just got a Xerox problem, 16 I think.

17 MS. SKOLNIK: Yes. On page two, answer three it 's

. 18 wrong. But there 's a PBS on page threa on question six in 19 the question.

20 Oh, okay. But we 're referring to the same 21 document, right? It should be PBS.

22 THE WITNESS: (Thonus) Yes.

23 JUDGE PARIS: Does anyone know, do the witnesses 24 know whether the document in question should be EG and G PRS 25 6798 or EGG PBS 67987 Heritage Reporting Corporation (202) 628-4888

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.() 1 JUDGE BLOCH: Just say whether you know.

2 JUDGE PARIS: You don 't know.

3 THE WITNESS: (Thonus) I don 't know. I was 4 trying to flip through the Board order here. On page 30 of 5 the Board order. it 's listed as PBS. I think it may be 6 referred someplace in the Board order as PRS.

7 But I don't have a copy with me.

8 JUDGE BLOCH: Ms. Skolnik, is this an important 9 matter for clarification?

10 MS. SKOLNIX: Well, in a way it is only because I 11 may make' reference to it in my conclusions and I wanted to 12 make sure that when I was talking about --

13 JUDGE BLOCH: To make a reference to it in your

() 14 conclusion, it has to be in evidence.

15 MS. SKOLNIK The document?

16 JUDGE BLOCH: Yes.

17 MS. SKOLNIK: Okay. Well, then when I 'm making 18 reference --

19 JUDGE BLOCH: You may want to get one of the 20 witnesses to verify that that 's what they 're referring to 21 and that they know that it 's on accurate document, j 22 It has to be something that will satisfy the Board i 23 that it 's entitled to be in evidence because it 's been 24 testified to. l 25 You can 't refer to documents outside the record.

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l 077 i i JUDGE PARIS: Do counsel --

("J L

2 JUDGE BLOCH: You can but we don't have to give 3 any weight to them.  ;

4 JUDGE PARIS: Do counsel for the Staff know what  :

5 this document should be called?

6 MS. WOODHEAD: No, I do not.

7 MS. SKOLNIK Well, if it 's referred to in the -

8 testimony, does it not automatically go into the testimony, 9 into the record?

10 JUDGE BLOCH: No, you can --

11 MS. SKOLNIK: The contents?

12 JUDGE BLOCH: You can show the document to the 13 witness and see if he recognizes if that 's what it 's a

() 14 referring to or not.

15 MS. SKOLNIK: Okay. ,

16 MR. BAXTER: It 's PBS.

17 JUDGE BLOCH: It is PBS? But still, there 's going 18 to have to be some way to get it in the record if you 're 1

19 going to refer to it.

20 MR. BAXTER: It would be my understanding that at  ;

21 least the witness ' testimony about it could certainly be 1 22 cited by all parties.

23 JUDGE BLOCH: Yes. the witness' testimony can be 24 cited. The document itself is not in evidence. l 25 MS. SKOLNIK Okay.

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() 1 JUDGE BLOCH: You can ask the witness if he 2 recognizes it and then ask questions about it.

3 MS. SKOLNIK: Okay.

1 4 BY MS. SKOLNIX: l

~

5 Q Mr. Thonus, do you recognize this document?

6 A (Thonus) I believe I recognize the document. A 7 copy I've seen before I believe is not a Xerox, but I 8 believe this to be the same document.

9 0 Is this the document to which you refer on page 10 two of your testimony in answer to question three?

11 A (Thonus) Yes.

12 JUDGE BLOCH: Now if there 's something in it that 13 you want to use, you 'll want to cross examine based on it.

()

I 14 MS. SKOLNIK: Yes.

15 JUDGE PARIS: And then this document then is EG 16 and G PBS 6798 TMI-2 Isotopic Inventory 'falculation?

17 JUDGE BLOCH: Mr. Thonus, is '. hat what it says on 18 the cover of the document?

19 THE WITNESS: (Thonus) Yes, it is. It 's listed

, i 20 as EG and G PBS 6798, dated August, 1985 1MI-2 Isotopic 21 Inventory Calculations.

22 JUDGE PARIS: Thank you.

23 BY MS. SKOLNIK:  !

i 24 Q Does this document contain data which was taken [

25 from comples of accident generated water?

i V

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() 1 MS. WOODHEAD: Obj ect ion. This document is not 2 sponsored by this witness.

3 MS. SKOLNIK: But it was referred to the witness 4 in his testimony.

5 JUDGE BLOCH: If the testimony of the witness is 6 about this document, it seems fair cross to me.

7 THE WITNESS: (Thonus) The part of it that I 8 reierred to did not have anything do do with any samples.

9 The part of it that I referred to, as I recall.

7 10 had to do with the computer prediction which was in that 11 document.

12 BY MS. SKOLNIK: ,

13 Q Mr. Thonus, do you use or the panel, do you use i

() 14 models of predictions for water samples, what might be in 15 the water? ,

(Thonus) 16 A I 'm not sure that I exactly understand 17 your question, but I 'm going to have a stab at it anyway.

18 JUDGE BLOCH: What 's the dif ficulty in 19 understanding the question? It seems fairly simple. ,

20 JUDGE PARIS: It seems to me the question would be 21 better stated, do you use models to make predictions? ,

22 THE WITNESS: (Thonus) Yes, that 's the question I i 6

23 was going to answer. We 've looked at the results of codes 24 like origin and LOR which would tell you the total inventory  ;

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380 l

} 1 the time of the accident.

2 And then you can from there try and maxe some 3 engineering estimates as to what percentage of those 4 radionuclides might be released to the coolant.

5 BY MS. SKOLNIK:

6 Q Do you feel that the use of models is important to 7 predicting the amount of radioactivity in water?

8 A (Thonus) It depends somewhat on how much f aith 9 you have in the original computer code. And how much f aith 10 you have in your model.

ii You can certainly, if you have good faith in the 12 computer code, you can use them as an upper bound.

13 The release fraction. I don 't have a terribly

() 14 great deal of confidence in on a number of radionuclides.

15 But again it depends on the specific radionuclide.

16 JUDGE BLOCH: Let 's narrow the inquiry to tritium l r

17 because that 's the one we 're primarily interested in.

J 18 Right? Let 's ask about the model with respect to tritium.

19 MS. SKOLNIK: Well, it 's also in respect to the 20 carbon 14 21 JUDGE BLOCH: Okay.

22 MS. SKOLNIK The testimony was directed to carbon 23 14.

24 JUDGE BLOCH: Okay. Those two.

25 MS. SKOLNIK: So it would be the two.

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() 1 THE WITNESS: (Thonus) What 's the question?

2 JUDGE BLOCH: How much faith do you have in the 3 models with respect to the predictions of carbon 14 levels?

4 THE WITNESS: (Thonus) I don 't think that, that 5 would be one of the ones that you could narrow within a 6 couple of percent.

7 The error for carbon 14 in that computer model 8 may be easily a factor of two off.

9 BY MS. SKt.NIK:

10 Q But you did use, did you use the predictions in 11 this document along with the RESL analysis for carbon 147 12 A (Thonus) Certainly what we used in the PEIS was 13 the number we got from GPU which was one times 10 to the

() 14 minus 4 microcuries per milliter.

15 Our sample showed a lower number than that. The 16 computer prediction also showed a lower number than that.

17 Did we absolutely rely on our lower number or the computer 18 number which was lower?

19 No. we didn 't. We used the higher number that was 20 supplied to us by GPU Nuclear.

21 Although thete is some evidence that the computer 22 mo tel can certainly be used as scoping even if you don't 23 know the -- well, there isn't a release f raction for carbon 24 ' i.

25 Q But you did not use the higher Westinghouse taodel?

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s.s 1 Could you explain why you did not?

e 2 A (Thonus) Well. the number that you had referred 3 to and the Westinghouse number was one of four samples taken 4 by Westinghouse.

5 And we didn 't. we wouldn't use the highest number.

6 And at the particular time that we did the PEIS. we didn 't 7 have the individual numbers from Westinghouse.

8 Now that we do have the individual Westinghouse 9 numbers at hand, if you ask me, would I change what we 've 10 done. I would say, probably not. I 11 We 're trying to use the best number for what 's the 12 average in the 2.3 million gallons.

13 Ar.d using the highest single result you have from

() 14 a given tank isn't necessarily representative. If I wanted 15 to be terribly conservative that would certainly be a valid 16 upper bound.  ;

17 I also talked to one of our other consultants and ,

16 asked. who will be up here later, what effect that would have on our dose calculations if I used the carbon 14 19 20 number. Is this a factor 3 higher?

e 21 JUDGE BLOCH: Well. let's have her testify about 22 that later.

23 (Continued on the next page.)

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( ';t/24 1 BY MS. SKOLNIK: f 2 Q Mr. Thonus, you just said that you didn't have the~

3 Westinghoune data, but the letter from GPU Nuclear presents 4 the Westinghouse data to the NRC in February, 1987. The EIS 5 document was printed in June or July 1987.

l 6 JUDGE BLOCH: Is that true?

7 BY MS. SKOLNIK:

8 Q Is that true?

9 A (Thonus) I would have to look that up. The 10 original number we got from GPU was in July of '86 and I 11 think that 's pretty much what our exposure estimates were 12 based on and then a February 18 letter which followed that 13 up.

() 14 JUDGE PARIS: Is this the letter reproduced on 15 Page A.43 and A.44 in the EIS?

16 (Pause) 17 THE WITNESS: (Thonus) You are correct that the.

18 I guess the EIS was in preparation at that time and probably I

19 we factored the final number of 1 times 10 to the minus 4 I

20 which was on their February 18 letter was the one that was  !

21 used. And I guess at the time the Staff did not consider it 22 unreasonable, given the four results that were above and 1

23 below that number, that that number be used as the average  ;

i 24 of them, weighted.

25 i

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(( ) 1 2 Q Okay. So you did have the higher Westinghouse  !

l 3 analysis prior to publishing --

4 A (Thonus) Prior to the final EIS going out. We l 5 had the one individual -- we had the results that indicated 6 there was one of the Westinghouse samples that was three 7 times 10 to the minus 4 microcuries per milliliter. That 's 8 correct. We also hed the information from our contractor 9 and f rom the computer predictions that said that GPU's 10 numbers may be conservative. In my earlier testimony I 11 alluded to the fact that doing isotopic analysis on pure 12 beta admitters is quite difficult. It 's more of a chem

  • Jtry 13 problem than it is a physics problem.

() 14 JUDGE PARIS: Is the isotope you are talking about 15 tritium or C-147 16 THE WITNESS: (Thonus) We 're discussing C-14.

17 JUDGE PARIS: Thank you.

18 THE WITNESS: (Thonus) So you have to have a very 19 good way of making sure that you get the C-14, you don 't get LO any interfering. Once you do your counting, you really 21 don 't know all that well what you 're counting. You 're j ust 22 counting beta counts. Whereas if you 're doing gamma 23 spectrometry. you have a much more accurate fingerprint to 24 tell what you 're doing.

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() 1 BY MS. SKOLNIK:

2 Q You say in your statement in answer to Question 3  ;

L 3 Page 2 -- three lir.es below what we were just talking about.

4 A (Thor.as) Yes.

i 5 Q You have that? Okay. And you say: In any event, 6 carbon 14 is a relatively minor contributor to exposure.

7 Are either of you radiation health physicists?

e 8 A (Thonus) Yes, I -- I am.

9 Q Okay.  ;

10 A (Thonus) I 've b' en a member of the Health Physice 11 Society since 1972 It 's on my statement of qualifications.

12 Q What is the dose from carbon 14 from the average 13 in Table 2.27

() 14 A- (Thonus) I think I'd have to defer to Linda 15 Munson when she gives her testimony. She is the one who did 16 our actual dose calculations. I did not actually crank the 17 numbers through the system.

18 Q But you do feel confident in saying that?  !

19 A (Thonus) I feel confident in her abilities, yes.

20 And I discussed the answer with her before I started down i I

21 here.

22 JUDGE BLOCH: Mr. Thonus, are you familiar with l 23 the whole proposal thet the licensees have made?

24 THE WITNESS: (Thonus) Yes, I am.  ;

25 JUDGE BLOCH: What would be the consequence if the O Heritage Reporting (202) 628-4888 Corporation s

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() 1 C-14 levels were ten times what they were estimated to be?

2 THE WITNESS: (Thonus) I guess I 'd let Linda give 3 you the specific numbers but if they were a factor of 10 4 higher it would not alter our conclusions.

5 JUDGE BLOCH: Would the release to the public be 6 different?

  • 7 THE WITNESS: (Thonus) It would somewhat depend 8 on the chemical form. I think that a large fraction of the

, 9 carbon 14 would not be released as the tritium would be. I 10 think the evaporator, if it 's carbon dioxide it 'll go out.

11 If it 's carbonate or sotae other form, it would tend to --

12 JUDGE BLOCH: Are you an expert on what percentage l

13 would actually be removed by the evaporator?

l

() 14 THE WITNESS: (Thonus) No. Well, I don 't have l 15 the chemical analysis of how much of it is CO2 versus 16 carbonate versus organic, at this point in time.

1

, 17 JUDGE PARIS: But the point is it 'll come of f as a 18 gas only as CO2 Otherwise, if it 's a carbonate, it will be f 19 precipitated out?

j 20 THE WITNESSt (Thonus) Yes.

l 21 BY MS. SKOLNIK:

22 0 As a Jos, though, doesn 't it enter our food?

- 23 Wo n ' t it, if it 's released into the atmosphere, does n 't it 24 accumulate in our food?

25 MS. WOODHEAD: Obj ec t ion. Mr. Thonus ' testinony O Heritage Reporting Corporation (202) 628-4888

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() i is about one sample the NRC took to verify the Licensee 's 2 data. He has not gone into testimony about the activities 3 of different radioisotopes.

4 JUDGE BLOCH: Sustained.

5 BY MS. SKOLNIK:

6 Q When you formulated the Ehr Table 2.2 --

7 MS. WOODHEAD: Obj ec t ion. .This is not his 8 testimony.

9- MS. SKOLNIK In answer to the questien in your 10 testimony, it states that the NRC assumes that the 11 concentrations of rtdionuclides can reasonably be considered 12 a maximum, and upon this assumption based its dose 13 calculations. I was Coing to cross examine on that

() 14 particular question, 15 JUDGE BLOCH: Ask the question. Let 's see what 16 happens.

17 MS. SKOLNIK Okay.

18 BY MS. SKOLNIK 19 Q When you formulated Table 2.2. "Environmental 20 Impact Statement Supplement Number 2." were you --

21 MS. WOODHEAD: Obj ec t ion. Mr. Thonus did not do 22 the calculations that developed into Table 2.2 He has 23 testified to that twice.

24 JUDGE BLOCH: Well, to the extent that he 's 25 testified about them being maximum values, it 's proper Heritage Reporting Corporation (202) 628-4888

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%/

1 cross. So what 's the question?

2 BY MS. SKOLNIK:  ;

3 Q Do the maximum values in Table 2.2 reflect the 4 kr )wledge that GPU intended to process some of the 40 5 ;r tent of the water going into the evaporator would not be 4

6 pu. through EPICOR SDS? f 7 A (Thonus) I 'm having dif ficulty. Could you l 8 rephrase the question?

I 9 Yes.

Q I 'm sorry. I realize it must have been 10 difficult. When you formulated Table 2 -- when Table 2.2 11 was formulated, at that time did the NRC bnow that the 12 Licensee may use the evaporator to decont aminate 40 percent 13 of the water?

() 14 A (Thonus) Well, I didn 't f ormulate Table 2. 2. but -

15 I think I could safely say that the NRC did not know the 16 details of the evaporator design and Table 2.2 is assumed t

17 influent radionuclides to a generic evaporator that we ,

18 didn't know the details of the desian of yet. As it turned 19 out, as we have seen the final or more toward the final (

l 20 design, the engineering of it is such that it would probably 1

21 provide a much greater decontamination factor than we had j 22 assumed and that there would be a 1cwer radionuclide  :

23 release. But at the time those evaluations were made, we i

(

24 didn 't have all that detail.  ;

25 Q So the table was based on the assumption that the {

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v. iter would all be processed through EPICOR to SDS?

A (Thonus) I think tha table is labeled and there 's l

3 two columns in there. One assunes 4G .3ercent reprocessing  ;

4 and one is 100 percent.

S Q Through EPICOR SDS7 6 MS. WOODHEAD: Mr. Chairman. Ms. Munson will be  ;

7 presented as a witnese later and she did indeed do most of  ;

8 the work in developing the PEIS. Mr. Thonus is aware of 9 data going into it, because of his job assignment, but his 10 testimony is related to a very narrow issue, and we 've 11 gotten far beyond that. We are getting irto the contents of -

12 the EIS. Mr. Thonus is only testifying about a small sample ,

13 that the NRC took to audit the licenset 's data. He does

() 14 refer to the EIS. but he did nat write the EIS. It is an 15 exhibit or a document that he relies on. But the witness 16 for the document itself was Ms. Munson, not Mr. Thonus. ,

17 JUDGE BLOCH: Well. I guess the cross is about the 18 meaning of the answer to Question 4. And I did allow it.

19 And I think there 's a limit to how much you want to go into i

20 it, but I think that the laat question as I heard it was l 21 okay.

j 22 THE WITNESS: (Thonus) We 've gone a little bit in j 23 a circle. Could someone j ust restate the question for me?  ;

l 24 I think I understand it but I j ust want to make sure I 'm i 25 clear, h Heritage Reporting Corporation (202) 628-4888 l l

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1 MS. SKOLNIK: Okay.

2 BY MS. SK0LNIK:

3 Q Is it true that Table 2.2 EIS is based on your 4 belief that all the water would go through EPICOR to SDS and 5 that those values reflected in 2.2 would be achieved by 6 EPICOR SDS?

7 A (Thonus) Not necessarily by EPICOR SDS. The 1 l

8 table says that that woula be achievable. GPU could use for 9 instance another system that they have, the DWCS 10 demineralize. They could use any system to achieve the 11 numbers. We 're looking at curies and if they were to bring 12 in some other contractor with some other system to achieve 13 those same numbers, we wouldn't have any obj ection to

() 14 whatever filters or demineralizers or other process that 15 they use as long as they achieve. they were within the 16 values that we have assumed in the Environmental Impact  ;

17 Statement. ,

i 10 Q However. didn't you base these concentrations not 19' only on samples but also on the operating hintory of EPICOR 20 SDS?  !

21 A (Thonus) The numbers that you 're referring to l

22 were submitted to us by GPU. I 'm sure that those numbers 23 are credible and we have knowledge that their systems are i 1

24 capable of achieving that. I 'm not sure if that answers 25 your question. But I think it does.

i i

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391

() 1 Q It doesn 't, because --

2 JUDGE BLOCH: Ms. Skolnik, maybe you could clarify ,

1 3 it for me. Why does it natter so much to you whether it 's j 4 by EPICO" SDS or some other way that the-/ get it down to l 5 that level?

6 MS. SKOLNIX: Well, the EPICOR SDS system has 7 already been proven. It 's already been shown to work. So ;

8 if we evaluated this table on the basis of past history of 9 EPICOR SDS, and then the licensee is coming along and saying 10 well, no, maybe we won't be using EPICOR SDS, obviously then 11 what we need validation, we have no validation at this tims 12 that the evaporator, there 's no operating history of the 13 evaporator to show that thase values can be achieved.

() 14 MR. BAXTER: I would submit. Mr. Chairman, that 15 the decontamination factor of the evaporator, was raised and 16 decided by the Board under Contention 4(b). So that is an 17 issue that has already been discussed in this proceeding and 18 that is its ability to remove particulates by a factor of 19 1,000. The Board found that reasonable and no material 20 issue to remain. So the ability of the evaporator as 21 opposed to EPICOR-2 or SDS to process the water as a pre-22 treatment technique has been raised and has been already 23 addressed and decided.

24 MS. SKOLNIK Well, I 'm glad that was brought up 25 because in the GPU letter which we received last week it did O Heritage Reporting Corporation (202) 628-4888

b 392  ;

() i say that the Board endorsed a decontamination factor of 2 1.000 But my interpretation of >vur order was not that it 3 endorsed a decontamination factor of 1.000 meaning a one ,

4 time through. I thought that you had said in there tisat our

{

S concerns were unwarranted because the evaporator could keep ,

6 putting the water through as many times as needed to achieve [

7 the levels that were needed for the influent to the t

8 evaporator. And that is different.

r

. 9 MR. BAXTER: It is different.- But that 's not the 10 point we*re talking about. either. That 's another part of i 11 the ruling. You 're correct. They did say that. To the 4

12 extent that there was more, it had to be run through more '

13 than once to get more than 1.000 particulate release in f

() 14 order to meet the influent criteria, it cout.d be done. But 10 the fact that it could achieve that decon' amination factor  !

4 >

16 is precisely what you raised in Contention 4(b) about the l 17 capability to remove radionuclides and was decided by the 18 Board on the merits.  ;

19 JUDGE BLOCH: To be : lear, when you say we endorse 20 something. what we found is that there was no genuine issue .

21 raised in the record. And you haven't raised any genuine 22 issue about the ability of the evaporator to do that. And  !

, 23 by repeating it, you don't lend any additional credibility t

24 to it. There really is no question on the record that the j

! 25 evaporator can reduce the radionuclides by very large {

i t l

I

! Heritage Reporting Corporation i (202) 628-4888

1 393

() i factors. And so there is no issue here about substituting 2 the evaporator for EPICOR SDS.

3 (Pause) 4 MS. SKOLNIK: Please clarify for me. did the Board 5 endorse a decontamination factor of 1,0007 6 JUDGE BLOCH: We said there was no genuine issue 7 about that because there was evidence that it occurred and 8 you had no evidence against it.

9 MR. BAXTER: Page 40 of the Board 's Memorandum and 10 Order lists the Joint Intervenors' material statements of 11 fact challenging the decontamination factor. The Board 12 found no material issue and resolved that part of the 13 contention.

() 14 MS. SKOLNIX: Could you repeat that reference.

15 please?

16 MR. BAXTER: That entire page has numerous 17 challenges by your organization to the decontamination 18 factor. The Board discussed it for the next few pages and 19 ruled that there was no genuine issue left on Contention 20 4(b) except for the alleged typo in the bid document.

21 MS. SKOLNIK: I 'm still. I 'm not sure. On Page 71  ;

22 of the Judges' Order -- ,

23 MR. BAXTER: This is discussing the contentions on 24 chemicals.  !

26 JUDGE BLOCH: What page are you citing. Mr.

f I Heritage Reporting Corporation l

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() 1 Baxter?

2 MS. SKOLNIX
Right. But that 's still referring ,

3 to the decontamination factor. ,

4 JUDGE BLOCH: Let 's see the page that Mr. Baxter ,

S :s citing. What 's the page?

6 MR. BAXTER: Well. the Board 's discussion begins ,

7 on Page 39. Contention 4(b) about the capability of the 8 system to remove radionuclides. The Joint Intervenors ' '

r 9 statements of material fact are quoted on Page 41. including ',

i 10 challenges to the decontamination factor of 1.000 in  ;

i 11 material statements of fact 2. 3. And the Board ultimately 12 holds --

13 JUDGE BLOCH: Page 42 just before Number 4 -- l

() 14 ML BAXTER: -- that there is no genuine issue. l

, 15 JUDGE BLOCH: "We therefore find no issue exists l 16 here."

4 17 MS. SX0LNIK: I had interpreted that to mean, and 18 you can correct me if I 'm wrong, that there 's on genuine 19 issue involved in whether or not the evaporator can achieve 20 certain levels.

21 JUDGE BLOCH. That 's correct. And why would there 22 be any genuine issue as to whether it does it once through 23 or ten times through?

24 MS. SKOLNIK: Well, it 's important if the water 25 has to go through once or ten times.

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, _ - , _ , . , . _ _ _ _ _ _ _ - _ _ _ , . _ _ _ . . . ~ _ , _ . _ _ . .

r.

1 395 l() i JUDGE BLOCH: 'Because what?  ;

2 MS. SKOLNIK: Because of cost, occupational  :

3 exposure, the amount of time that it would take, possible f 4 accidents. l 5 JUDGE BLOCH: Do you have an issue on occupational 6 exposure?

7 MS. SKOLNIK Yes. i 8 JUDGE BLOCH: That 's still in this case?

l 9 MS. SKOLNIK: Well, i t 's i n -- no . I will be cross j

10 examining --  !

i 11 JUDGE BLOCHi I don't think there is an issue on 12 occupational exposure that you have in this case.  !

13 MS. SKOLNIK: There is testimony advanced by GPU {

() 14 Nuclear concerning occupational exposure in relation to the

, 15 no-action alternative and the evaporation, there 's a

{ 16 comparison between the two. t f

17 JUDGE BLOCH: Yes, you are going to be questioning i 18 their statements on that, that 's correct. So what you are  ;

19 trying to question now is whether it can be done once (

I 20 through or more than once through? l l

i 21 MS. SK0LNIK Yes. It 's extremely relevant 22 whether or not the Board has endorsed a decontamination 23 factor of 1.000 or on the other hand if they say the water ,

24 can be pretreated to the point of achieving a certain level. l 25 MR. BAXTER: I think it 's unambiguous that the [

F Heritage Reporting Corporation l (202) 626-4888 L  ;

i

. c _.

396 1 Intervenors were challenging the decontamination f actor and

({ 2 that the Board on Page 42 found there is no litigable issue. 3 None of the testimony is addressed to the Board in defense 4 of that f actor because it 's been decided. 5 MS. SKOLNIKi So there 's no material issue as to 6 whether or not a decontamination factor of -- wait a minute. 7 now. Strike that, please. 8 There 's no material issue as to whether or not the 9 evaporator can eventually achieve certain levels? 10 MR. BAXTER: That 's not the ruling. 11 JUDGE BLOCH: The ruling was that Contention 4 12 raised no litigable issue, and Contention 4 says: 13 "Sufficient evidence has not been provided to ensure that () 14 the evaporator can filter out other radionuclides as well as 15 chemicals to protect the public health and safety." There 's 16 more to it. But we said there 's no 1* sue there. That 's 17 clear. 18 MS. SKOLNIK: Okay. But is that based on your 19 endorsement of a decontamination factor of 1.000 or is it 20 based on your belief that the water can keep going through 21 in numerous cycles to reach a certain level of ) 22 decontamination? It's two different things and it 's 23 extrenely relevant to the hearings. 24 JUDGE BLOCH: What is the question you 're trying 25 to ask here? What are you trying to pursue with this Heritage Reporting Corporation (202) 628-4888 4

397 (]) 1 witness? And .why is it an issue in the hearing? l' 2 MS. SKOLNIK: Well, it 's an issue because -- i 3 JUDGE BLOCH: First, before you say that, what is 1 i 4 the subj ect matter that you're trying to pursue? 5 MS. SKOLNIK: I 'm trying to pursue whether or not

                                                                                                                                )

6 the maximum concentration of the influent to the eve,*srator l 7 is reflected accurately in Table 2 2. 8 JUDGE BLOCH: The maximum concentration of carbor 9 147 10 MS. SKOLNJK: Of carbon 14 and tritium. Tritium, 11 okay, tritium won 't mat ter. 12 JUDGE BLOCH: The tritium won't be reduced by the 13 evaporator. It will be the same coming out. Carbon 14 () 14 will. We held that. The evaporator will reduce it to the 15 levels for influent in this, to the influent levels that are 16 set in that table. 17 MS. SKOLNIK: Yes. I 'm not disputing, at this 18 point I 'm not disputing that it will reduce it. What I 'm 19 disputing is, are you saying -- 20 JUDGE BLOCH: How many times it has to go throuch-21 MS. SKOLNIK: Yes. 22 JUDGE BLOCH: Do you know the cost of putting it 23 through another time? l 24 MS. SKOLNIX: I'm hoping the Licensee can answer l 25 that when their witness comes forward. l l Heritage Reporting Corporation (202) 628-4888

398 1 JUDGE BL CH: Why don't you ask the witness who ({]) 2 knows. 3 MS. SKOLNIX: Yes. Well. I'd like to ask the 4 witness who knows but there are certain statements made by 5 these witnesues too which I feel I still need answered. I 6 don 't f eel I 've got a proper answer yet as to whether or not 7 this table adequately reflects the maximum concentration of 8 the influent into the evaporator. 9 JUDGE BLOCH: Ms. Woodhead. I'm inclined to strike 10 this particular answer. I don 't see why we need it. 11 MS. WOODHEAD: I don 't either. I 'd prefer that it 12 be stricken. 13 JUDGE BLOCH: We 're going to just strike that () 14 whole question and answer because it 's beyond the expertise 15 of this witness if that 's acceptable to you. 16 (Continued on the next page) , 17

        .g l        19 20 l        21 22 23 24 25 O-                     Heritage  Reporting Corporation (202) 628-4888

399 j ) i MS. SKOLNIK: The question and the answer will be 2 struck? 3 JUDGE BLOCH: Correct. 4 MS. SKOLNIK: Okay. 5 JUDGE BLOCH: That 's Question and Answer 4 on Page 6 2. 7 MS. WOODHEAD: May I make a correction, Judge 8 Bloch? The paragraph designated as (4) is one of the issues 9 admitted for litigation. It is not my original question. it 10 is an issue admitted for litigation. 11 JUDGE BLOCH: Isn 't Ms. Munson -- excuse me, nor 12 Ms. Munson -- yes -- Ms. Munson -- going to testify about 13 this? Isn't she the expert on it? () 14 MS. WOODHEAD: She is the greater expert. But as 15 the material statements of fact of the Intervenors were put 16 together in the Board 's Order admitting certain issues under 17 Contention 3, this particular statement was in there. So t 18 there is a redundancy between the testinony of Mr. Thonus 19 and the testinony of Ms. Munson. And you are correct. Ms. 20 Munson is the better witness. 21 But I do want to point out that this is one of the 22 issues admitted in the Board 's oldor. 23 JUDGE BLOCH: Yes, but it 's not being struck 24 because it 's irrelevent. It 's being struck because the 25 witness doesn 't hat - .treet knowledge of the testimony. It Heritage Reporting Corporation (202) 628-4888 l

400 ('] 1 wasn't his field of expertise. 2 MS. SKOLNIK: And so.then the question will go to 3 Ms. Munson. Thank you. 4 Could you tell me what time lunch is at? 5 JUDGE BLOCH: When it 's comfortable to take a 6 break. Are you asking for lunch to be now? 7 MS. SKOLNIK: Yes. I would like lunch. Yes. 8 JUDGE BLOCH: Let 's go of f the record. 9 (Discussion off the record) 10 JUDGE BLOCH: Why don't we take a one hour lunch 11 break and return at 1:00 O ' clock? 12 (Whereupon, at 12:00 Noor, the lunch recess was 13 taken, the hearing to reconvene at 1:00 p.m. the same day. () 14 Tuesday November 1, 1988, at the same location.) 15 16 17 18 19 20 21 22 23 24 25 t

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i 401 1 A F .' 2 R N O O N SESSION  ! f] 2 1:00 p.m. L 3 JUDGE BLOCH: Good ofternoon. Ms. Skolnik. 4 MS. SKOLNIX: Yes. ' S Whereupon, f 6 LEE THONUS 7 MICHAEL MASNIK  ! 8 having been previously duly sworn, were called as witnesses 9 herein and were examined and testified as follows:  ; 10 MS. SKOLNIK Excuse me, please. i 11 JUDGE BLOCH: Ms. Skolnik. you are excused but we l 12 would prefer that you do the shuffling before the session 13 starts instead of after. () 14 MS. SKOLNIK: I know. I thought I had everything 15 sitting in front of me. 16 CROSS EXAMINATION (RESUMED) j 17 BY MS. SKOLNIK: 18 Q The question will be directed to your answer on  ; 19 page three to question six. It refers to the tritium source l I 20 term? [ 21 A (Thonas) Yes.  ; 22 Q Could you clarify for me when you say the other  ! 23 numbers are not too inconsistent with the 1.020 curies used { t l 24 in PEIS Supplement Number Two. do the other numbers include j 25 the tritium inventory of 8,794? I i r l O' Heritage Reporting Corporation j (202) 628-4888 i I l

402 f~) i A (Thonus) I think what you 're referring to is that s-2 there are more than one number for the amount of curies that 3 would have been in the core at the time of accident. 4 The number that has the 8.794 is not necessarily a 5 number that I would endorse. 6 I believe that the source of thut number was 7 brought up during discovery. It 's my understanding that the 8 basis of why that number came out so high was that it 9 assumed that there was a large amount of lithium containment 10 in the fuel. 11 In either case. if you believe the accuracy of the 12 computer models for this particular isotope, they should be , 13 relatively good since it 's a relatively common and well () 14 known and well documented isotope that you would have 15 something between 4.000 and 8.000 curies at the time of 16 shutdown. 17 And then there would be a certain amount of that, t 18 that would be released. As my testimony says, hydrogen 19 reacts chemcially with circle life forming nerchonium 20 hidrites. 21 And what we know is out of what was released that 22 there is still 1.020 curies approximately in the water. 23 Now you con draw your own conclusions as to 24 whether you want to believe the 4.000 curies which I think 25 is more accurate of the two numbers or the 8.006 curies O Heritage Reporting Corporation (202) 628-4888

403 (]} i which seems to be a rather conservative overestimate. 2 If you want to choose the higher number, one then 3 could conclude that the release fraction was lower. 4 Q What determines the occupancy of the 4.000 figure 5 or the 8,000 figure? What criteria would you use to l 6 determine that ? j 7 A (Thonus) Well. they used two different inputs, t i 8 it 's my understanding. I didn't write either of those , i 9 documents.  ! 10 But as I understand it there were two different i 11 inputa to the computer code one of which used what I think , L 12 would be a gross overestimate of the amount of lithium that l 13 was a containment in the uranium dioxide fuel which leads () 14 you to a much larger tritium inventory than I think a l 15 reasonable person would believe. But it perhaps doesn 't 16 matter. i 17 JUDGE BLOCH: Which one of them made that 18 assumption? i 19 THE WITNESS: (Thonus) The 8. 794 i 1 20 JUDGE BLOCH: They assumed more lithium than -- 21 THE WITNESS: (Thonus) They assumed the maxiu,um f l 22 allowable lithium as an impurity in the manufacturing l I l 23 process which wouh t couple of parts per million. f i 24 You know, tnere 's no evidence that anyone knows of 25 it. There was any particular number of lithiums present. [ l I i O Heritage Reporting Co rporat ion (202) 628-4888  ; I l I

404 1 JUDGE BLOCH: How did the other model deal with . i 2 the lithiuia? i 3 THE WITNESS: (Thonus) Well. neither model is , 4 mine. I believe the other model did not account for lithium . 5 in the fuel. 6 It would have accounted for anything in the 7 primary coolant but not in the fuel itself.  : 8 JUDGE BLOCH: So why not assume that the other  ! 9 model was not conservative enough instead of the 8.000 -- l 10 The one accounted for more lithium perhaps in 11 setting up the limits that was there and the other forgot 12 atout the lithium. L 13 THE WITNESS: (Thonus) Well, the other one. I I O 14 de ieve she one w11h the 4.000 ceries mex heve hed some  : 15 traced number of parts per million, but I didn't develop 16 I cither number. i 17 I couldn 't be sure to whether it had -- p ? i

18 JUDGE BLOCH
So really what you testified from

( 19 knowledge rather than belief. Do you know whether or not it [ l 20 used any amount at alI? 21 THE WITNESS: (Thonus) I couldn't tell you if it l 22 used any lithium or not. I did an independent calculation.  ! 23 Predominant tritium production normally is from curinary l 24 fission or approximately one in every 10.000 fissions 25 results in the production of a tritium atom. . i l l  ! O Heritage Reporting Corporation t (202) 628-4888 l 1

1 405 i And that 's the model that I'm more f amiliar with. 2 You con either do a hand calcuation or you can do an origin. i 1 3 And I did a hand calcuation to check on the origin

                                                                                                                                                  )

4 and my number came out relatively close to the 4.000 number. ) 1 5 And I guess the crux of my testimony is that, i l 6 whether you assume 4.000 was in the fuel at the start of th) l 7 accident or 8.000, what we are really trying to do is l 8 measure how much is in the water that's evaporated,

                     .                                                                                                                            j l

9 If you assumed that there was 8.000 there then I 10 guess you would just assume that there was a correspondly 11 lower release fraction during the accident. l 12 JUDGE BLOCH: But at this time what use. if any, j 13 do you want to make of the source term calculation? O 14 THE x1TsesS. crhonue> weil. 1her would de urger 15 bounds. I'm not --

                                                                                                                                                  ]

16 JUDGE BLOCH: When you have measurements. why do 17 you want upper bounds? 18 THE WITNESS: (Thonus) That's exactly cur point. j 19 Ms. Skolnik is the one who is bringing in the higher I l 20 numbers. These questions didn't come originally f rom the ' 21 staff. 22 JUDGE BLOCH: Okay. Well, one thrust of Ms. 4 I 23 Skolnik 's question so f ar is the possibility that it is l l 24 important -- because there could be a hioden source of this 25 radioactivity somewhere in the plant that's going to be i O Heritage Reporting Corporation (202) 628-4886 i i 1

1 i 406 * () i released. Is that possible? 2 THE WITNESS: (Thonus) It is possible that there 3 is some tritium that is still bound up with =ercoloid. And 4 if you were to go in there and do comething that would 5 either chemically or physically separate the hydrogen from 6 the =1rconium, you could liberate additional tritium but you 7 would have to have a very dramatice process to do that. 8 There 's nothing in the Licensee 's proposal that 9 would -- nor have any of the cleanup activities to date 10 resulted in any additional release of tritium one has been 11 able to see on primary coolant sample analyses. 12 JUDGE PARIS: The loose core debris has already 13 been removed f rom the reactor vessel. hasn 't it? () 14 THE WITNESS: (Thonus) Approximately 68 percent 15 of it has been removed. 16 JUDGE PARIS: Where would the tritium be? Would 17 it be in the crust or in the molten material? 18 THF WITNESS: (Thonus) It would be in the 19 cladding. 20 JUDGE PARIS: In the cladding. Okay. 21 JUDGE BLOCH: If I hear you correctly, it wouldn't 22 be in the form of tritium right now, is that right? 23 THE WITNESS: (Thonus) Well. it would be tritium 24 but it wouldn 't be tridiated water. It would be, nirconium 25 hydride would be the most likely chemical form of all. O- Herituge Reporting Corporation (202) 628-4888

407 () i Given the temperatures that were experienced 2 during the accident, there may be some chemical or physical 3 phenomena that the scientific community is not familiar with [ 4 where it could be in some other form. 5 But the normal form of that tritium would be I G =1rconium hydride, i 7 BY MS. SKOLNK: 8 Q So there is still 32 percent of the fuel to be 9 removed and that fuel contains the =irconium? f 10 A (Thonus) That 's a little bit misleading. It 's l 11 not associated with the fuel. In all likelihood, it 's  ! 12 associated with the cladding. if indeed it is there. - 13 Q Is the cladding the cover around the fuel rods? () 14 A (Thonus) Yes, it is. 1S Q So if 68 percent of the fuel is gone, there is t 16 still 32 percent of the fuel remaining with the cladding? I 17 A (Thonas) No. The portion of the fuel that 's ' 18 remaining doesn't seem to have very much cladding associated i i 19 with it. I i 20 Out of the -- I 'm not sure that I have a precise  ! 21 number for you but a higher percentage of the cladding has f 22 been removed than the percentage of the fuel that 's been f 23 removed. h i 24 Q Have you -- f l 25 A (Thonus) The 68 percent of the fuel that has been  ! l l i

O Heritage Reporting Corporation F

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408 ' () i removed has probably incorporated somewhat more than 68 2 percent of the cladding with it. j 3 So if any of that hydrogen existed as circonium j 4 hydride, more than 68 percent of it would have been removed f 5 at this point, t 6 JUDGE PARIS: That 68 percent was the loose core . I 7 debris? , L 8 THE WITNESS: (Thonus) 68 percer* is total mass , 9 including fuel, cladding. the structural components and then P 10 associated odds and end loose tools that people would drop. ' 11 We threw in. I guess, a little bit of a fudge l< 12 factor to come up with 300.000. The actual number. I think. l 13 came out 293.000 () 14 But every now and again, they dropped a tool or  ! 15 they cut a piece of structural steel that adds to that mass [ t 16 and in our, the staf f 's estimate. it came out 300.000 poundt  : 17 of fuel. . 18 BY MS. SKOLNIK: [ l 19 Q When the fuel is leaving, the fuel that you have j 20 removed from unit 2, that 's been taken out from Three Mile f i 21 Island, do you measure the percentage of circonium cladding l I 22 that was going out with the fuel? t 23 A (Thonus) No. no one does that. 24 Q So, do you have eny table to which you can refer }; 25 to which tells you the amount of airconium cladding which i l, O' Heritage Reporting Corporation (202) 628-4888 L i i

r r 409 , () i has gone on the amount that is left? ( Tho, tu s ) I don 't have a tab'.e to refer to, no. a t 2 A 3 Q Do you have any basis upon which to make a [ 4 statement about the amount of zirconium cladding left in the i 5 reactor vessel? 6 A (Thonus) I didn't quantify it deliberately. The 7 6:ssis for that is my own visual observations during de-8 fuel.ing. 9 JUDGE BLOCH: Ms. Skolnik. you might want to ask 10 soms questions that would establish why it 's important to 11 know the exact percentage of =irconium. I don 't see that 12 yct. 13 BY MS. SKOLNIX: () 14 Q You say that there could be tritium bound up in 15 the circonium cladding? 16 A (Thonus) Yes, that 's possible. 17 Q Is there any way in which you can determine the 18 amount of tritium in the =irconium cladding? 19 JUDGE BLOCH: Ms. Skolnik, the testimony was that 20 if it is bound up with the cladding, it 's in a stable 21 chemical compound. That it would be very difficult to 22 dislodge it. 23 MS. SKOLNIK: Okay. 24 BY MS. SKOLNIK: 25 Q It 's true that decontamination of the reactor O Heritage Reporting Corporation (202) 628-4888 1 l I

410 () i vessel is continuing? 2 A (Thonus) Yes. that 's true. j l 3 Q Is it also true that a lot of the procedures which i 1 4 will be needed to complete the cleanup have not yet been j i 5 dovised? l 6 A (Thonus) I would say that that 's true. There are 2 7 some procedures that have yet to be developed. 8 Q Is it also true then following from that, that [ i 9 perhaps some procedures could change the chemical form of l 10 tritium so that it would be released into the water?  ! L 11 A (Thonus) I would think that, that .,ould be very  ! l 12 unlikely. That would probably be a pretty strong chemical l 4  ! 13 reaction to do that. ,

() 14 Q Is it possible?

i

15 A (Thonus) I 'm not sure. I 'm not en expert on the i i

l 16 disolution of fuel cladding although I'm sure that it 's  ! 4 17 possible. 18 I mean there was an operating plant at West Valley ( ] 19 where they dissolved fuel pinn at one point in time. I

,                                                                                                f 20            So I'm sure that it 's possible to dissolve                                  ;

i 21 ercoloid. It 's been done with highly concentrated acids. f; 22 JUDGE BLOCH: Will one of Licensee 's witnesses be { t 23 able to testify on the criteria for the cleanup procedures [ i 24 that are being developed? j 25 Is there someone who this question could be put to  ! r

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ll l 411 [ 1 later?. f 2 MR. BAXTER: I believe that Mr. Buchanan probably [ 3 can answer the question. I haven't asked him particularly. 4 We weren 't anticipating -- t 5 JUDGE BLOCH: Well, the question has to do with 6 whether or'not -- r 7 MR. BAXTER: Exploration of the rest of the T 8 defeuling program. , S 9 JUDGE BLOCH: Do you know if he knows about what f 10 would be the properties of =irconium hydride? He doesn 't. 11 So he 's not the right person.  ! 12 What 's the basis for your belief that the 13 procedure probably won't dislodge the zirconium hydride? O 14 Tae W1TuesSt <rhonue> Wen. 1he types a ininge f 15 GFU needs to do to get the fuel out are mainly mechanical, j i To separate the zirconium from the =irconium 16 17 hydride would involve a -- vell, I'm not again an expert on 7 l l 18 the disolution of =irconium. l 19 We do have a limited body of experience on l 3 20 dissolving fuel. And they have typically used very, very l

                                                                                                                                                                                                    }

i 21 strong acid.  ; 22 And there may be a simplier easier way of doing i 23 that but I'm not in the fuel reprocessing business.  ! f 4 JUDGE BLOCH: So providing that the Licensee does l \ i l 25 not use strong acids in the cleanup that won't dissolve the i I Heritage Reporting Corporation f l (202) 628-4888  ? f _ _ _ _ _ - _ _ . _ . _ _ _ _ _ _ - _ _ . - - _ - _ - _ _ - _ - - - _ _ . - - _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ ____ _____ - -t

412 l

 ]                                                   1 2
                                                       =irconium hydride, do you know that as a fact?

THE WITNESS: (Thonus) Well. I guess you could f 3 say I do not know that as a fact. The only methods that I l 4 ara f amiliar with for the dissolutior, of fuel are something i c 5 like the Pure X process. l 6 If there is indeed a process out there that they 7 would want to use that's unique and novel, they would hsve [ 8 to submit that to us and we 'd have to evaluate it. 9 To the best of our knowledge -- h 10 JUDGE BLOCH: We'lI want some kind of assurance 11 somehow that the =1rconium hydride won't be dissolved and 12 accidentally released tritium. That 's one thing we would  ! 13 like to have. O 14 THe wit"ess' <Thonus) I m sure Geu couid eddress 15 whether or not they any plans for some unique process. 16 They 'd have to submit it. 17 If they were to use some special process like 18 that, they would have to submit a safety evaluation to the 19 NRC staff. We 'd have to evaluate it. 20 JUDGE BLOCH: That*s providing it really is a real 21 tough process. I don't know enough about =1rconium hydride 22 to know that. 23 You said you didn't know it as a fact that it 24 required a strong acid to do that. 25 THE WITNESS: (Thonus) That's true. If O Heritage Reporting Corporation (202) 628-4888

413 () i somebody 's got a secret process that 's not in the textbooks 2 -- there 's a possibility that someone 's got something out 3 there that I don 't know about. 4 I 'm sure I don't know everything if that 's the 5 word you 're af ter. 6 JUDGE BLOCH: No. I mean do you know that the 7 textbooks say that you can only dissolve circonium hydride 8 with acid? 9 THE WITNESS: (Thonus) The only way I 've ever 10 seen referred to in any nuclear engineering textbook would 11 be a strong ac.d. i 12 JUDGE BLOCH: And do you consider yourself an 13 expert? () 14 THE WITNESS: (Thonus) No. I don 't consider 15 myself an expert on fuel reprocessing.

16 JUDGE BLOCH
Continue.

17 BY MS. SKCLNIK 18 Q So are you expert enough to have made the 19 statement since hydrogen reacts chemically with =ercoloid 20 fuel planning, not all of the initial core inventory was 21 released to '.he reactor coolant? 22 A ("thonus) Yes. that 's evident from using either of 23 the model '; hat -- there was some of the tritium still bound 24 up. 25 Now what fraction. if you use what I would think i Heritage Report ing Corporation (202) 628-4888

i 414 r () 1 would be the most reasonable assumption. that's a relatively 2 small fraction is still bound up with cladding.  ; I 3 Q I 'm sorry. What assumption did you use?  ! 4 A (Thonus) Well, if you use the number of {! 5 approximately 4.000 curies as the original core inventory.  ! l 6 that would perhaps lead you to believe that there is still j i 7 some hydroCen, hyrdogen 3. tritium still chemically bound up  ; 8 with the =ercoloid cladding, but not a very large fraction I 4 9 of it.  ; i 10 If you assume that the initial 8,000 curies then i 11 you would have to, by calculation, come to the conclusion f 32 that a h1Eher fraction of the tritium is still chemically , t 13 bound to the zercoloid.  ! () 14 Q How much of the tritium is formed in the fuel? 15 Since tritium is an activation and a fission product, how f 16 much of that tritium would have been formed by the fuel and i C 17 how much would be in the borated water? 1 18 MS. WOODHEAD: Obj ect ion. Mr. Chairman. I obj ect ( 19 to this general line of questioning because Mr. Thonus is i 20 testifying. his testinony deals with the present content of [ a i 21 the AGW and the staf f 's reason for believing that there are [ 22 a certain number of radionuclides or curies in the water. f i 23 He is not testifying about speculation about  ; 24 additiotsal fuel dissolution and he has not been entered as a l l 25 witness on the remaining defueling assigned. [ l I i i j O Heritace Reporting Corporation i j (202) 628-4888 l t i i

r i 415 () 1 JUDGE BLOCH: Overruled. Becuase question six addresses the question of source term and that 's all he's 2 l 3 being asked about in the relationship between the cource 4 term and the current measurements and where the rest might I i 5 be. , 6 MS. WOODHEAD: It 's my understanding that the  ; 7 issue admitted for litigation is the contenta of the 8 decident generated water as presented in the EII.  : 9 JUDGE BLOCH: As of the time, it is going to be 10 finished you have all the callons which means if something I 11 else is released it could have a hiEher content. [ 12 THE WITNESS: (Thonus) Could you restate the . 13 question? () 14 MS. SKOLNIK: Yes. t 15 THE WITNESS: (Thonus) We had a little bit of  ; 16 tine in here.  ; a r , 17 BY MS. SKOLNIX: i i > l 18 Q Do you know how rouch of the tritium is forned r 19 within the core, sorry, Let me strike that, please. j 20 Do yuu know how much, what is the percentage of k I 21 tritium that is forned in the f uel and how much, what l 22 percentage of tritium is forned in the borated water which 23 nurrounds the fuel? [ t 24 A > nus) It depends on a large variety factors { 25 some of wh, i've previously discussed. i f Heritage Report ing Corporation  ; (202) 628-4888 l t r l

f b 416 c (}I i But the amount that 's formed in the coolant is 2 primarily -- l l 3 JUDGE BLOCH: The question wee, do you know?' l 4 THE WITNESS: (Thonus) Precise number, no. 5 JUDGE BLOCH: Well, just do you know? The 6 peccentage that would be formed in the fuel as opposed to in 7 the borated around the fuel. You eitner know or you don't 8 know. Are you an expert on that? 9 THE WITNESS: (Thonus) I can give you an 10 approximate number but I didn't do any detailed calculations 11 if that 's what you 're asking. 12 JUDGE BLOCH: So the extent of your knowlecge is 13 what? What 's the source of your kncwledge about that? () 14 THE WITNESS: CThonus) Well, I 'm f amiliar with 15 the tritium production mechanisms in the water which are i 16 dependent on lithium and boron concentration in the water. 17 And what 's produced in the fuel is in my mird 18 primarly terinary fission. However, you can make some 19 assumptions about impurities in the fuel and typically you 20 would come out on the order of 90 percent would be formed in 21 the fuel. 22 But again those depend on all kinds of factors, 23 beginning of core life, end of core life, boron 24 concentration, which core you 've got. 25 The calculations to my knowledce can't be done Heritage Reporting Corporation (202) 628-4888

417 . (). 1 accurately by hand. You 've cot to have a code like Origin. 2 JUDGE BLOCH: So that 's one of the thing that the 3 codes are used for, right? 4 THE WITNESS: (Thonus) Yes, it 's one of the . 5 things Origin is used for but again you have to plug into-  ! 6 Origin the core operating history, how many PBM boron were 7 in at that day, how much lithium was in it that day. 8 JUDGE BLOCH: But that 's been done, right? , 9 THE WITNESS: (Thonus) That 's beeri done for TMI, 10 yes, sir. 11 BY MS. SKOLNIK: , t 12 Q And isn 't it true that the Origin 2 code came up , i i 13 with the figure, 8,794? i () 14 A (Thonus) Again, one of those inpute in th'It ! 15 particular number was a lithium impurity. A nd i can 't speak 16 to the individual who plugged in that lithium tw::u ci ty. 17 Q But isn 't it -- 18 JUDGE BLOCH: The question doesn't have to be 19 answered because it 's on the record. You know that that 's

         'O true. Right?   So if you know it 's true, you don 't have to I

21 ask it. 22 MS. SKOLNIK: Okay. , 23 JUDGE BLOCH: If you have is q> ration to follow up 24 on it, something you want the witnese tn c e cyn n, t 1, ask the 25 questior you really want him ta answe O Heritage Reporting Corporation (202) 628-4888

i l l l I 418 1 BY MS. SKOLNIK: (")'T u 2 Q Isn 't it important to know the total anount of 3 tritium in the core inventory so that you can mako en 4 estimate of the amount that might be left which might go 5 into the water? , 6 A (Thonus) Could you rephrase that? 7 Q Sure. Is it important to know what was originall" 8 in the core concerning the tritium so that you might be able 9 to calculate, taking into account the losses through 10 evaporation, what might be left? 11 JUDGE BLOCH: I think we went into that when we 12 asked where it might be. Are you asking any additional what 13 we went into before? () 14 MS. SKP 4: Maybe not. 10 JUDGE BLG.H: Could it be added to the water? 16 That 's the kind of thing we 've asked him before. 17 BY MS. SKOLNIX: 18 Q Okay, Mr. Thonus, my original question was, the 19 other numbers are not inconsistent with the 1,020 curies and 20 that included -- or did that include the estimate of 8,000 21 curies? 22 A (Thonus) Yes. 23 Q Okay. Are you, in the rest of your statement 24 then, are you saying that you can account for the amount of 25 water left, of the amount of tritium left in the water by Heritage Reporting Corporation I (202) 628-4888 t

419' 1 subtracting the evaporative losses from the total? ( 2 A (Thonus) I 'm not sure what your question is. 3 Could you rephrase that nacin. 4 JUDGE BLOCH: Ms. Sko l nip., I think it 's getting 5 repetitious.

6. MS. SKOLNIK: Is it?

7 JUDGE BLOCH: He said that there are, we 've got 8 d.fferent ^.odels. They all have uncertainties in them and 9 we have measurements of the amount of tritium in i.he water. 10 There 's a possibility that there is some other 11 stuff somewhere in the plant. We 've talked about that. 12 The witnesses are saying, unlikely that it will be 13 added but possibly it could be added. But there are () 14 uncertainties '.n the models themselves. So you can't just 15 subtract the amount that 's measured f rom the amount that was 16 predicted and say, yes, that 's got to be somewhere. 17 It 's either somewhere or the models were incorrect 18 to start with. And we 're not certain at this point which is 19 true. 20 The models are not precise as I understand the 21 testimony. If you 'd like further cle.rification of the 22 testimony, you might get it. 23 But as I understand the present testimony it 's 24 along those lines. 25 Heritage Reporting Corporation (202) 628-4888

420

  <s   1              BY MS. SKOLNIK:

( ) 2 Q And in regard to micro-organisms -- 3 JUDGE BLOCH: You might want to specify the time. 4 Is it before they 've been boiled away <or af ter? 5 BY MS. SKOLNIK: 6 Q The point is, can the micro-organisms be boiled 7 away? 8 A (Masnik) The micro-organians will be boiled. And 9 the question, I guess, will any be released? 10 Q Yes. 11 A (Masnik) Is that the question? 12 Q Yes. 13 A (Masnik) There 's no way that we can be absolutely 14 certain that no organisms will be released. But it 's very 15 unlikely that any will be released in a survivable 16 co ndi tion. 17 Q When you say, survivable, do you mean alive or 18 dead? 19 A (Masnik) Alive. Alive. 20 JUDGE PARIS: Does that go to the temperature of 21 the water in the past? ( 22 THE WITNESS: (Masnik) It 's because of a number 23 of things. To begin with there are probably very few 24 pathogens, pathogenic organims, if eny, in the water. 25 And then based on the opera'sion of the system the O Heritage Reporting Corporation (202) 628-4888 k

421 1 organism would experience temperatures that were well in (7l 2 excess of temperatures that would normally cause lithalody. 3 JUDGE BLOCH: Could you compare the likelihood 4 that there are pathogens that would be emitted from this S- process to the possibility that there are pathogens in the 6 air conditioning system in this building right now? I I 7 THE WITNESS: (Masnik) It 's a very, very highly - l 8 - it 's very more likely that there are pathogens in this air 9 conditioning system than would come out of that stack simply because this is a closed cycle system. 11 And the type of organisms that could be spread by 12 an aerosol are typically found in air conditioning systems, 13 air handling systems. 14 JUDGE PARIS: The water that 's being recirculated 15 in this system now is not at the high temperature, is it? ! 16 THE WITNESS: (Masnik) When you say this system. 17 are you speaking in the plant presently or in the -- 18 JUDGE PARIS: Yes. 19 THE WITNESS: (Masnik) No. The temperature of 20 the water in the plant is essentially inambient. 21 JUDGE PARISi Has water been added to it from the 22 river? 23 THE WITNESS: (Masnik) The source of a great 24 portion of the accident generated water was originally the f 25 Susquehanna River. O Heritage Reporting Corporation (202) 628-4888

422 1 JUDGE PARIS: Since the temperature has been

 ; i,.-~l 2 allowed to drop to near ambient, has water been added from 1

3 the river? l l 4 THE WITNESS: (Masnik) There has been water added  ; l 5 to the plant 's system and that makeup is the river. surface 6 water systems, so. yes. 7 JUDGE PARIS: Is it not possible that pathogens 8 could have been introduced that way? 9 THE WITNESS: (Masnik) That 's the likely source 10 of any pathogenic organism in that water would be the river. 11 That 's correct. 12 BY MS. SKOLNIX: 13 Q Is it possible that the pathogens which have come {} 14 15 in from the river water will change character because of the medium in which they 're existing in the reactor vessel? 16 A (Masnik) When you say, change character. I assume 17 you 're saying, is there some genetic difference between the 18 organima found in the river and the organims found in toe 19 plant? 20 Q I think it 's more -- I 'm asking you -- 21 A (Masnik) Would th're be more pathogens? 22 Q Would they be different? Would they be different 23 in any way so that for as the pathogens in the river may not 24 be dangerous, residence in the reactor vessel could make 25 them unhealthy or unsafe? () Heritage Reporting Corporation (202) 628-4888

I 423 1 A (Masnik) It 's extremely unlikely. I

      )
   '~'~

. 2 Q Would you expand upon that, please? 3 A (Masnik) The organism that are of concern, first 4 of all, don't exist very well in nature free living. I mean 5 they 're mostly associated with living inside of a host or 6 people. 7 And upon entry in the system, if they 're not 8 presented with a host, they generally die off. 9 So they wouldn't be in that plant for a very long 10 time before they would essentially die. As far as changes 11 in the organism because of the presence in the facility, the 12 most obvious change would probably be mortality when the 13 utility shocks the system with hydrogen peroxide.

    ~3  14           Since we don't expect any long term survival of (G        these organims then they 're periodically killed of f by the 15 16 hydrogen peroixde addition.

17 I really don 't see n.uch possibility for any change 18 in the organisms that would make them more -- 19 Q So it 's the amount o' time that they are alive, 20 determines whether or not tPc/ change? 21 A (Masnik) No, nc It 's j ust, it 's j ust that they 22 don 't exist in the plant for very long and they're killed 23 off. 24 And the only mechanism that I could poutulate that 25 would cause a change would be the radiation from the plant.

   ]

k Heritage Reporting Corporation (202) 628-4888

424 7-q 1 The problem is, micro-organisms are highly

 ~ \ 'i 2 tolerant of high levels of radiation.

3 And if the levels were high enough, I guess it 4 would kill the organism off but in this case and in some 5 cases it hasn 't. 6 Q And don 't they keep -- isn't there a constant 7 supply of them coming in from the river so that even if you 8 were to kill the population that came in a month or two ago, 9 there would still be new ones coming in? 10 A (Masnik) I don 't believe that there 's much makeup 11 from the river if any. I 'm not exactly sure. We 'd have to 12 ask the Licensee. 13 But again the water coming in is from the river 14 and I don 't see where that would be a problem. 15 JUDGE BLOCH: Ms. Skolnik, if this is a problem, 16 I 'd remind you that the proposal that you 're making is that 17 they be stored onsite for 30 years where they might be 18 released before they 're boiled? 19 So I don't really understand how it relates to the 20 case you 're trying to make. You 're going to have them 21 stored in tanks onsite, these pathogens. 22 MS. SKOLNIK: Yes, but if they 're stored onsite in 23 tanks, the only way they 're going to get out is with an b 24 accident. 25 JUDGE BLOCH: Or rupture. Heritage Reporting Corporation ' ' (202) 628-4888

425

   .s     1           MS. SKOLNIK:   But if they 're in the water, they 'll c

('-) 2 be evaporated. 3 JUDGE BLOCH: Unless eventually, you 're going to 4 have them evaporated anyway. They're going to get it 5 somewhere sometime. 6 MS. SKOLNIK: Yes, but then we 're talking about 7 their life expectency too so in 30 years the question is. 8 will they still be alive? 9 JUDGE PARIS: Well, in the evaporation process. 10 won 't the temperatures be high enough to kill any micro-11 organisms present in the water that 's beind evaporated? 12 THE WITNESS: (Masnik) That 's correct. ' N 13 JUDGE PARIS: So if that would be correct, they 14 could be evaporated next month or 30 years from now, right? 15 THE WITNESS: (Maanik) That 's correct if the 16 organisnm could survive that length of time. 17 JUDGE PARIS: All right. 18 BY MS. SKOLNIK: 19 Q But the evaporator has to maintain a temperature 20 -- will the evaporator maintain a temperature of 240 degrees 21 for approximately 21 minutes to sterill e any object in the 22 system? 23 A (Masnik) The evaporator will not, the vaporizer 24 will. 25 Q Okay. Will 'he vaporizer maintain a temperature. () Heritage Reporting Corporation (202) 628-4888 l

426

       ,                                                                               i                                                                        a constant temperature of 240 degrees for approximately 21                                                                                ,

1.' ) 2 ' minutes as you say here in page five? 3 A (Masnik) It 's an average temperature of about 240 4 degrees for about 21 minutes. That would be the residence 5 time of the water in the system. 6 Q When the micro-organisms are in the reactor 7 vessel, is it t rue that . they f eed on the radioactivity in 8 the reactor vessel in the water? 9 A (Masnik) Absolutely not. These organisne are in l, 10 most cases require -- l 11 JUDGE BLOCH: Could you stop. I think you 've 12 answered it. 13 THE WITNESS: (Masnik) O'.< a y . 14 JUDGE BLOCH: I mean I'm amazed you asked that

            )

15 question. Could they feed on the radioactivity? 16 MS. SKOLNIX: It was a -- 17 JUDGE BLOCH: Did any of your experts suggest that 18 to you that organisms could feed on radioactivity? 19 MS. SKOLNIK: From a transcript at a citizen's 20 advisory panel meeting, that subj ect was discussed that the 21 micro-organism does use the strontium in place of the , i 22 calcium that it r. cds. 23 JUDGE BLOCH: Okay. It doesn 't feed on the 24 radioactivity. It might feed on the strontium. That 's a f i 20 whole different question. Heritage Reporting Corporation O~ (202) 628-4888

427 1 It might feed on a radioactive element. It 's not 2 going to feed on the radioactivity. The answer to the 3 question was, absolutely not. 4 MS. SKOLNIK: Okay. Well, I wasn't aware that the 5 two were different so -- G BY MS. SKOLNIK: 7 Q So the micro-organism does feed on the strontium 8 90? 9 A (Masnik) I think the word, feed is incorrect. 10 There 's a possibility that, that some of the atoms in the li micro-organism could be replaced by stcontium or some other 12 radionuclide in the water that is radioactive. 13 JUDGE BLOCH: I don 't understand the relevance. r"3 14 MS. SKOLNIK: Well, if a certain -- if there 's a m' 15 possibility that a certain amount of micro-organisms will 16 get out through the vaporizer, dead or alive, and they 17 contain strontium 90, it 's an addition to the dose. 18 JUDGE BLOCH: The whole process is designed to 19 take the strontium 90 out, reduce the total strontium 90 to 20 less than a thousandth of what it was whether some of it is 21 in micro-organisms or not. It doesn 't seem relevant. 22 MS. SKOLNIK: I guess it seemed relevant to me 23 though. 24 JUDGE BLOCH: Especially dead micro-organisms. 25 THE WTTNESS: (Masnik) The micro-organisms would ly) Heritage Reporting Corporation (202) 628-4888

428

 ,f~   i be indistinguishable from any, as far as the evaporator is 2  concerned is indistinguishable from a particulate.

3 I mean' it 's J ust- as if f rom the standpoint of the 4 evaporator. it 's just as if it was a particle of sand. 5 BY MS. SKOLNIK: 6 Q Have you undertaken analysis yourself of the 7 possible pathogenic problems of the micro-organisne in the 8 reactor vessel or I should say, has the NRC7 9 JUDGE BLOCH: To nome extent his testimony states 10 that certain analysis he 's done of that. So you 've .seen 11 come of that. 12 Is there something, some other kind of analysis 13 you want to ask him about? 14 (Continued on the next page.) 15 16 17 18 19 20 21 22

23 24 l

25 l t Heritage Reporting Corporation i (202) 628-4888

l 1 I 1 429

   -s x

i BY MS. SKOLNIK: t (~) 2 Q Did the NRC undertake analysis of the 3 microorganisms for diseases like Legionnaires Disease? 4 A (Masnik) Would you define what you mean by 5 analyses? 6 Q Did you take a sample of the water and send it to 7 a laboratory which would look specifically for viral 8 infections? 9 A (Masnik) No, we did not. 10 MS. SKOLNIK: That 's everything. Thanks. 11 JUDGE BLOCH: Thank you. Licensee. 12 MR. BAXTER: We have no questions. Thank you. 13 JUDGE BLOCH: Mr. Mather. 14 MR. MATHER: I have a few questions. I ought to 15 introduce myself for the witnesses. My name is Rick Mather. 16 I'm an attorney with the Commonwealth of Pennsylvania, he 17 have filed for and been granted interested state s':atus in 18 this proceeding. I just have a few questions regarding your 19 questions, or the answers that you provided on Page 3 of 20 your testimony, Questions 5, 6 and 7. 21 CROSS EXAMINATION 22 BY MR. MATHER: 23 Q If you look at your answer to Question 7 second 24 line, it says "Deviations above and below the average which 25 do not materially change the average do not affect the S Heritage Reporting Corporation ('J (202) 628-4888

430 1 Staf f 's conclusion. " What do you mean by 'which do not 2 materially" - "Deviations...which do not materially 3 change..."? Can you quantify what you meant by that? 4 A (Thonus) I'm sure if you looked at the GPU S analysis of the 25 separate tanks you would find some 6 variability in the concentrations of individual isotopes in 7 individual tanks and assuming that they would process these 8 tanks one at a time or maybe two at a time, some tanks would f 9 have higher concentrations and lower concentrations, 10 depending on the radionuclide, than other tanks. 11 One of the things, end I did not participate in 12 this, but we 've looked at it on a quarterly average, that 13 would stay within the limits that were imposed by Table 2 14 that would then be within the environmental impact that we 15 evaluated. I could give you a for instance. The average 16 number is .13 microcuries per milliliter. If they had Tank 17 X that had .17 and Tank Y that had .09, it would average out 18 to .13. assuming that they were the same size. I 'm not 19 sure, did I answer your question or is there something else? 20 Are we going to set a number that they have to be within 21 plus and minus 20 percent? 22 Q I 'm looking for whether or not you know what the 23 material deviation would be so that your conclusions might 24 change. 20 JUDGE BLOCH: Mr. Mather, may I LJR a question to Heritage Reporting Corporation

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431

 ,-m    1 clarify this?

(~) 2 MR. MATHER: Yes. 3 JUDGE BLOCH: If we were to take out the phrase, 4 the "which" phrase, "which do not matorially change the 5 average," if we just struck it from the sentence, would the i

                                                                            ~

6 remainder of the sentence be true? 7 THE WITNESS: (Thonus) Yes, that 's true. That 's 8 correct. 9 JUDGE BLOCH: So it's not dependent on the size of 10 the difference from the average. It 's a statement that 's 11 true regardless of the size of the difference. 12 THE WITNESS: (Thonus) Yes. But at one point 13 when the staff looked at that, if it were a large, if it 14 were a single large enough tank and for that particular 15 calendar quarter, it threw the number outside of what we 16 analyzed, we would probably not allow -- we would require 17 the Licensee on a quarterly basis to meet those average 18 numbers. 19 JUDGE BLOCH: Because it would affect their 20 compliance with the tech. specs, is that what you 're talking 21 about? For release?

22 THE WITNESS: (Thonus) It would -- yes. Both it 23 would, potentially could affect their compliance with the 24 tech. specs, although it may affect the analysis that we did 25 in the PEIS. In the long run, over a two-year period. it [

O Heritage Reporting Corporation (202) 628-4888 t i

432

 ,        1           really doesn't matter what calendar _ quarter it goes out or
 )

( 2 which tank is high and which tank is low. The dose to the 3 affected environment is going to be the same. GPU and the 4 NRC are both taking a relatively conservative approach on 5 that. 6 JUDGE BLOCH: I hope that helped. Mr. Mather. 7 MR. MATHER: Well, it helps somewhat but I was 8 still looking to see whether or not you could quantify what 9 the material difference would be which would change the t 10 conclusions that they reached. 11 THE WITNESS: (Thonus) I don 't have a number for 12 you off the top of my head, but i t would be any number that 13 would be large enough to alter our conclusions as to the 14 offsite doce to the public, the integrated offsite dose 15 through the process, or would lead us to believe that they 16 were going to exceed the number of curies that we analyzed 17 in Table 2.2. t 18 MR. MATHER: That 's the only question I had. 19 JUDGE BLOCH: Thank you. Staff? 20 MS. WOODHEAD: I have no redirect. I 'd like 21 specific instructions as to how we should submit the i; 22 inspection reports that you requested earlier concerning the [ h 23 Staf f 's analysis of the accident water. I 24 JUDGE BLOCH: I guess it would be helpful if the t 25 parties could have that report prefiled at least a week () Heritage Reporting Corporation (202) 628-4888 l l

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     ,,      i   before we 'll hear them. I guess what I 'd like to do is to 2   consider hearing those on the day that 's now vacant, the day
   ,         3   that Mr. Morgan was going to begin testifying.      That 's the 4   15th.

5 MS. WOODHEAD: I didn't understand that you 6 visualized this as testimony. I thought this would be a 7 document, an agency document just submitted to the record. 8 JUDGE ELOCH: Won 't you have '.o somehow verif y it 9 as true for testinony, for evidence? If we 're going to have 10 an adequate record, you 'll have to have someone sponsoring 11 it. 12 MS. WOODHEAD: Yes. Well, this was at the Board 's 13 request. so I wasn 't clear on what you were requesting. I 14 suppose. to authenticate the document, we would have to have 15 the inspector. I would have to ask Mr. Thomas who these 16 people are. I was unaware of these documents before he 17 mentioned them. 18 Well. at any rate. perhaps we could discuss that ! 19 off the record. I thought that you had something specific 20 in mind you could tell me. 21 JUDGE BLOCH: I 'll modify what I said. We 'l l t ake 22 the inspection report a week before the 15th which would be 23 the 8th, and having looked at it, we 'll tell you whether 24 that 's satisf actory for us. l 25 MS. h00DHEAD: All right. i l 4 - Heritage Reporting Corporation

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                                                                                                                                                                          ~434 j-         1                                  JUDGE BLOCH:                          Do you have a comment?

(' 2 1AR. BAXTER: Simply that the 15th is when Dr. 3 Morgan is-coming. 4 JUDGE BLOCH: The 14th? '

5. MR. BAXTER: 14th.

6 JUDGE BLOCH: So we should have it on the 7th if 7 we can so we can have a chance to look at it. 8' MS. WOODHEAD: All right. We 'll submit i t as soon 9 as possible. The Staff has no redirect. 10 JUDGE BLOCH: So now you get to do recross on the 11 subj ect that was raised by the State. 12 RECROSS EXAMINATION 13 BY MS. SKOLNIK: 14 Q Is it true that there is a deviation above or

            )

15 below, above the average which would affect the Staf f 's 16 conclusions? 17 A (Thonus) Could you rephrase that question? , 18 0 You said that over a two-year period, 1020 curies i 19 of tritium would be released, but you also mentioned that 20 over a quarterly period there were technical specifications 21 which designated the release rate. What I would like to 22 know is have you actually formulated the deviation which you 23 are not willing to accept? Do you have a figure? t 24 JUDGE BLOCH: Yes or no? Then you can explain how i 25 you figured it out. i O Heritage Reporting Corporation (202) 628-4888 l r h _ __.m_- _ __- __________________.__m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . - __m__ m _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . .

i 435 , ,- 1 THE WITNESS: (Thonus) What we 're willing to \# 2 accept is the total curies and we 're not willing to accept 3 GPU exceeding that. So frem that standpoint, we e-e not 4 willing to accept a deviation from what the Utility and the 5 NRC have evaluated. If you are talking on a week by week 6 basis, which will not affect the net environmental impact. 7 we don 't expect the weekly environmental impact to be the 8 same over whatever period of time it takes them to evaporate 9 the water. And at this point the exact time period that it 10 takes the water. I want to make it clear, is not known. 11 You can certainly estimate that; two years is a 12 fair estimate. But I 'm not swearing it will take them 13 exactly two years. 14 BY MS. SKOLNIK: 15 Q Do you have e figure -- please say yes or no -- do 16 you have a figure which represents an acceptable deviation? 17 JUDGE BLOCH: Do you want to know if he knows 18 whether or not there is an amount that cannot be exceeded in 19 a given calendar quarter? 20 MS. SKOLNIK: I want to know doca he have a figure 21 for the maximum average concentration of tritium which is 22 acceptable for the technical specifications. 23 JUDGE BLOCH: So you want to know if he knows the 24 tech. specs? 25 MS. SKOLNIK: No. Well. I hope he knows the tech. (~') Heritage Reporting Corporation \' (202) 628-4868

l 436

 ,_     1 specs. What I want to know, though, is what is the maximum 2 average concentration of tritium which will not e::ceed the 3 technical specifications?

4 MR. BAXTER: Over-what time period? 5 MS. SKOLNIK: A quarter. l 6 JUDGE PARIS: You are asking for an average. A , 7 maximum average. And not a maximum maverick value that 's l 8 way above the usual values. 9 MS. SKOLNIK: i 'm asking for. yes, a quarterly

      .10 average.

11 JUDGE PARIS: Okay. 12 THE WITNESS: (Thonus) I don't have the technical 13 specifications in front of me. I 've looked at that and I

14 recall that the amount, based upon either 3 or 5 gallons per 15 minute evaporation rate, they will not approach their 16 technical specification limit.

17 And if you are talking averages, what we have 18 evaluated in the PEIS is the long term average as given in 19 here of .13 microcuries per milliliter over the duration of 20 the process. 21 BY MS. SKOLNIK: 22 Q But isn 't it true that if mixing of the tanks has 23 to occur before they go into the evaporator, that the 24 concentration of tritium will be over .13? 25 MS. WOODHEAD: Obj ect ion. This is repetitive. Heritage Reporting Corporation ('O' (202) 628-4888

F

n 437
    ,-q        i We 've had _this question several times.

() 2 JUDGE BLOCH: Sustained. 3 MS. SKOLNIK: Judge Bloch, when I asked my 4 question before, and you had directed Mr. Thonus to give a 5 yes or a no. And I didn't get a yes or a no. Therefore I 'm 6 still confused as to the answer of my question. 7 JUDGE BLOCH: He said he doesn 't know the tech. 8 spec. He did say that. So he doesn't know the total amount 9 that can be released in a quarter. Is there something else 10 you want to know whether or not he knows? 11 "he NRC relies on the applicants in the first 12 instance to comply with the technical specifications. 13 MS. SKOLNIK: Well, the statement is -- 14 JUDGE BLOCH: Let me ask this. Mr. Thonus, is 15 there an amount of tritium that would not be, that you would 16 not permit to be released which would result in a release 17 that is within the technical specifications? 18 THE WITNESS: (Thonus) No. 19 JUDGE BLOCH: So the only limit Mr. Thonus would 20 place on the releases are that they stay within the , 21 technical specifications, in a particular quarter. The 22 total release resulting from concentrations were analyzed as 23 he knew them. T29/Blad MS. SKOLNIX: I just want to say that I don 't feel 25 happy that the issue has been answered but I 'm not able at Heritage Reporting Corporation O' (202) 628-4886

438 ,, 1 this time to put it into, to formulate it in a question 2 form. 3 JUDGE BLOCH: Okay. Because-you would have to ask 4 a question to get an answer. 5 MS. SKOLNIK Right. 6 JUDGE BLOCH: So I guess that 's just an 7 unfortunate fact. 8 MS. SKOLNIK: Right. 9 JUDGE BLOCH: Licensee? 10 MR. BAXTER: Nothing further. 11 JUDGE BLOCH: Staff? 12 MS. WOODHEAD: Nothing further. 13 JUDGE BLOCH: Okay. The witnesses are excused. 14 Thank you for your participation. 15 (The witness were thereupon excused.) 16 JUDGE BLOCH: Licensee, next witnesses? 17 MR. BAXTER: The Licenseo calla David R. Buchanan. 18 Jar es E. Tarpinian and William W. Weaver. 19 Gentlemen, beginning on my left, would you each 20 state your name? 21 MR. TARPINIAN: My name is James Ephraim 22 Torpinian. 23 MR. BUCHANAN: My name in David R. Buchanan. 24 MR. WEAVER: My name is William W. Weaver. 25 JUDGE BLOCH: Gentlemen. I would like to welcone O Herituge Reporting Corporation (202) 628-4888

439 1 you to the proceeding and to tell you that the testimony you 2 are about to give must be the truth, the whole truth and 3 nothing but the truth, and that the testimon/ will be 4 subj ect to possible penalty for perj ury. Do each of you S understand the statement that I have just made? 6 MR. TARPINIt.N: Yes. 7 MR. BUCHANAN: Yes 8 MR. WEAVER: Yes. 9 JUDGE BLOCH: Let the record show that they all 10 have. indicated that they understand. Welcome. l 11 Whereupon, , 12 JAMES E. TARPINIAN 13 DAVID R. BUCHANAN 14 WILLIAM W. WEAVER i O 15 having been first duly sworn, were called as witnesses , 16 herein, and were examined and testified as follows:

;                 17                                                  DIRECT EXAMINATION 18                                  BY MR. BAXTER:

19 Q Mr. Tarpinion, we will begin with you. I call 20 your attention to a document that bears the caption "The r l 21 Proceeding" dated October 11, 1988. It 's entit led , t 22 "Licensee 's Testinony of James E. Tarpinian on Occupational 23 Dose Assessments (Contention 2)." It contains four pages of 24 questions and answers and an attachment. 25 Does this reflect testinony prepared by you or Heritage Reporting Corporation (202) 628-4888

440 g s i under your supervision for presentation at th*.s hearing? H

     - _]  2      A    (Tarpinian)   Yes, it does.

1 I y 3 Q Do you have any changes or corrections to make to l 4 your testimony? 5 A (Tarpinian) I do not. I co not. No changes. l 6 Q Is it true and accurate to the best of your 7 knowledge and belief? 8 A (Tarpinian) Yes, it is. 9 MR. BAXTER: Judge Bloch. I move the admission of 10 Mr. Tarpinian's testimony and ask that it be physically 11 incorporated into the transcript as if read. 12 JUDGE BLOCH: There being no obj ections, that 13 shall be done and it shall be numbered consecutively, 14 (The "Licensee 's Testimony of 15 James E. Tarpinian on 16 Occupational Dose Assessments 17 (Contention 2)" is inserted 18 into the record and follows:) 19 20 21 22 23 24 is i 25 Heritage Reporting Corporation s- (202) 628-4888 i

a 441 L . o 4 October 11, 1988 i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I In the Matter of ) f

                                            )                                       '

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

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

Station, Unit 2) ) O r LICENSEE'S TEST! MONY OF JAMES E. TARPINIAN  ! ON OCCUPATIONAL DOSE ASSESSMENTS i ' (CONTENTION 2) 5 i I

I r

L [ ($) I I j

442 Q.1 Please state your name. A.1 James E. Tarpinian. Q.2 Mr. Tarpinian, by whom are you employed, and what is your position? A.2 I am employed by Bechtel Construction Inc. as Manager, Radiological Engineering for GPU Nuclear Corporation's ("GPUN") Radiological Controls Department at Three Mile Island Nuclear-Station, Unit 2 ("TMI-2"). Q.3. Please summarize your professional qualifications and experience relevant to this testimony. A.3 I have a B.A. degree in Biology and earned a M.S. de-gree in Radiological Sciences and Protection. I am certified by the American Board of Health Physics in the comprehensive prac-O tice of health physics and the power reactor specialty and regis-tered by the National Registry of Radiation Protection Technologists. From 1975 to 1978, I was a radiological controls monitor for the Electric Boat Division of General Dynamics Corpo-ration. In that position, I provided radiation safety for all aspects of nuclear submarine overhaul and refueling, including AI. ARA evaluation, monitoring the workplace for radiation hazards, and setting protection requirements for verkers. From 1978 to 1980, I taught classes in physics and radiological sciences at the University of I.ovell. In 1980, I was hired by sechtel North American Corporation. I served in a variety of engineering and

443 B supervisory capacities in a group dedicated to decontamination (~Y and radvaste engineering for the THI-2 recovery project. In U september, 1984, I joined GPUN's Radiological Controls Department , at THI-2, and in December, 1984, I assumed the role of Deputy Manager, Radiological Engineering for THI-2. Since September, 1986, I have held my present position as Manager, Radiological Engineering for GPUN's Radiological Controls Department at TMI-2. My current responsibilities include ALARA planning and engineer- i ing for all THI-2 recovery work. A complete statement of my pro-fessional qualifications is appended as Attachment 1 to this testimony. Q.4 What is the purpose of this testimony? , A.4 I will address the occupational radiological dose esti-mates for the GPUN proposal to estporate the TMI-2 Accident-() Genersted Water ("AGW") and for the alternative raised by the Joint Intervenors, involving on-site storage followed by dispos- I al. Q.5 What is the estimated occupational dose for the evapo-ration proposal? 6 A.5 The occupational dose attributed to evaporation of the I AGW and the packaging of the evaporator bottoms has been conser- L vatively estimated to be 23 person-rem. This maximum dose is

based on 9.6 person-rem from approximately 16,000 persea-hours
 ;                                                  for the evaporation process in a radiation field of 0.6 mrem /hr,                                                                    i I                                                                                                                                                                                    :

l ($) l l 4

                                                                                                                                         .i                                              k i

t

e 444 1 i 8.7 person-rem from approximately 3,500 person-hours for the n -

    \~)                           packaging of the evaporator bottoms in a radiation field of 2.5 mrem /hr, and 2-5 person-rem from the processing of about 31% of the volume of water.       This dose is a very small percentage of the total THI-2 recovery exposure to the work force estimated by GPUN and tite NRC.

Q.6 What is the estimated occupational dose for the Joint Intervenors' alternative involving on-site storage of the AGW > followed by disposal? l A.6 Assuming the Joint Intervene!c' alternative calls for the preprocessing of 31% of the projected 2.3 million gallons of AGW prior to storage, the occupational dose attributed to the Joint Intervenors' alternative has been conservatively estimated l[p to be approximately 15 person-rem, After a 30-year storage period, it is not unreasonable to assume that the occupational 3 dose vill be half of the maximum dose if evaporation were to take place at this time. Thus, the total occupational dose vould be approximately 15 person-rem based on 5 person-rwm for preprocessing and a 50% reduction in the 19 person-rem figure for evaporation (assuming ovaporation is chosen as the pitimate I method of disposal), a l i () '

445 a ATTACHFINT 1 () JAX13 i TARP!N!AN e SUXXARY:' Thirteen years' experience in applied health physics i and radiation protection primarily associated with nuclear power facilities. A broad base of experience includes managing a radiological engineering program for a major nuclear utility, large-scale decontamination project, technical planning quality asaurance of a audit, i and developing and conducting training programs for nuclear workers. Certified in comprehensive I practice by the American Board of Health Physics. RPM qualified per ANS! t.tandards. Active in professional societies and standards setting organizations and made numerous presentaticas to i technical and non-technical audiences. . EDUCATION: University of Connecticut at Storrs  ! B.A.. Biology, 1975 () University of Lowell X.S. Radiological Sciences and Protection, 1980 t EXPERLINCE: i 1984-Present Bechtel National Inc. - Manager, Radiological Engineering for 'QPU Nuclear's Radiological Controls Department at Three Mile Island Unit-2, reporting to the RPM and supervising a staf f of up to  ! thirteen engineers responsiblo for the ALARA planning and engineering for all TX!-2 recovery work. Other routine functions include affluent monitoring and reporting, 10 CPR 61 complia'Me and radweste  ; characterization, special scuece and radiation analysis, internal and external dosimetry assessments,

 ;                                   emergency response, and various other aspects of tocht,1 cal reppert for the Radiological Controls                                                    <

De ps.'e t me n t . Served as Deputy Manager of the group for two years psior to assuming present position in September of 1986. Previously served as the senior , ' ' engineer in the Decontamination Planning Department. '

'                                    Authore*J technical plans, planning studies, and data reports pertaining to the decontamination of TXI-2 facilities, and supervised the development of these

, (]) products by other members of the group. , i 1980-1984 Bechtel North American Corp.- Served in a variety of l I engineering and supervisory capacities in a group ' dedicated to decontamination and radwaste

446 JAX13 3. TARP!N!AM

                               ~

engineering for the TMI-2 recover'y project. Responsibilities included the development of

                       **   daccatamination specifications, technical and safety
                  .       . review of decontamination and radweste procedures.

ALARA planning and engineering, and supervising up to six engineers. Authored and co-authored key technical and safety evaluation reporte, served on several task groupe reporting to the Office of the Director, and played a lead role is the early reactor building entry program. 1978-1980 University of Lowell- Graduate Assistant and i Indepandent Consultant. Developed and tsught undergraduate labe and lecture cournen tu l physics and radiological sciences. Edited e l training manual for radiographere under coutraat to the NRC. Developed and conductsd workshope na radiation for school teachord. Developed aLA conducted a training program for the health physics staff at vermont Yankee. , 1974-1978 Iloctric Seat Division of General Dynamics Corporation- As Quality Assurance Auditor (1 year) was responsible for the evaluation and audit of systems and procedures for the quality control of O nuclear submarine constructiou. Audit findings were consunicated directly to upper unnagement. As a Radiological Controla Moniter (3 years) provided radiation safety for all aspectu of nuclear submarine overhaul and refueling, including ALARA

       ,                    evaluation, annitoring the workplace for ..'adiation hasards, and setting protectic'n requirements for workare. Other duties included waste management, emergency response, and training ot' workare ana I

peers. Qualified as Radiological Controits Monitor per Navskipe 0284. " DOD Sec re t" security clearance. PRCPESSIONAL DATA: Certified in comprehensive practice by the t aurican Board of Health Physica in 1984 and registecad by the National Registry of Radiation Protectiun (NRRPT) Technologists in 1976. Current offices held Chair of the Nominating Committee of Health Physics Jociety (KPS). President of the Susquehanna Valley Chapter of the HPS. asd Chair of ASTM E-10.04.02 standerds writing task group on ALARA. Memberships: Health Physics Society. American Academy of Health Physics. Power Reactor Section HPS. NRRPT. Tusquehanna Valley Chapter of HPS. Delaware Valley Scciety of Radiation Saf ety. (]) American Nuclear Society ( ABS). Central PA Section of ANS. American Society for Testing of Materials,(ASTM).

                                                                         #   4

447 1 BY MR. BAXTER: 1 ' - (. ) 2 Q Mr. Buchanan. I call your attention to a document j 3 that bears the caption of'the proceeding. It 's dated 4 October 11. 1988 and it is entitled "Licensee 's Testimony of l l 5 David R. Buchanan on the Evaporation Proposal and the Joint j o Intervenors ' Alternative (Contentions 2 and 3)" consisting , I 7 of 16 pages and one attachment. Does this represent  ; I 8 testimony prepared by you or under your supervision for 9 presentation at this hearing? 10 A (Buchanan) Yes, it does. 11 Q I would also like you to identify for me. Mr. 12 Buchanan, the document that was pre-filed as a GPU Nuclear 13 letter on the cover. It 's dated October 7, 1988, from Mr. 14 Roche to the NRC and it has attached to it a document called 15 "Division Technical Evaluation Report for Processed Water 18 Disposal System." Was this also preparea under your 17 supervision? 18 A (Buchanan) Yes, it was. 19 MR. BAXTER: Judge Bloch. I 've provided the Court 20 Reporter with three copies of this latest document and 21 request that it be marked for identification as Licensee 's 22 Exhibit Number 1. 23 JUDGE BLOCH: Off the record. 24 (Discussion off the record) 25 JUDGE BLOCH: Let 's mark that Licensee 's Exhibit Heritage Reporting Corpo ation O' (202) 628-4888

448 1 1

    @    2                                      (The document referred to was 3                                      marked for identification as 4                                      Licensee 's Exhibi t 1. )

S BY MR. BAXTER: 6 Q Mr. Buchanan, then, on Page 6 of your testinony. 7 the last line of Answer S. should that blank be number 17 8 A (Buchanan) Yes, it should be, f 9 Q Do you have any changes or corrections to make to 10 your testimony. Mr. Buchanan? 11 A (Buchanan) There are two changes that should be 12 made. On Pace 5. second line of the second paragraph where 13 the nunber 2.1 million is. I would like to change that to r^ 3 14 read 2.2 million. And on Pege -- G' 15 Q Let 's slow up a minute. 16 JUDGE BLOCH: Line 7? 17 THE WITNESS: (Buchanan) That 's correct. The 16 seventh line. And on Page 12. for Answer Number 16 on the 19 second line where it says "Generic Letter 81-83." that 20 should be corrected to read "81-38." 21 MS. SKOLNIK I 'm sorry. Mr. Buchanan, Could you 22 repeat that please? I lost it. 23 THE WITNESS: (Buchanan) Sure. 24 JUDGE BLOCH: Off the record. 25 (Discussion off the record) [j Heritage R epo r t i ng Corporation (202) 628-4888 L

449

    <-  1                                 THE WITNESS:                                                                   CBuchanan)  That 's the only changes.

2 BY MR. BAXTER: 3 Q You have changes on Page 13. I'believe. Mr. 4 Buchanan. Answer 18? 5 A (Buchanan) That is correct. There arc 3me 6 additional changes on Page 13 I need some help with the 7 numbers, though. L 8 Q Your copy isn 't marked? 9 A (Buchanan) No, my copy is not marked . 10 JUDGE BLOCH: Mr. Buchanan, you could leave to'get 11 the document you need. 12 THE WITNESS: (Buchanan) Okay. For Answer Number 13 18, in ihe fourth line after the word "offsite" insert the 14 words "total body". ( 15 Next change then is starting on that same line. 16 strike the words "to the bone". i 17 Then on Line 5. the number "3.6 millirem", change 18 that to read "1.3". 19 The next line down which reads "O.011". change 20 that to read "O.005". 21 Second line f rom the bottom, the fourth word. 22 which is "one-half". change that to read "one-fourth". 23 JUDGE BLOCH: That 's the second line f rom the 24 bottom? 25 THE WITNESS: ' Buchanan)

                                                                                                                         .           Right.   "small doses by l                                             Heritage                                                                  Reporting Corporation

! (202) 625-4888 i l l

450 1 one half". change that to read "small doses by one fourth". -

  )                                                               2              BY MR. BAXTER:                                                                                                                       ,

3 Q As corrected, is your testimony true and accurate 4 to the best of your knowledge and belief? 5 A (Buchanan) Yes, it is. 6 MR. BAXTER: Judge Bloch, can we move the 7 admission of Mr. Buchanan's testimony and ask that it be j 8 physically incorporated into the record at this point as if [ 9 read and move the admission of Licensee 'a Exhibit Number 1?  ; 10 JUDGE BLOCH: Mr. Buchanan, just because of the f 11 way that this was done, before I do that, I would like to j 12 ask you how the corrections on Page 13 came to your 13 attention? 14 THE WITNESS: (Buchanan) That came to me by some 15 changes that were made by separate testimony being prepared 16 by Dr. Baker or Mr. Cooper. My statements on that Page 13 l 17 reflect their testimony.  ! 18 JUDGE BLOCH: Do you know independently that i 19 what 's stated in your testimony on Page 13 is true?  ! l 20 THE WITNESS: (Buchanan) No, what I am stating  ! 21 there is, as I state, testimony according to Dr. Baker. I l 22 am referencing his testimony. So I am obviously taking his l 23 word for it. 24 JUDGE BLOCH: Thank you. Are there any j 25 obj ec t ions?  ; i

() HeritaBe Reporting Corporation (202) 628-4888 l

t l 6

451 1 (No response) O 2 JUDGE BLOCH: There being none, that testimony 3 shall be bound in and consecutively numbered. 4 (The "Licensee 's Testimony of i 5 David R. Buchanan on the  ; 6 Evaporation Proposal and the 7 Joint It'.tervenors

  • Alternative ,

8 (Contentions 2 and 3)" is 9 inserted into the record and 10 follows:) 11 12 l 13 e " 15 i 16 17 18 , 19 , 20  : F 21 l 22 l t 23 j 24 i 3 25 i f G Heritage Reporting Corporation (202) 628-4888 j

452

   */

k October 11, 1988 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 Mlle Island Nuclear                             )        Generated Water)

Station, Unit 2) ) O LICENSEE'S TESTIMONY OF DAVID R. BUCHANAN ON THE EVAPORATION PROPOSAL AND THE JOINT INTERVENORS' ALTERNATIVE (CONTENTIONS 2 and 3) t

 .O b   ..

s

453 Q.1 Please state your name. (" A.1 David R. Buchanan. U} 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 ("THI-2"). Q.3 Please summarize your professional qualifications and experience relevant to this testimony. A.3 I have a B.S. degree in Hechanical 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 THI-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 C:)

454 i raised by the Joint Intervenors, involving on-site storage fol- {} loved by disposal. In particular, in response to contention 2, will compare the resources necessary to implement the GPUN pro-I posal and the alternative put forward by the Joint Interveners. 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 THI-2 accident. Second, I will explain the GPUN proposal for disposition of the AGW. Third, I l vill address the Joint Intervenors' alternative for disposition of the AGW. ( Q.6 What is Accident-Generated Water ("AGW")? A.6 On February 27, 1980, an agrer. ment executed among the City of Lancaster, Pennsylvania, Metropolitan Edison Company, and the NRC defined "Accident-Generated % \ter" as

a. Water that existed in the TMI-2 Auxiliary Fuel t Handling, and Containment buildings ir.cluding 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 of greater than 1 uCi/ml prior to processing except where such water .

l is originally nonaccident water and becomes j contaminated by use in cleanup.

.O
  • i

455

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

O What has happened to the AGW since the TMI-2 accident? Q.7 A.7 Following the accident, GPUN' installed three separate treatment systems to remove radionuclides and other contaminants from the AGW. The first was EPICOR !!, 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 Domineralizer System ("SDS"), which was placed into operation in June 1981 and employed inorganic cesi2m 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 THI-2. Of this volume, about 640,000 gallons were located in the R8. Direct release from the Reactor Coolant System ("RCS") contributed 69% of this water. An additional 28% Y vas river water introduced via leaks in R8 air coolers at the time of the accident and the remaining 3% vas added via the con-tainment spray system during the first several hours of the acci-dent. Subsequent to 1981, most of this water was processed by both SDS and EPICOR !! to reduce radionuclide levels to very low concentrations. [

                                                      +

O l 1 e

456 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 l contained an additional 96,000 gallons which also required pro- l cessing by the SDS and the DWCS. i 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 vill increase but is not expected to exceed 2.3 million 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, re.gulatory 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 i the separation and final treatment of the solids removed and i I

457 , collected during *.he evaporation process and :he preparation of i g- 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, I,n c . , 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 TMI-2 application. A detailed description of the systems f and evolutions which vill accomplish the controlled disposal of the AGW is contained in GPUN's Technical Evaluation Report for Processed Water Disposal System. A c.opy of that report is pro-vided as Licensee's Exhibit No. 1. ._ Q.9 Please describe the AGW disposal program. A.9 The processed water disposal program consists of (a) a , dual evaporator system designed to evaporate the processed water () at a rate of five gallons per minute; (b) an electric povered va-  ; porizer designed to raise the evaporator distillate temperature to 240*F and to release the resultant steam to the atmosphere via a flash tank and exhaust stack; (c) a vaste concentrator designed to produce the final compact vaste form, and (d) a packaging sec-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 of Fact 4(xiii) under Contention 3, the Joint Intervenors assert the NRC's dose calculations are inadequate because the water () l

458 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 vaporizer is supplied from an independent staging tank. Conversely, if the vaporizer is cou-pled 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.11 Are the Joint Intervenors' correct in their assertion that batch cyle operations will invalidate the NRC's dose calcu-lations? A.ll 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 () h-e-i- m. i si-ii..i .

                                                                                                       ...,-,-.-,,-,-w

459

         '                         effects'of evaporator discharges. The activity releases occur-r                             ring from evaporator discharges of "Base Case" vater result in

(.)' releases that are a small fra: tion of the releases permitted by existing regulatory requirements. Since the PEIS analysis assumed processing "Base Case" vater with a vaporizer discharge to the atmosphere containing 0.1 per-cent of the radioactive particulates from the influent, that value vill be used as the system operating limit. Thus, when . r operating the processed water disposal system in the coupled mode l (evaporator and vaporizer in continuous operation), the volume of water being processed will be isolated from all sources of con- l l tamination. Its radionuclide content will be verified to be vithin 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

; [}

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 Table 1, Column 2. These limits equate to an atmospheric release rate for particulate radionuclides of 8.23E-5 uti per second if  ; processing water containing the maximum limits at a rate of five 1 gpm. In short, the system operating limit vill be the same for i all methods of operation, and the batch cycle operation of the l evaporator vill not-affect the resulting dose calculations. I l I 1 () 1

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

    <~                        al?

A.12 Based upon vendor price quotes, the evaporation and vaporization 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 will cost an estimated $293,700. Preprocessing approximately 31% of the water volume by domineralization 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, , I 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 i vater disposition, t A.13 It is not clear that the Joint Intervenors propose any

  • T option, since in discovery they stated they did not have suffi-cient information to select a preference. They have urged that [

t further study be given to what Joint Intervenors call, in [ Contention 2, the "no action" alternative. However, the term f t

                           "no-action" alternative is really a misnomer.                                        Under this alter-                 (

native, as defined by the Joint Intervenors, the AGW would be f () t i. I i

                                                                                                                                                    ~461 stored in tanks on the TMI site for some period of time, followed by disposal of the AGW in some manner.                The Joint Intervenors

(]} would 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 THI-l's operating license is scheduled to expire in 2008, I have assumed a potential plant life extension of 10 years. For r arposes 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 ga'11on Processed Water Storage Tanks ("PWSTs") and various tanks (]) and systems throughout THI-2. In order to complete the cleanup of the plant, the approximately one million gallons of water in 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 *.anks on 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 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. () .

 .                                                                        i 462 l 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. Ona set of assumptions would 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 Motion for Summary Disposition, would require constructing ne/ tanks to the standards of Generic Letter 81-38 for temporary vaste 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 I .11 - () 9

m 4 463

 '                    (a)   seismic criteria;                                                     e

(~') (b) withstand the corrosive nature of the wet vaste 7 s_- stored; , (c) have curbs or elevated thresholds with floor ' drains and sump to safely collect vet vaste assum-ing the failure of all tanks or containers; (d) remove spilled vaste to the radvaste treatment systems; i (e) monitor liquid levels and to alarm potential over- l flow conditions; i (f) control, if feasible, and moni?or all potential j release pathways of radionuclides pursuant to 10 r C.F.R. 50, Appendix A (General Design Criteria 60 and 64); r (g) integrate the required treatment with the vaste processing and solidification systems; , (h) have the same level of security as exists for the plant protected areas; and (1) be heated electrically for freeze protection. 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 l 2.3 million gallons of processed water? A.16 It is estimated that it will cost $9.1 million to con-struct tankage meeting the standards of Generic Letter 81-t& 39  ; (5-year storage period) and capable of holding 2.3 million gal-  : lons of AGW. A detailed cost breakdown is contained in Table 3. Q.17 In response to summary disposition motions, the Joint  ! Intervenors speculated that new technology may develop which will reduce storage costs. What do you believe the potential is for new technology which will reduce the storage costs? () I

464 A.17 Scientific research and development always give reason /~T to hope that technological advances will bring safer and cheaper V technology. Hovever, at the present time, I am not aware of an/ 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 Intervenors, from the standpoint of costs? A.18 If our proposal is approved, GPUN will have spent about $4.1 million to lower the level of radioactivity and to dispose of the AGW by evaporation, a process which, according to W boas the testimony of Dr. Baker, vill reduce the off-siteA doses t; th: ;. ta bonesto Fv6 mrem for the hypothetical maximally exposed individ- , o.cos ual, and to 4.411 mrem for the average person within a 50-mile O Ns 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 oute one is left with the additional $1.3 million to 39.1 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 m e.. W  : small doses by :n:-half, is unjustified in my view on ALARA or any other cost / benefit bases.  ! {} i

465 P O 74.u i tatuffricATION OF RAnfomuCLlots IN P40Ct15t0 WAftt Column 1 Column 2 Column 3 Column 4 Column 5 Curies Concentrat*,en spec 1fic Total Grams Present in in vC1/m1 Activity in A-2 Present in linL1.idai LA.f5&L jn 2,3 m g,itarsa 2.3 m6AL I l l l Y.t.hti l Ce n t ue-137 l 3.2C-1 l 3.7t-S l 9.St+1 l 10 l 3.7t-3 Ce n t um-134 1 7.648-3 l 0.81-7 l 1.2t+3 l 10 ( t.34t-4 Stronttue-90 l 9.4t-1 l 1.1 t-4 l 1.St+t l 0.4 l 6.4t-3 Antimony-125/ l 2.0t-2 l 2.3t-4 l 1.4t+3 l 25 l 1.43t-5 i Tellurium-12$a l l l 1.St+4 l 100 l 1 Cart >en-14 i S.7t-1 l 1.0E -4 l 4.6 i 60 1.09C-2 , Technetium 99 l 8.71-3 l 1.0E-4 l 1.7t-a l 2s S.12t-i tron-SS l 4.2C-3 l 4.08-7 l 2.2t+3 l 1000 ' 1.91t-4 Cob 41t40 l 4.21-3 1 4.81-7 l 1.1t+3 l 7 1 3.at-4 , t odine-129 l 45.2t-3 l <4.0E-7 l 1.6t-4 l 2 l.43.39t+1 l Cerium 144 l <1.4E-2 l <1.8t-4 l 3.2t+3 l 7 l <4 . 386-4 . Manganese-54 l < 3. S t -4 l <4.0t-4 l 8.3t+3 l 20 l <4.21-8 l

                                                              ".4.0t-6                 3.1E+4                    l      20                  <1.13C-4           :

Cobalt-S8 l 43.SE-4 l l l Nickel-43 l <S.2t-3 l <4.08-7 1 4.6t+1 l 100 l < 1. 4 -4 l lint-65 l 58. St-4 l <t.St-4 l S.0t+3 1 30 l <1.06t-7 l O Ruthen t um-106/ Rhodium-104 l l

                                  <2.9t-3              1 l
                                                              <3.3C-7         l l

3.4t+3 l l l l l

                                                                                                                                            <S.53t-7 i

l

                                                                                                                                            <l . 04 t-I S t iver-110m          l     <4.st-4                     < S . 6t -4     1        4.7t+3                    l         1        l Promethium-147        l     <4.2C-2                .

44.St-6 l 9.4t+2 l 25 l <4.478-5 i Europium-152 <3.3t-4 l < 3. S t -10 l 1.9t+2 l 10 1 <1. 7 4 t -g I l , Europium-154 l < 3 . 08 -4 l 44.4t-4 l 1.St+2 1 5 l <2.S3L4 i Europium-155 l <t.6t-4 l <1.It-1 l 1.4C+3 l 60 l <6.84t-7 Uranium-234 l <a.7t-S l <1.0E 8 l 6.2C-3 1 0.1 1 <1.40t-r Urantum-235 i <1. 0 t -4 l <1.2t-8 l 2.It-4 1 0.2 l <4.76t+1 i Uranium-238 i <l . 0t-4 l <l.2L-s 1 3.3t-7 unlimited l <3.03C.2 l Plutonium-230 l <1. 0t -4 l <l.21-0 1 1.7t+1 l .003 l <b.88t-4 [ Plutonium-239 l <1.2t-4 l <1.4t-a l 6.2C-2 l .002 l <1.14t-3 ' Plutonium-240 1 <1.2t-4 l 41.4t-4 l 2.3C-1 l .002 l <l.22C-4 Plutonium-241 l <S.7t-3 l <6.St-7 l 1.1t+2 l 0.1 l <b.18t-S  ; Americium-241 1 <1.0t-4 l 41.2t-4 l 3.2 l .000 1 <3.13t-S l Curium-242 l 48.7t-4 l 41.0t-7 l 3.3t+3 1 0.2 1 <2.64t-7 l l 1 l l Total I <2.27 C1 l <2.6t-4 wC1/m1 l l<3s4.66 grams , t l l l l l I

                                                                                                                                                               \

l O [ I i ar . p._ ,,mm.,_-.c

e 466 4 TABLE 2 i I}-

        \                                                                                                                                                      !TEMIZED COSTS FOR THE EVAPO 6.T!ON PROPOSAL 1

Distillation & Packaging of Bottoms Preliminary Design 5 36,000 l Fabricate, Test & Install Equipment $801,000 t Training & Psychological Screening S 5,000 t Distillation of 2.3 MG Processed $735,000  ; Mater Pack &qing of Evaporator Bottoms S 80,000 i Demobilization s 33.0QQ Subtotal $1,690,000 f i Disposal of Evaporator Bottoms 17 C 55-gallon Drums (590) $ 24,000 Truck Shipments (8) $ 40,000 i GPUN Loading Operations

                                                                                                                                                                                                   $ 10,000                                               .

Disposal of Class A Drums $220.000 l Subtotal S 294,000 Preprocessing 31% PW Volume $2,100,000 i (Total cost, including all operations

              "%                                                                                                              & handling resin, liners, transportation (d
      '                                                                                                                       & burial)

TOTAL COST: / $4.084.000/ ( r b L r O -1s-

b 467 i I TABLE 3

                                                                          !TEMIZED COSTS FOR GENERIC LETTER 81-38 TANKAGE

(] Direct Costs , Labor . $1,800,000 ' Materials s4.700.000 Subtotal $6.500.000 Indirect Costs - j Construction Management $1,630,000  :' Engineering / Administration s 175.000

  .n.

Subtotal s1.805.000 . Contingency at lot s 830.000 TOTA!. EST! MATED COST: / $9.135.000/ j l t b' o  ; i I

r t

k I i i i

j. 5 I

r (

i f

i O  ! I i l- .  : , i t [

468 RESUPE O David R. Iuchanan P.O. tex 440 . Mfddletown, PA 17057 , WORK HISTORY 07/80 - Present

!                                     GPU Nuclear corporation /GPU service corooretten 4

Current 7f tie Manager, Recovery Engineering TMt.2 Dept./ Loc. : 31te Operatiens, TM!-2 i i Responsible for all engineering support, eacept for i 1 defueltag$ include p ant modificationsto the TN!.2 Division. Act

                                                                    , support to Operstfens and Maintenance, Radtecheetcal tagineering, '

} start Up and Test, 6nd Fire Protectfen. Tne

sectfen mes formed September 1908 Site Engineering and Plant Enginee, ring sectfeno.by cas i 02/06 08/06 -

j - Manager, Sito Engineering TM!-2. Provided on site engfneering recovery support to ensure technical adequacy of efforts.

,                                                           Prepared and reviewed safety
evaluetfens and sodtffcatfen pactases, plus

) developed and managed the program Per Important to { Safety (!T$) determinetten te correctly classify j recovery programs work. Also, responsible for , TM!-t Start.Up and Test activtties. i 12/M - 2/88 - Task Leader, Reactor Of sassembly and Defueltnq. 1 Responsible for provtding pro and technical overvfew for ongressette direct < en site recovery { 4 sctivities related to reactor defuelf ag/ disassembly ! as asstgned by the Manager Recovery Programs.

Assignments includu defueling plus defueling water l clean up systems Weste Mand 11pg and Packaging Facility, and the Sedfaent Transfer systes.

! Og/et 11/04 - l Manager $tte tagineering, TW!.2. Same as durfng February 1908 through August 1986 08/81 09/02 - { Manager, Project tagineering. Managed the Project tagineering section te include directfen of l technical wort, monitoring attatament of department ! cost / schedule goals and maaging projects such as RCS Processing, EPIC 04 Venting, and engineering involvement in the Qufck Look Entry. O M

1 469 i

0. R. Suchance O Page 2 4

07/00 - 04/81 Supervisor, Recovery Technical Planning. Supervised technical planning efforti, associated with initial recovery at TMt.t. 01/64 - 07/80 - isostinghouse tiectric Corporetton_ Employed at lettis Atomic Power Laboratory in the l positions of Associate tagineer, Refueling  : Equipant Design and Operations; Senior Engineer, Fluid Systems; Superviser/ Manager, Manual W1 ding Support; Materials Evaluation Lateratory , Engineering Managert and Decentaminettee i Engineering Manager. 07/59 - 12/83 - U.S. Steel Carperetten , i Entered management training program. Majority of l asperience as Aell Designer for structural and  ; plate mills. 1 EDWAT!(N B.S., Mechanical Dgineering, Lehigh University,1989 [ LICENSES AND CERT!F!CAfts , j P.E. License, state of Pennsylvania,1965 [ l t  : I 4 i  ! l . i  ! l \ r i lO t l t r

470 ; i MR. BAXTER: Your Honor, we also move the f O 2 edmission of Licensee 's Exhibit Number 1. ' 3 JUDGE BLOCH: This is an admission as reference or { 4 as evidence? 5 MR. BAXTER: Evide nce. 6 JUDGE BLOCH: And there are no objections? 7 (No response) I 8 JUDGE BLOCH: Then Exhibit Number i also is 9 admitted into evidence. , 10 (The document referred to. I 11 having been previously marked [ 12 for identification as 13 Licensee's Exhibit 1. vas [ 14 received in evidence. ) [} 15 BY MR. BAXTER: p 16 Q Mr. Meaver. I call your attention to a document j 17 that bears the caption of "The Proceeding." It*s dated  ! i 18 October 11. 1988 and it is entit led "Licensee 's Testimony of i 19 William W. Weaver on Accident Risks (Contentior. 2)" 20 consisting of eight pages of questions and answers and one l 21 at t achmmit . [ 22 Does this reflect testirony prepared by you or l 23 under your supervision for presentatiori at this hearing?  ! l I

                        '4                                   A (Weav er) Yes. $t does,                               j i

25 MR. BAXTER: I have a correction in one of the l l () Heritage Reporting Corporation (202> 628-4888 f

                           ,                                                                                    471 l

i questions. On Page 7 in Question 8. the last sentence of 2 the question should read: "Is it correct?" Instead of "Is 3 i s. . . " 4 BY MR. BAXTER: 5 Q Mr. Weaver, do you have any corrections to your ) 6 tectimony? t 7 A (Weaver) Yes. I have two corrections. l 8 Page 3. A . 5. fifth line. "O.17"should read "O 17 9 percent". 10 JUDGE PARIS: Should read "O.17 percent"7 11 THE WITNESS: (Weaver) That 's correct. 12 JUDGE PARIS: Thank you. 13 THE WITNESS: (Weaver) Also on Page 7 A . 8. third 14 line. "3.6 millirem" has been changed to "0.4 millirem". 15 "2.0 millirem" has been changed to "1 3 millirem". 16 BY MR. BAXTER: 17 Q As corrected. is the testimony true and accurate 18 to the best of your knowledge and belief? 19 A (Weaver) Yes, s i r. 20 MR. BAXTER : I then nove that Mr. Weaver 's I 21 testimony be received in evidence and incorporated ir 'o the 22 transcript as if read. 23 JUDGE BLOCH: There being no obj ection, that shall 24 be done. i

25
Heritage Reporting Corporation d

(202) 628-4888 l

472 1 (The "Licensee 's Testimony of 1 2 William W. Weaver on Accident 3 Risks (Contention 2)" is 4 inserted into the record and . 5 follows:) 6 I 7 l 8 'l 10 l- 11 12 l 13 i 15 1 16 i 17 l- 18 19 1 ' 20 1 21 22 23 I 24 25 h Heritage Reporting Cocporation (202) 628-4888

                                     ~

473 October 11, 1988

i. . UNITED STATES OF AMERICA i 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) ) J LICENSEE'S TESTIMONY OF WILLIAM W. WEAVER ON ACCIDENT RISKS (CONTENTION 2) 9 i O l

        . _  -    ~ . , . .

474 Q.1 Please state your name. (~) A.1 William W. Weaver. v Q.2 Mr. Weaver, by whom are you employed, and what is your position? A.2 I am a self-employed consultant for GPU Nuclear Corpo-ration ("GPUN") at Three Mile' Island Nuclear Station, 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 Marine Engineering, a M.S. de-gree in Nuclear Engineering, a M.B.A. degree and have completed all course work for the Doctorate in Business Administration and Operations Research. I am certified by the American Society for Quality Control as a quality engineer and as a reliability engi-(]) neer. I am responsible for developing probabilistic risk assess-ments for THI-2. I have over 12 years experience in the field of probabilistic risk assessment. I previously was supervisor of probabilistic risk assessment at Babcock & Wilcox Company. A complete statement of my professional qualificaticas is repended as Attachment 1 to this testimony. Q.4 What is the purpose of thia t9stimony? A.4 I will address the issues retiaining on the risks from acciden'es associated with GPUN's proposal to evaporate the TMI-2 Accident-Generated Water ("AGW") and with the alternative raised (

       - - ~ - . . - - - , - - . - - . . , . - - , -     .       , _ _ _ , _ _ _ _ _

i 1 475 a- by the Joint Intervenors involving on-site storage followed by 7s disposal. In addition, I will specifically address the Licensing > (m) l Board's conclusion in its August 25, 1988 Memorandum and Order regarding the dose calculations from an accident involving the Joinc Intervenors' alternative. Q.5 What are the potential risks associated with the evapo-ration proposal? A.5 The ev,poration procecs is estimated to last from 15 to 24 months. During that time, the AGW will be stored in an ap-proximately 500,000 gallon tank prior to be8ag vaporized. The probability of a:, uncontrolled release from the stagino tank is estimated to be 0.177.over a 24-month period with a re. ting dose of 2.50 mrem from the liquid pathway and 1.79 mrem from the air-borne pathway to the. critical organ-the bone. () The transportation of evaporator bottoms to a disposal site involves radiological and non-radiological risks. Radiological - risks include occupational dose to drivers and handlers of AGW , and dose to members of the general population. The general popu-lation dose consists of routine dose exposure to by-standers and other vehicular passengers in addition to accident dose due to ttansportation mishaps.

It is estimated conservatively that disposal of evaporator bottoms will require 8 to 12 truck shipments to che burial site.

The average activity of each shipment is expected to be less than 0.5 curies total activity. The shipments are assumed to travel l () l L

476 along the least risk route (in terms of population density as de-termined by INTERSTAT computer code) from TMI to Hanford, ({} Washington, which would be an estimated distance of 2800 miles. Using the RADTRAN computer code, the incident free popul tion

     . dose from 12 shipments would be 10.4 person-rem. The estimated dose to the driver per shipment is 95 mrem.

The expected number of traffic accidents and fatalities for these shipments is 0.049 and 0.002, respectively. Taking into account the severity and probability of the accident, the popula-tion density along the least risk route, and the resulting re-lease fraction or radionuclides produces 0.003 person-rem expect- , ed from these shipments. an addition, the preprocessing of 31% of the AGW will' pro-duce approximately 40 liners which will require 20 to 40 ship-ments for disposal and represent a disposal volume of 6,200 ft3 (]) The expected number of traffic accidents and fatalities resulting from disposal of these liners 'is 0.093 and 0.0038, respectively. The expected dose to each driver would average approximately 15 mrem per shipment. The incident free dose to the general popula-tion from these shipments is 4.8 person-rem, and taking into account the severity and probability of an accident, the estimat-ed accident dose is 0.56 person-rem. Q.6 What are the risks associated with the Joint Interve-nors' alternative for disposition of the AGW involving on-site storage followed by disposal? ()

477 l A.6 Storage of the AGW on-site presents the continued risk (^) of a radiological accident. An uncontrolled release could occur ) v as a result of damage to one or more tanks due to an external event or due to tank failure (e.g , leaks due to the aging pro-External events that were found to contribute to the re-cess). lease probability include airplane crashes, tornados, floods and seismic events. The probabilities associated with the occurrence of external events that could cause a breach of the AGW tanks were derived from the Probabilistic Risk Assessment performed for TMI-1, analyses performed for the Probabilistic Risk Assessment for TMI-2, data contained in the TMI-2 FSAR, and data obtained from the Harrisburg Office of the U.S. Department of Interior, Geological Survey Water Resources Division. The probability of a leak or rupture can be examined from comparable tank failure rates. (]) The probability of an uncontrolled release over the 30-year period has been estimated to be roughly 3.75%. The weighted av-erage release (at the fifteenth storage year) results in 5.3 mrem ' via the inhalation pathway and 7.1 mrem via liquid release path-vays to the maximally exposed individual. Q.7 on page 15 of its Memorandum and order of August 25, 1988, the Licensing Board stated: The oniv credible accident identified for this alternative lthe "no-action" alternative) is tank rup-ture, which in the worst case would result in discharge of the entire contents of a tank in a short period of time. Ibid. Staff estimated that the 50-year dose to

                                                                                                             +

b

i 478 the maximally exposed individual in the event of an ac-

   ,_              cidental spill from an 11,000-gallon storage tank would (l               be 0.015 mrem to the bone and 0.002 mrem to the total
                body. The collective 50-year dose commitment to the affected population vould be 0.7 person-rem to the bone and 0.015 person-rem total body.      Id. at 3.8-3.9.

Is this correct? A.7 No. The Board apparently is discussing the vorst case scenario for an accident under the "no-action" alternative. Hov-ever, the Board is using the Staff's accident analysis for the evaporation proposal. On pages 3.33 and 3.34 of PEIS Supp. No. 2, the Staff presents its accident analysis for the "no-action" alternative. There, the Staff states: The only credible accident ideatified for this altetna-tive (the "no-action" alternative) is tank rupture, which in the worst case could result in discharge of the entire tarsk contents in a short period of time . . . . The prompt acci- ' dental discharge of 2.3 million gallons (8.7 million literii of this water vould result in a bone dose of 3 mrem and a () total body dose of 0.4 mrem for the maximally exposed indi-vidual, assuming that individual ingests water and fish from the Susquehanna River and participates in recreational ac-tivities such as swimming and boating. . .. The collective 50-year dose con'itment to the popula-tion is estimated to be 40 person-re.4 to the bone and 1.0 person-rem to the total body from ingestion of drinking vater and fish from the river, participation in recreational activities, and consumption of shellfish from the Chesapeake Bay. The total 50-year dose :ommitment to the larger popu-lation would contribute 100 par ~ -rem to the bone and 3 person-rem to the total body. a.ase dosen vould be lower after some radioactive decay. Therefore, the data presented on pages 3.33 and 3.34 is the Staff's accident analysis for the "no-action" alteenative. f 9 4

479 Q.8 On page 25 of its Memorandum and order of August 25, 1988, the Licensing Board concluded: (} (T]he dose commitment resulting from an acci-dental discharge from a tank would be very small, representing a small fraction of the radiation dose that would result from forced evaporation. Is rk correct that the dose resulting from an accident during the Joint Intervenors' alternative would be a small fraction of the dose resulting from forced evaporation? A.8 No. According to the testimony of Dr. Raker, the esti-mated doses to the maximally exrosed hypothetical off-site person o.4 for the duration of the evaporation process will be 4,4 mrem to 1.5 the bone and Gv4 mrem to the total body. By contrast, the weighted average release from an accident involving the Joint In-tervenors' alternative results in 5.3 mrem via the inhalation 7 pathway and 7.1 mrem via liquid release pathways to the maximally exposed individual. Thus, the dose commit.7ent resulting from an accident during the Joint Intervenors' alternative would be greater than the dose commitment resulting f rom tite evaporation process. Q.9 Mr. Weaver, in conclusion, how would you compare the risks from accidents associated with the evaporation proposal and the alternative identified by the Joint Intervenors? A.9 The risks from accidents associated with the evapora-tion proposal are definable and not significant. By contrast, all of the risks associated with the J 9nt Intervenors' ()

    ,.  ._ ,  ,                    _.       _   m  -. _ . , . ,       ___      -

480 alternative cannot be identified. At thir time, can identify r~T the risks associated with the storage component of the Joint In-V However, there are acditional risks from tervencrs' alternative. ultimate disposal which must be factored into the accident analy-sis for the Joint Intervenors' alternative. In my view, on the basis of risk annlysis alone, the better course of action would be to go forward with the evaporation proposal now and not in-crease the riska and exposures to the public by continued storage of the AGW followed by eventual disposal with all of the atten-dant risks of both storage and disposal. i l i O

481 WIL'.!AM W. WEAVER O eeeeeeeeee.'eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeee RELEVANT WORK EXPERIENCE Self-Empleved Consultant 1987 to prenant On-Gite Consultant et Three Mlle loland. Safety Review Group l quellf fed. Member of Emeegency Reaperee team. Alternate l Special Nuclear Material Coordinate. Work esope incluees < aieveloping a PMA for Unit 2 and Chapter 18 assidente for WAR submittel. P.e**ermed multi-et'ribute doeleien theory analysis on bloath well dispeellion doeleien. l Saboeck G Wilcom . 1993 to 1990 On-Gite PRA/Rellability Censultant et Three Mlle leland. Wmber of emergency reopense team. A' ternate Speelei Nuoleer Meewlete Coordinator. Work esepe included analysing lemuse (igirig a probabillette perspective) on e cess ty-case besie such as exemptioo-from solemic requiremente. beren dilution concerne. , O and Fire Henards Analyela. Performed reliability analyses on , routine hardware such as plant cranes and unique hardware ruch as  ! the Roeot Vehicles. 1082 to 1983 Fellowohlp to Derden Suelnese School. University of VirgMio. Work concentration'in Optimization. Scheduling. Decialon Making under Uncertainty, and Strategy Formulation and Strategy implernentation. 1980 to 1982 Supervisor of PRA Group. Responsibilities included technical supervisor of group and individual projects. Individual work scope included princical reviewer for Crystal River IREP. input to Oconee/NCAC offert. and peer erviewer on NUREG/CR-2300. 1975 to 1980 Rollability Engineer in technical staff grasp. Performed enelyses ( (Foult Tree. R80. FMEA. Markey) on mechanical and electrical systems including APW. MFW. HPl. LPl. ESPAS. RPS. and ICS. j Cost /8enefit and Aging Analyses. Project leader with budgetary  ; roepwnelbility for RAM RGO estivities. l t i e PART ACTIVITIES l O aevi~er r- ~RC inastrv Praanisii aia Aa -n Guia ea-

  • IEEE Subcommittee 5,4 Working Group i
  • Atomic Industrial Forum Subcommittee on PRA I
      ' Interdivlelonel SGW Rolletility Committee e

482 PARTIAL PUBUCATION LIST O T he i m ,est e, a.in. Mechanisme on ase ior Safeiv Performance.- (co-author eith E. Celkere (BS.WB. Nuoteer solence and Engineering. Volume 60. No. 3. December ig78 s .

        * ' Aging Tgchniques and Quellflod Life for Safety System Components.' Nuclear Safety, Volume 21. No.1. Jan - Fete 1980
        * ' Deterministic Criterie Versus Probabilletic Analyese: Examining the Single Fellure end Separation Criterie.' Nusteer Technology. Volume 47. No. 2. February 1900
        * 'Auxillery Feedwater Rollability Analytes for Plants with BGW Designed NN's." (co author with R.S. Ensinne and R.W. Oormen (SGWD. ANS 26th Annual Meeting. June 6-12. 1980, Lee Vegas
        * 'Probabillesle Analys,la and IREP Studies.* (co auther with E.R. Kane (SGW) and P.M.         '

Abraham (Duke PowerD. presented at the 7th Annual Nuclear Operating Experience Conferews. Atlante. March 1981

        * 'PItfalle in Current Deelgn Requiremente.' Nuoteer Befety, Volume 22. No. 3. May , June 1981
        * ' Methodology and Application of Cost-Genefit Analyels' MPW System.' (co auther with S. Ahmed (BGWU presented at ANS ICel Annual Meeting. Mia.i. PL                    _,
        * 'A Decielon Methodology fr/ Quantl43tive Safety Goal Allocations for Nuclear Power Plants.'

(co-author with S. Ahmed - (SGWD. Proceedings of the ANE/EW Topleal Meeting on O Probabilletic Risk Aessesment. Sept. 20-24.1981. Port Ctwater (Invited]

        * ' Estimating Failure to Close Probabilitlee for Pressurizer Velves.' presented at the Internettonal Meeting on Thermal Nuclear Safety. Chicago. IL. August 2g - September I.

1952

        * ' Insights from the TMI-2 LQOP Analyele." (co-author with F.W. 011ninger (Fen-Pac)L ANS.

i Reno, June 1986

        * 'A Method to integrate PRA Results with Plant Upgradee.' ANS. Washington. OC. Novem-ber 1986 (invited)                                                                         ,

EDUCATION , I

  • United States Morehent Marine Academy - BS Maine Engineering
  • Meesechusette Institute of Technology - MS Nuclear Engineering
  • George Weehlngton Univoretty - MBA
  • University of Virginia - All course work completed for Doctorate in Susiness Aoministration and Operatione Research l PROFEWlONAL CERTlPICATIOM
         ' Certifled QL .ity Engineer - ASQC i
  • Certified Rollability Engineer - ASQC
  • 3rd Engineer Steam and Olseel. Any Horsepower - USCG

,1

  • SW $

483

     ,x
     ,         1                 MR. BAXTER:   The witnesses are available for cross 2'     examination.

3 CROSS EXAMINATION 4 BY MS. SKOLNIK: 5 Q Mr. Buchanan, on Page 5. Line 5, you say that the 6 reactor vessel required processing by the SDS and the WCS. 7 Could you clarify for us please, does it not require 8 EPICOR? 9 A (Buchanan) At the very minimum, the RCS water was 10 going to require DWCS and/or SDS processing. EPICOR 11 processing really gets to be more of a runction of'what do 12 you want to do with that water. If I want to stage that 13 water for final decon. activities or staging it for the 14 evaporator, then yes, then EPICOR processing would also be (J-) 15 necessary. , 16 Q Will you want to use the EPICOR system for the 17 water that is presently in the reactor vessel? 18 A (Buchanan) Yes, we will be. 19 Q And the SDS system will also continue to be used? 20 A (Buchanan) No, the SDS vessel is no longer being 21 used. 22 Q Has the water that is presently in the reactor 23 vessel been through the EPICOR SDS system since GPU 24 submitted their proposal in 19867 25 A (Buchanan) I don 't really remember the last date () Heritage Reporting Corporation (202) 628-4888

1

                                                                    '484'
 ,s  .i when we utilized'the SDS system for RCS processing.        It's 2 been a while-   So I 'm not sure of that detail. DWCS 3 definitely. EPICOR, there has been some water from the RCS 4 that has received EPICOR processing.

5 Q Could you let us know what percentage of the 6 60,000 gallons in the reactor vessel has gone through the 7 EPICOR? 8 A (Buchanan) No, I can 't tell for sure. 9 Q How adequately does the table in the GPU proposal 10 reflect the water that is presently in the reactor vessel? 11 MR. BAXTER: Obj ec t ion. Mr. Chairman. That is 12 what the last panel was on the stand for. We 're not talking 13 now about the. sampling analysis of the water. What {} 14 15 JUDGE BLOCH: is your response? The obj ection is irrelevance. Excuse me. It 's not relevant to the 16 ritbj ect matter of this testimony. 17 MS. SKOLNIK: What I 'd like to determine is the 18 influent to the evaporator. 19 JUDGE BLOCH: Is there some testimony here that 20 you are cross examining on? You 're cross examining on this l 21 testimony, i ! 22 MS. SKOLNIK: Yes. ! 23 JUDGE BLOCH: So which testimony is this relevant 24 to? 25 MS. SKOLNIK: Mr. Buchanan 's. O Heritage Reporting Corporation (202) 628-4888

485

   -    1            JUDGE BLOCH:     Which portion?

2 MS. SKOLNIK: On Page 5 where it starts, it is 3 describing the water. 4 MR. BAXTER: That 's an historical reflection on 5 how we got to today 's point leading up to the introduction 6 of the evaporation proposal. Mr. Buchanan is not 7 characterizing the isotopic content of the water. Simply 8 giving historical facts about the treatment that 's taking 9 place, and the volume. 10 MS. SKOLNIX: However, Mr. Luchanan will be 11 answering questions on the evaporator, so the contents of 12 the water going into the evaporator are relevant. 13 MR. BAXTER: That 'r why we had testimony on it. 14 But it wasn't by these witnesses. 15 JUDGE BLOCH: You can ask him how the evaporator 4 16 could handle different kinds of influent. 17 MS. SKOLNIK: Okay. 18 JUDGE BLOCH: Pref erably it won 't be questior.s 4 19 that he 's already answered in the direct testimony, though. 20 BY MS. SKOLNIK: 21 Q If defueling and decontamination activities 22 continue through 1990, how much water vould be added to the 23 2.2 million gallons which you state on Line 6? 24 A (Buchanan) Well, there is no way of giving a 25 de'inite proj ection. You can look at past trends and make heritage Reporting Corporation (]) (202) 628-4888 L

4 486 1 some reasonable forecast, but I, you know, I can 't say for

  .(f,)
                 -2   sure just how much water will be in the inventory at the 3   time of defueling or decontamination completion.

4 Q Could you estimate how much is leaking in each 5 month? 6 A (Buchanan) If you go back over the last couple of 7 years, we are seeing a total increase in inventory of about 1 8 100,000 gallons a year so if you want to make a straight 9 line proj ection, that 's reasonable. But it could be more or 10 it could be less. 11 Q When you originally conceived the proposal and 12 presented it to the NRC, at that time did you know that the 13 water would go from the reactor vessel into the evaporator? 14 A (Buchanan) I 'm not sure I understand the

      )

15 question. Water -- did I know the water was going to go 16 from the reactor vessel to the evaporator? 17 Q All right. Let me reframe that. Did you know 18 that the evaporator would be used to decontaminate the water 19 as well as to evaporate the water and release the vapor? 20 A (Buchanan 1 When did I know this, you 're asking, 21 in 1986?  ; 22 Q Yes. Did you know that when you presented the 23 proposal? 24 A (Buchanan) 1986 we were just trying to develop. 25 you know, conceptual methods, you know, basic technology to i r () Heritage Reporting Corporation (202) 628-4888 l l

487

  -  1                   apply to the program.           Clearly the details of what the 2                   system was going to look like was not known at that time.

3 Q On Table 1 of Page 14 of your testimony, is Column 4 2 the same as the base case in PEIS Table 2.27 5 A (Buchanan) Yes, I believe it is. 6 Q That base case reflects the estimated average l 7 concentrations of the water if Lt had gone through EPICOR l 8 and SDS. is that true? 9 A (Buchanan) Yes. 10 JUDGE BLOCH: Terrific. I 'd like to encourage il answers of that length. Just answer directly. 12 BY MS. SROLNIK: 13 Q Yhich column on this table reflects the 14 concentrations of the water which would be going into the 15 evaporator without EPICOR SDS treatment? 16 A (Buchanan) There is no column I suppose in this i 17 table. You like short answers. But you 've got to keep in l l 18 mind. I think this has been explained before. Column 2 , l 19 represents a list of values that assuming a DF of 1.000 will 20 achieve the desired vaporizer effluent. So if you take what l 21 you want to have come out of the evaporator -- correction. l 22 If you know what you want to have come cut of the vaporizer. 23 multiplied times 1.000, then you will get these values that 24 are listed in Column 2 So you have a vatlety of ways in 25 which you can get to the values in Column 2 You can l t () Heritage Reporting Corporation (202) 620-4888

       , , , _ - ~ . . .        _ _       _ _ _ . . _ .   . _ _ _ _ _ . _ _ _ _ . - . . , ,        .   ..   . . - , . .   - __- _ __

488 >7s i preprocess. water through any type of ion exchange system, b 2 might be a way, and it might also be feasible to have it go 3 through the evaporator in what we refer to as the batch 4 mode. 5 So your question about where is the list of values 6 associated with batch processing ir the evaporator, you 7 could say it is also this Column 2, or it could be through 8 the EPICOR ion exchange system. 9 JUDGE BLOCH: Am I correct in understanding that 10 Column 2 was derived from going backwards from what you were 11 willing to release, when you figured what you had to have as 12 input and i' it 's how you got Column 2? It really had 1 13 nothing to do with SDS and EPICOR? (Buchanan) {} 14 10 THE WITNESS: think of it because then you have a target which to shoot That 's the way I like to 16 for. Now you would have an understanding of how good you 17 performance needs to be of your ion exchange system. 18 JUDGE BLOCH: Was that actually the way it was 19 done? 20 THE WITNESS: (Buchanan) Quite honestly, I don 't 21 know. I was not involved in that detail development in '86 22 JUDGE BLOCH: Your testimony is that whether it 23 was done that way or not, that 's the way it works. 24 THE WITNESS: CBuchanan) That 's the way it works. 25 though.  ; () Heritage Reporting Corporation (202) 628-4888 r i

1 489

      ~

1 JUDGE BLOCH: So if you can meet these goals for

 - l) 2 influent, you 'll get the result you need?

3 THE WITNESS: (Buchanan) That 's correct. l t/30 4 BY MS. SKOLNIK: 5 Q How many times will the reactor vessel water have 6 to be treated in order to meet the criteria for the influent 7 to the evaporator before it goes to the vaporizer? 8 A (Buchunan) I 'm certainly one pass through the 9 EPICOR system will be adequate. 10 Q That would assume that the strontium concentration 11 was 1.1 E to the minus 7; in order for it to come out as 1.1 12 E to the minus 4, it would have to go in as 1 1 E to the 13 minus 7? 14 A (Buchanan) No, no. You're going the other way. { 15 JUDGE BLOCH: E to the minus 7 is a smaller number 16 than minus 4. 17 BY MS. SKOLNIK: 18 Q Okay. 1 1 E to the minus 1 It would have to go 19 into the evaporator ao 1.1 E to the minus 1 in order for it 20 to come out as 1.1 E to the minus 47 21 A (Buchanan) With a DF of 1,000 4 22 Q With a DF of 1,000. 23 Q On GPU proposal Table 2-3, we 're given the actual 24 cource terms, and the strontium value there is 1.80 E to the 25 00. In order -- how many times -- () Heritage Reporting Corporation (202) 628-4888

(. 490

   .s     1            MR. BAXTER:   Excuse me. The witness, do you have
  'km)    2 a copy of that?

3 THE WITNESS: CBuchanan) Give me some time. What 4 are'you referring to? 5 MS. SKOLNIX: It's the GPU proposal, July 1986. 6 THE WITNESS: CBuchanan) Table -- ? 7 MS. SKOLNIK: Table 2-3 Page 12 8 THE WITNESS: (Buchanan) Okay. 9 JUDGE BLOCH: Is that document already in the 10 transcript? Off the record. 11 (Discussion off the record) 12 JUDGE BLOCH: Back on the record. I 'll have to 13 ask Ms. Skolnik to attempt to make her questions 14 intelligible without reference to the document for ease of {} 15 reference within the transcript. 16 MS. SKOLNIK: l 'Il try. 17 JUDGE PARIS: I would like to ask if this document 18 is headed "TMI-2 Cleanup Proj ect Directorate. Attention: 19 Dr. W. D. Travers. Director, U. S. Nuclear Regulatory 20 Commission." 21 MS. SKOLNIK: I 'm sorry. What did you say? 22 Sometimes I can 't hear what the Board ir saying. 23 JUDGE BLOCH: I believe Dr. Paris is referring to 24 Licensee 's Exhibit 1. 25 MR. BAXTER: No, sir. () Heritage Reporting Corporation (202) 628-4888

491

      ,. 1            JUDGE BLOCH:   No?
   -l    i 2            MR. BAXTER:   Licensee 's Exhibit 1 is a Technical 3 .. valuation Report dated October 10, 1988 or 7 dealing with 4 this particular system. This $s the original proposal that 5 was filed back in July, 1986.      We discussed it yesterday to 6 some extent. As I indicated, while some of the source term 7 information is used still today that was presented in that 8 document, much of the rest of it is of historical interest 9 only because we had no system design at that point.

10 JUDGE PARIS: Was the cover letter to this 11 document dated July 31, 1986? 12 MR. BAXTER: Yes. 13 JUDGE PARIS: Okay. , 14 JUDGE BLOCH: Then Dr. Paris has the document. 15 Let 's continue. 16 BY MS. SKOLNIK: 17 Q If a concentration of strontium 90 of 1.80, which

18 is the measurement for the reactor coolant system in 1986 --

19 JUDGE BLOCH: Did you say it was the source term? 20 Is it the source term or is it a measurement? 21 MS. SK0LNIK It 's a measurement. 22 JUDGE PARIS: Are you looking in this document? 23 MS. SKOLNIK: I 'm looking in the GPU proposal. 24 JUDGE PARIS: What page? 25 MS. SKOLNIK: July, 1986. Page 12. Table 2-3. () Heritage Reporting Corporation (202) 628-4888

s - _ 492 fs 1- JUDGE BLOCH: Let me ask the witness first, do you

    .(d      2    know whether these -- are these measurements or are they the 3    results of a run of a model?

I= 4 THE WITNESS: CBuchanan) These are based on 5 measurements. 6 JUDGE BLOCH: Measurements. Thank you. 7 MS. SKOLNIK: I 'll ask my question again. 8 BY MS. SKOLNIK: 9 Q If the strontium 90 valLe in the reactor coolant 10 system is 1.80 E plus O microcuries per milliliter, how do 11 you intend to decontaminate that water to arrive at the 12 value in Column 2 to arrive at a value of 1 1 E to the 13 minus 4? 14 A (Buchanan) The water will be processed --

        }

15 MR. BAXTER: I 'm sorry. The testimony earlier was 16 that the influent would be 1.1 E to the minus 1. Isn 't that 17 what you established? 18 THE WITNESS: (Buchanan) The listed number where 19 influent to the evaporator, assuming the coupled mode. 20 straight through, would be 1.1 E to the minus 4 strontium. 1 21 You are going to get there two ways. DWCS lon exchange will 22 reduce it and then from there the water would go through the 23 EPICOR system and we should be able 'o reach the 1.1 E to 24 the minus 4. 25 JUDGE BLOCH: Did you say the SDS? O Heritage Reporting Corporation (202) 628-4888

493 7-y i THE WITNESS: CBuchanan) If I did I meant to say t1 2 .DWCS. 3 JUDGE Bl.OCH: Okay. 4 MS. SKOLN.i K : It 's very confusing. So I hope S you 'll bear with me, please. I 'm trying to understand 6 exactly how you are going to arrive at the influent criteria 7 for the evaporator. And I think a lot of the problem has to 8 do with the proposal being two years old. 9 JUDGE BLOCH: The testimony was he 's going to use 10 DWCS and EPICOR. And that will get you to the influent 11 criteria you believe? 12 THE WITNESS: (Buchanan) Yes, it will. 13 BY MS. SKOLNIK: i 14 Q However, isn 't it true inat the NRC and GPU 15 arrived at the table. Table 2.2. on the basis of the 16 operation of the EPICOR and SDS and not the EPICOR and DWCS? 17 A (Buchanan) DWCS and SDS are for all intents and 18 purposes the same, perform the same function. They are i 19 different systems but they both contain the same type of 40 demineralizer material so their function is roughly 21 equivalent. [ 22 Q Why did you cence to use SDS?  : 23 MR. BAXTER: Obj ect ion, Mr. Chairman, at this 24 point. Our capability to pretreat the water and meet the 25 influent criteria is not an issue in this case. What is at () Heritag Reporting Corporation (202) 628-4888 ( I

l 494 l l' issue is what is in the water and what is going out the .O,. 2 stack and what the health effects are. We 've already 3 established in earlier parts of this case that we can meet 4 the influent criteria and the Board has, in its summary 5 disposition rulings, expressed confidence in our sample 6 program to be used prior to the batch treatment in the 7 evaporator and it really is irrelevant at this point how we 1 8 get to these influent criteria.  ! 9 JUDGE BLOCH: Sustained. These methods of , 10 reducing to the influent criterion were all well known on 11 the record. The testimony really stands for itself. And we 12 have said that they could reduce by one one thousandth in 13 the evaporator itself, too. Your problem is how many times 14 it 'll have tc go through? Is that really still your [} 15 problem?  ! 16 MS. SKOLNIK: Yes. Because it 's the cost that 17 matters and it 's also the occupational dose. j 18 JUDGE BLOCH: Okay. Let me ask Mr. Tarpinian a 19 question. 20 If material has to be run through the evaporator a 21 second time, in order to reduce to the influent criteria 22 that are set in the proposal, can you tell us something 23 about the magnitude of the occupational dose that would be l l 24 received for running it through the second time? [ 29 THE WITNESS: (Tarpinian) Yes. If one assumes a  ; i () Heritage Report ing Corporation (202) 628-4888

l' 4

                                                                                                                          ]

y' 495 I

        ,-            A                      batch of 80,000 gallons which is as large as it can be, that N'K]'   l 2                      would result in a maximum cumulative dose of about one third 3                      of a person-rem.

4 JUDGE PARIS: So if it is run through twice, then S is it two thirds of a person-rem? 6 THE WITNESS: (Tarpinian) Realistically, no, it 7 will be less than that because the second time around it 's 8 going to be much less radioactive and the resultant dose 9 rates from the piping are going to be smaller. 10 JUDGE PARIS: Oh, yes. Okay. Thank you.

                  '11                                    BY MS. SKOLNIX:

12 Q When you say it 's a third of a person-rem each 13 time, what are you assuming is the concentration of the D 14 water in order to give that third of a person? 15 A (Tarpinian) I didn 't say that it would be a third 16 of a person-rem each time. It would be a third of a person-17 rem the first time. And that 's based on the numbers in my i 18 testimony. , 19 Q Well, could you address that part of your 20 testimony right now since it 's come up? 21 A (Tarpinian) What 's your specific question? 22 Q The specific question is in order for you to 23 calculate the occupational dose, what was the concentration i 24 cf the influent into the evaporator? 20 A (Tarpinian) The occupational dose is arrived at () Heritage Reporting Corporation (202) 628 4888

496 js 1 in the following way. I 've assumed the maximum dose rate 2 that I would consider to be allowable for the operators to 3 be operating the evaporator under those conditions. The 4 concentrations in the piping system are those that are 5 reflected in the GPU proposal. Those dose rates I have 6 modeled and have found the dose rates that one would get 7 from the piping are much less than that which I have assumed 8 for the purpose of calculating an upper bound for the 9 occupational dose to the workers. 6 millirem per hour is 10 the maximum dose that I find acceptable for the operators to 11 be working in when they are in the control room. 12 Does that answer your question? 13 Q In other words, you alculated the radiation field 14 to the worker using a model?

     ")

15 A (Tarpinian) No. I calculated the occupational 16 doce to the workers based upon the maximum dose rate which I 17 would allow for those workers. Then I went back and modeled 18 the dose rates in the work area based upon the

                 '. 9                        concentrations proposed by the Licensee 's proposal and found

? 20 that those doue rates would be in fact much less than that 21 which I have used as the basis for calculating the maximum 22 collective dose to workers. 23 Q And which concentrations of the Licensee 's did you 3 24 use in ibose calculations? i i 25 A (7arpinian) I don 't recall precisely the O Heritage Reporting Co rporat ion (202) 628-4888 1

497

   -~  1   concentrations for each radionuclide that I used.
 )   2               JUDGE BLOCH:   Was there a table you used. Mr.

3 Tarpinian? Did you get it from some table? How do we know? 4 THE WITNESS: (Tarpinian) The information was 5 obtained -- I don 't recall precisely which table I used in 6 the calculation and I don't have the calculation on it. 7 JUDGE BLOCH: So I don 't know what to make of the 8 dose rates that come out of amoun*.s rf influent that we 9 don 't know. I don 't know what to uo about that. 10 MR. BAXTER: The witness didn't say his 11 calculations came out of those values. He said in fact that 12 his calculations are dominated by an assumed .6 millirem per 13 hour field. And he did then a calculation from the actual 14 sources and found that that was much less so he went with i the higher figure. 15 16 JUDGE BLOCH: But which actual sources? Was it 17 the influent criteria or was it the source term criteria?

18 THE WITNESS
(Tarpinian) The influent criteria 19 for the vaporizer?

20 JUDGE BLOCH: Yes. 21 THE WITNESS: (Tarpinian) Oh. It 's boced on the 22 source term criteria -- I 'm sorry, the influent critoria for 23 the evaporator. I mean the influent criteria for the 24 vaporizer. 25 JUDGE BLOCH: So it 's i 000 times the influent Heritage Reporting Corporation i (]) (202) 628-4888

498

      ,s
      ,     1 criteria for the vaporizer?

('") 2 THE WITNESS: (Tarpinian) I don 't understand the 3 question. 4 JUDGE BLOCH: Maybe it would help if you would ask 5 some direct queotions without leading to see if we can 6 figure out what the enounts were that were small compared to 7 what was permitted? 8 MR. BAXTER: In calculating a radiaticn field. Mr. 9 Tarpinian, did you use the assumed, the values that would be 10 entering the disposal system, the radioactivity levels 11 entering the disposal system? 12 THE WITNESS: (Tarpinian) Entering into the 13 cvaporator? 14 MR. BAXTER: Yes. 15 THE WITNESS: (Tarpinian) Yes. 16 JUDGE BLOCH: Would you be able to recognize a 17 table of those values or wouldn 't you? 18 THE WITNESS: (Tarpinian) Yes. 19 JUDGE BLOCH: Well, let 's first show him the table 20 f rom the PE S, 21 THE WITNESS: (Tarpinian) I would like to direct ] 22 your attention to the table previously referenced by Ms. 23 LMolnik. 24 JUDGE BLOCH: What is the title on that table? 25 JUDGE PARIS: It 's the number. , () Heritage Report ing Corporation (202) 628-4888  ; L___

I 499 r 7s2 THE WITNESS: Okay. I refer you to 1 (Tat I] 2 Table 1 of the testimony by Dava Buchanan on Page 14 of his  ! 3- - test imony. Column 2, which reads: "Concentration in 4' Microcuries per Milliliter." Those are the values that I l

           'S    used to estimate what the dose rates in the vicinity of the                                                                ,

6 evaporator would be. l 7 JUDGE BLOCH: Ms. Skolnik, would you continue? 8 MS. SKOLNIK: I have the table. i t 9 BY MS. SKOLNIK: , i 10 Q Is it incorrect of me to have assumed that when i 11 you spoke of batch cycle operations, that not all of the  ; 12 water would have that Column 2 criteria? 13 A (Tarpinian) You had asked me -- are you asking , i 14 about -- well. I referred to a batch of water that ,

      )

! 15 represents these concentrations in Column 2 The reason 16 that I am doing thet is because I am using the average dose 17 that it would take to process through the evaporator one 18 gallon of water. My testimony is based upon 16.000 person-19 hours of operation fo:. the 2. 3 million gallons of water that , l ! 20 need to be processed throu~'- So it is an average [ 21 number. l 22 JUDGE BLOCH: Mr. Tarpinian, are you familiar with  ; l 23 the possibility that .ie evaporator could be used in batch

                                                                                                                                             )

i 24 mode and not connected to the vaporiner? 25 THE WITNESS: (Tarpir.lan) Yes. () Heritage Reporting Corporation (202) 628-4888 1 l

                                                                                                                                               \

L 500 g-) 1 JUDGE BLOCH: Have ye- drawn any conclusions about (.) ' 2 how much radioactivity would be permissible for workers as , l 3 the influent to the evaporator in batch mode? l l 4 THE WITNESS: (Tarpininn) Yes. We 've given { 5 thought to that. 6 JUDGE BLOCH: You could what?

           ?             THE WITNESS:       (Tarpinian)            Yes.                          We 've given              i 8 thought to that.                                                                                             :

JUDGE BLOCH: What have you concluded? 10 THE WITNESS: (Tarpinian) Well we 've concluded . 11 inat the -- t 12 JUDGE BLOCH: I want ' o know what you 've concluded , i 13 persor.al ly. () I 14 THE WITNESS: (Tarpinian) Oh. I 've concluded ! 15 that the influent criteria specified are acceptable; on the j 16 other extreme. the concentrations that currently are in the [ 3 17 reactor coolant system would be unacceptable. '. l I 18 JUDGE BLOCH: Am I correct in assuming then that ( 19 you don't anticipate the use of the evaporator in batch mcde 20 to meet the influent criterion?  ; 23 THE WITNESS: (Tarpinian) Thtt 's a dif ficult  ! 22 quest ion to answer because I don 't krtow what the influent , 23 concentrations are. 24 ' - 7GE ELOCH : The ones that you are refer-ing to 2S *  ? am referring to as influent conver. ration. () ileritage Reporting Corpor at ion (202) 628-4888

501

,                                                                                            I i           You would not, as I understand.it..want the water to begin
    .O          2           with more radioactivity than that and to use --

3 THE WITNESS: (Tarpinian) Oh. Oh. It is " 4 certainly acceptable for the concentrations specified there 5 to be exceeded to a certain extent. In fact, on the basis  ; 6 of the modeling that I 've done, the concentrations could 7 easily be tripled and still we would have dose' rates in the 8 general' area of less than the .6 millirem per hour that I 9 have assumed. l 10 JUDGE BLOCH: Three times the intluent would be  ! 11 the trost you 'd want to use in batch rroda? f 12 THE WITNESS: (Tarpinian) I'm not going to put an ; 13 upper bound, an upper limit on it, but I am stating that if 14 these concentrations were tripled, then he dose rates where j 15 the operators are working would still be less than .6 l L 16 millirem p2r hour. 17 JUDGE BLOCH: And if they were three orders of j 18 magnitude larger instead of tripled?  ; f 19 THE WITNESS: (Tarpinian) Yes. They would [ 20 certainly be unacceptably high at that point. To a certain l 21 extent, if the radiation levels outside the control room 22 were hir.h enough to warrant it. I would specify shielding so 23 that the dose rates for the operators would remain below .6 24 millirem per hour. T31/B185 O "eriteee aenorti"8 core ret 1o" (202) 628-1888

SO2 1 BY MS. SKOLNIK: g (_s) - 2 Q In arswers to interrogatories on March 30. 1988, a 3 statement was made. Could you please answer for me if this 4 statement is still correct? 5 MR. BAXTER: I 'm sorry. What was the reference at 6 the beginning?  ; 7 MS. SK0LNIK Licensee 's Answers to SVA-TMIA 's 3 8 Second Set of Interrogatorien to GP Nuclear. March 30, 198. , 9 JUDGE BLOCH: Could you read the answer and then , 10 we 'll have the comment? 11 MS. SKOLNIK: Yes. "The volune of waste generated 12 as a result of preprocessing this 40 percent inventory with 13 batch cycle evoporation would be approximately the same 14 volune as that generated f rom continuous cycle evaporation. "

        }                                                                                                                                                                                      l 15                                            MR. BAXTER:                                        Coulc you give us a reference to the 16                          interrogatory number?                                                                                                                                 i 17                                            MS. SKOLNIX:                                          Page 16. Line S.

Since I don't have it. I 'm going to I 18 JUDGE BLOCH: 19 look over Mr. Buchanan 's shoulder. 20 JUDGE PAf<IS : What 's the table number? 21 MS. SKOLNIX: It 's not a table. 22 JUDGE PARIS: Oh, i 23 MS, SKOLNIK It 's a statement beginning on Line . I 1 24 S. 25 (Pause, off the record comments) l I f () Heritage Reporting Corporation (202) 628-4888 i

  ,        ,   . _ _ , . . . . - . - . ~     - . . ,   - - . , . . . ~ . , - - , - , _ _ - , . - _ - _ _ _ , - .

503 W i ' JUDGE BLOCH: The witnesses want to f amiliari::e L) 2 themselves with the answer before they even hear the 3 questior.. So let them read it. 4 MS. SKOLNIX: Yes. 5 (Pause) 1

        !                                    6                       MS. SKOLNIK:     Actually, I hate to confuse you even 7           more. But if you would look at Page 15, the answer starts 8           there. It 's the Answer to Interrogatory Number 18 9                        (PauJe) 10                       MR. BAXTER:     Judge Bloch, would this be a 11           reasonable opportunity for a short break, to give the 12           witnesses tine to read this?

l- 13 JUDGE BLOCH: Yes. Let 's take a ten-minute break. 14 I have 2:47. We 'll be back at 2: 57. That 's 2 : 57. 15 (Whereupon, a brief recess was taken.) 16 JUDGE BLOCH: Ms. Skolink, please continue, j 17 BY MS. SKOLNIK l 10 Q Mr. Tarpinian, is the statement which answers

19 Interrogatory 8 wherein it is stated that the batch cycle 20 operation will be used by the evaporator -- please strike i 21 that from the record.

! 22 Is the statement related to the use of the 23 evaporsdsr for 40 percent of the accident-generated water 24 inventory by batch cycle evaporation still correct? l [ 25 A (Tarpinian) Your question was to the accuracy of j O Heritage Reporting Corporation (202) 628-4888

         ,                                                                                                                                         t 504  ,

i the statement that the volume of waste would not be l 2 different. And the answer is, that 's true. It won 't be , 3 different. l 4 Q If the 40 percent of water is processed through S the evaporator, there will be an increase in waste? r r 6 JUDGE BLOCH: No. what he said was that the volurre ' 7 of waste would not be different in doing it that way. If I 8 understand also, Mr. Tarpinian, your answers now indicate 9 that you never would do it that way. Is that correct? You 10 r.sver would do batch cycling to reduce to the influent  ; 11 criterion. Recycling over and over. t 12 THE WITNESS: (Tarpinian) It 's not -- well, it 's 13 outside, the operation of the evaporator is really outside 14 my scope of testimony.

        }

15 THE WITNESS: CBuchanan) Let me answer the i 16 question. 17 JUDGE BLOCH: Well, let 's have Mr. Tarpinian 18 answer first, because within the scope of your testimony, 19 the question is whether worker exposure would require that i 20 you would ask the company not to undergo operntions by . 21 continuous batch cycle mode. i , 22 THE WITNESS: (Tarpinian) The best way to answer  ! i 23 the question I guess is that if the concentrations were 24 sufficiently high I would ask them not to prccess by using l 25 the evaporator in that mode. Yes.  ! () Heritage Reporting Corporation (202) 628-4888 t I I t-.,__-- ____._ _ , _.._ _ __ _ _ _. -

i 505  !

                                                                                                                \

1 JUDGE BLOCH: Mr. Buchanan, do you want to add to

       )  2 that?
       ^                                                                                                        i 3            THE WITNESS:   (Bttchenan)  Yes.                                   Let me amplify if 4 I could just a little bit. Certainly the decision as to                                         j 5 whether or not to utilize the evaporator in a batch mode for                                        l I

6 a given baten of water, one of the criteria or concerns  : 7 would be the resultant radiation dose. 6 Another criterion which is discussed in the 7 Exhibit 1. the technical evaluation report, is our 10 commitment that any of the bottoms of the solid waste that  ; 11 is produced will be shippable as Class A LSA waste. That  ; i 12 also puts a limitation upon us. In fact, whr':ever I have ) 13 answered the question would you use or could you use the i 14 evaporator in batch mode to process RC5. and I say no, what 15 is driving ; hat answer is what I believe would be the  ; i 16 classification of the bottoms. This is talking cbout the [ 17 waste classification of the bottome that will exceed Class A 18 LSA waste. 1 s 19 In general terms. you know. the classification

                                                                                                               ]!
20 relates to the radiation exposure, the radiation level and

, 21 i.s surrounding thet canister of waste. And RCS. its bottoms 22 is going to be too hot to handle as Class A material. So 23 therefore we would not want to use the evaporator as a j 24 preprocessing component ior RCS water. And I think that 's 25 la agreement with the text that 's pr: ed in answer to the i i l l O Heritage Reporting Corporation (202) 628-48P6 l 1 1

506 1 interrogatory. 2 THE. WITNESS: Tarpinian) I would further add. 3 then that we have, I have evalus _*d what the resulting dase l l 4 rates in the work area would be for the maximum J 5 concentration water that we could put through the evaporator i 6 and give us Class A waste evaporator bottoms, and found that 7 dose rate to be within or less than the .6 millirem per hour I

                                                                                                                                                                                \

8 that I assumed 1.1 the dose rate calculation. So the .6

,                                                                                                                                                                             i j                                                         9               millirem per hour does represent an absolute maximum dose 10                        rate.

11 BY MS. SKOLNIK , 3 12 Q So. am I correct then in assuming that the i 13 criteria of Column 2. Table i on Page 14 is '.he only , i 14 influent criteria that will gn into the evaporator? [} 15 A (Buchanan) When the evaporator is in the coupled  ; l 16 mode with a DF of 1.000 this is your influent criteria. l 17 Q So in other words the evaporator will be used to 10 decontaminate certain portions of the water that are 19 presently stored on the Island?  ! i 20 JUDGE BLOCH: Well, will it be? Will the I 21 evaporator be used to decontaminate certain portions down to 22 the influent criterion? ( 23 THE WITNESS: (Buchanan) I want to answer that 24 with a perhaps. The hardware capability will be there. I ( 25 We 're expecting the sof tware to be in place to be able to do {

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507 1 that. But whenever it comes time to make that decision O

                     \~'

2 you 've got to factor in the other activities that are going 3 on and make an operational decision as to whether or not 4 we 'd want to use the evaporator or whether we 'd want to use 5 the EPICOR system. 6 BY MS. SKOLNIK 7 Q So, Mr. Tarpinian, when you made your occupationt.1 8 dose assessments, did you allow for a certain percentage of 9 the water being decontaminated in the evaporator? 10 A (Tarpinian) Not specifically. no. 11 Q So in other words, the dose to the workers could 12 be higher than the estimate in your testimony? 13 A (Tarpinian) No. 14 Q From evaporation.

15 A (Tarpinian) No. Because I evaluated the case of l 16 the maximum concentration of water that we would or could 17 put through the evaporator and found that thc.se dose rates 18 would be less than that which I based ny estimate on.

19 JUDGE BLOCH: And if I understand your testimony. 20 the maximum amount, the limit, is based on the amount that 21 would produce Class A bottoms? 22 THE WITNESS: (Tarpinian) That 's correct. f 23 JUDGE BLOCH: Did someone refresh your mind obout 24 that during the break? 25 THE WITNESS (Tarpinian) Yes. Someone pointed E Heritage Reporting Corporation (202) 628-4886 L

i* 508 I i out, the reason that I wasn't able to answer the question i O 2 directly before is I was confused and thought that someone

,                      3               was asking me to recite the concentrations that I used 4               specifically.                        I don 't remember what those are.                                                                       But I        -

i 5 remember that it was based upon the maximum concentration we  ! I 6 could put through the evaporator and have resulting Class A j 7 waste bottoms.  : I 8 JUDGE BLOCH: And who provided you with that  ; 9 information? [ 10 THE WITNESS: (Tarpinian) Well, the information 11 that that 's what we intend to do is in the TER. , 12 MR. BAXTER: That 's Exhibit 1. l f 13 JUDGE BLOCH: Excuse me? j That 's Exhibit 1 that he was just {} 14 15 referring to. MR. BAXTER: j 16 JUDGE BLOCH: Exhibit 1 in what? j 17 MR. BAXTER: Licensce 's Exhibit 1.

  • 18 JUDGE BLOCH: Oh, okay. Could you refer to the 19 portion of Licensee *a Exhibit i that contains those data? L l

20 (Pause) 21 JUDGE BLOCH: Can anycne state where that 22 statement is? f 23 THE WITNESS: CBuchanan) On Fage 16 of the  ! ~ 24 technical evaluation report, the bottom paragraph. Would 25 you like for ne to read it. or paraphrase it? (

                                                                                                                                                                                                  ?

i () Heritage Reporting Corporation (202) 628-4888 l i f I 1 i , r i

1 509 f- 1 JUDGE BLOCH: No, because it doesn't answer the 2 question. 3 THE WITNESS: (Buchanan) Okay. 4 JUDGE BLOCH: The question was, what data were 5 used to indicate the levels of radioactivity that would 6 prevail in order to meet the criterion of Class A bottoms. 7 Where were the data about that? Who did the calculations? 8 What numbers were used? 9 THE WITNESS: (Tarpinian) The calculations were j 10 done by my group and they were based upon this criteria os 11 stated, that the waste from the evaporator bottoms will 12 conform to Class A waste. ! 13 JUDGE BLOCH: How did you get from that criterion I j 14 in the levels that you would start with?

             )

! 15 THE WITNESS: (Tarpinian) We had to work i i 16 backwards using certain assumptions about the amounts of 17 radioactive material that would wind up in the resultant 18 bottoms. 19 JUDGE BLOCH: So was the assumption that you 'd 20 multiply by 1,000? 4 21 THE WITNESS: (Tarpinian) I don 't think so. I 22 don't remember. See, the concentration specified for the 23 waste burial requirements are in terms of activity per gram 24 so we made certain assumptions about the translation between 25 microcuries per milliliter concentration in the water and () Heritage Reporting Corporation ( .".0 2 ) 628-4888 i

    -._m___-

SiO i what would become microcuries per gram in the evaporator y 2 bottoms. e 3 JUDGE BLOCH: But in terms of a procedure saying 4 we will not use the evaporator in batch mode if we exceed a 5 certain amount. I take it that the calculations have not yet i 6 been done? } 7 THE WITNESS: (Buchanan) Certeinly we have not i 8 yet developed the procedures which specify those details. ( 9 There have been some calculational efforts on that topic but , i 10 they have not been formalized yet or received any extensive { 11 internal review. 12 JUDGE BLOCH: Was there a plan that specified that i 13 that would be done? l (Buchanan) {} 14 15 do that. THE WITNESS: Well, certainly we will  ! 16 JUDGE BLOCH: Was tiiere a plan that specified that 1Y that would be dorie?  : 18 THE WITNESS: (Buchanan) I 'm sorry. I don't i 19 unde rs tand. l t 20 JUDGE BLOCH: How do we know that you had  : 21 anticipated this problem? What document is there that says i 1 22 you were going to do this calculation? f i 23 THE WITNESS: (Buchanan) The technical evaluation  ; i 24 report says that we will neet these two criteria. Then  : I I l 25 there have to be procedures in place to reflect the  ! f r () Heritage Repoeting Corporation (202) 628-4888 [ t , i h

511 i requirements of this TER. O 2 JUDGE BLOCH: OXay. So the only problem that 3 we 've got is that there is a set of numbers that was 4 generated and we can't see those because they are not 5 available right now? 6 THE WITNESS: (buchanan) I do not have them, 7 that 's correct. 8 BY MS. SKOLNIK: 9 Q Mr. Buchanan. do you understand the f rustration 10 that the public might have with this in that -- 11 JUDGE BLOCH: That 's irrelevant. 12 MS. SKOLNIK Is it ir.= levant? 13 JUDGE BLOCH: Yes. You are going to try a case 14 here. And the public 's response is irrelevant. We 're going 15 to decide the case on the merits. This isn't for history. 16 MS. SK0LNIK: I know it 's not for history. But 17 okay, off the record, it seems to me I 'm evaluating a 18 proposal without having the procedures in front of me or the 19 numbers and it 's really, it 's such a burden. 20 MR. BAXTER: There was a discovery process. Ms. 21 Skolnik. We answered every question you had during 22 discovery. I know it could go on forever, but that 's not 23 the process. 24 MS. SKOLNIK: And the discovery process -- 25 JUDGE BLOCH: Okay. Let 's stop for a second. The Report ing O Heritage (202) 628-4888 Corporation

512 i 1 debate is really not relevant. I understand you are 2 frustrated. That 's part of being in a case like this. - 3 There are problems that arise. This may be something that 4 is important for your case and it may not. What you have to 5 do is to go ahead and try the case on the merits. That's ell f 6 we 're here for. The frustrations are just sometning you  : 7 have to suffer.  ; i 8 (continued on the next page)  ! 9 i 10 i i 11 i 12 t 13 i O 15 l t i 16  ! t 17 f 18  ; 19 i i l 20 l l 21 22 23 24 25 O Heritage Reporting Corporation (202) 628-4883 h_.m

6, 613  ! I i BY MS. SKOLNIK: l O~ 2 Q At this point in time. Mr. Tarpinian, is it not 3 possible for you to tell me what the maximum dose is to.the j 4 workers from the evaporator? I l 5 A (Tarpinian) Maximum collective dose for our  ! 6 proposal is as stated in my testimony. It is 23 person-rem. i 7 JUDGE BLOCH: May I ask, were there any } 8 assumptions in that as to the method of processing as to 5 9 what percentage of it might be done in the SPICOR system and 10 what percentage in the evaporator? i i 11 THE WITNESS: (Tarpinian) I didn 't make any [ i 12 specific assumptions on the mode of preprocessing. , 13 JUDGE BLOCH: Does it matter?  ;

14 THE WITNESS
(Tarpinian) It does not matter.

15 JUDGE BLOCH: Why doesn't it matter? , 4 i 16 THE WITNESS: (Tarp 1141an) It doesn't matter l 3 17 because the conditions stated are a bounding upper limit for ) l ! 18 the dose rates for the operetw s in the control room. } l 19 JUDGE BLOCH: I don't quite understand. Does that l l 20 mean that 's the most you 'd parmit?  : I 21 THE WITNESS: (Tarpinian) That 's the most I would f l 22 permit. l 23 JUDGE BLOCH: But how do you know that the actual j , i 24 processing will stay within that? ) i l 25 THE WITNESS: (Tarpinian) As I previously stated. l t i ! [ O "erite8e aevorti"c corvore'io" I (202) 628-4888 [ [ I t

I i 514 1 we evaluated several different possibilities for influent f O 2 concentrations and the most reasonable maximum was for the 3 case where we had water that was the maximum concentration 4 that we could put through the evaporator and have Class A ( 5 bottoms and I found those dose rates to be less than that 6 which I assumed for the maximum dose to en individual. l 7 JUDGE BLOCH: I didn't think the answer you just  ! i 8 gave had to do with the 23 person-rem, did it? l 9 THE WITNESS: (Tarpinian) I believe it does. The f 10 maximum dose rate for the operatoru is .6 millirem per hour, j i 11 That 's not based on the concentration of the water. It 's I 12 based upon the maximum dose rate that I would allow. I $ i ! 13 started with that. Then I compared that with concentrations j f 14 that we expect to run through the evaporator. The resulting [ 15 dose rates in the work area were less than .6 millirea per l \ l 16 hour using those models. So I felt content that the .6 j i 17 millirem per hour represented an upper bound. l' l 18 JUDGE BLOCH: And the total nunber of hours was >

                                                                                                                                                    )

l 19 derived how?  : l 20 THE WITNESS: (Tarpinian) The total number of 7 i ! 21 hours was given to me by Dave Buchanan 's group. We i 22 generally rely upon other organizations to give us data like l i I 23 that so that we can do our estimate. l , 24 JUDGE BLOCH: So. Mr. Buchanan, how did you get I I

25 the total number of hours? j I  ?

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515

            -                            1               THE WITNESS:                          (Buchanan)                                                We assumed that there 2   would be two people per shift exposed to the radiation field 3   16 hours a day for two years.

4 JUDGE BLOCH: How did you kr.ow you could finish in 5 two yests? 6 THE WITNESS: (Buchanan) Our estimate is that we 7 will be able to finish it in two years. 8 JULGE BLOCH: Based on what? How did you 9 calculate the rate? 10 THE WITNESS: (Buchanan) We 've done a e m ple 11 different estimates on time spent. We did one where we 12 looked, we assumed 75 percent availability. 75 percent of 24 4 l 13 hours availability per day times five days per week times 14 2.3 million gallons and that gave us a certain calendar time IS span which I believe is on the order of a year and a half, j 16 And later on top of that, you know, some assumptions, it 's 17 possible, depending upon the rate of defueling or [. 16 decontamination, there is the issue, will water always be 19 available? So there is potentially, we cuuld have some 20 slowdown or stretchout of the activities due to the pace of 21 the availability of water. And some allowances for 22 maintenance activities where we might have to do some 23 equipment disassembly for extensive repair. JUDGE BLOCH: 24 So it's a conservative rate. 25 THE WITNESS: (Buchanan) So it 's a conservative. () Heritage Reporting (202) 628-4888 Corporation l

I ,

 . ls 516                  ;

l~ 1 which I think is an upper bound of the length of time. (q/  ! 2 JUDGE BLOCH: But it is actually based on a

3. calculation of the processing capacity of the evaporator? l 4 THE WITNESS: (Buchanan) That enters into it. f 5 certainly.

6 JUDGE BLOCH: Well, that helps. Because most of f i 7 the other stuff seemed ;o come from the result you needed.  ! t 8 Ms. Skolnik? . L 9 BY MS. SKOLNIKr 10 Q As far as the time period, does that include the 11 time it would take to put some of the batches through a  ; t 12 second or third time? 13 A (Buchanan) In developing the estimate, as you , {} 14 15 heard me explain it, it 's obviously rather simplistic and rather crude and I'm looking for an upper bound. How much i l 16 time did I allow for reprocessing? None. Is there time ( t 17 available in there to do some reprocessing and still get j 16 done in two years? Yes. I believe so. ( 19 Q # hat period of time would you believe is j i 20 available?  ! 21 A (Buchanan) I do not know. I did not do the l 22 estimate that way. The numbers are rough estimates. I 'm 23 assuming 75 percent availability. I 'm assuming no weekend l 24 work. Maybe those nunbers are right, maybe they 're wrong. I 25 So we 'll make adjustments to get the job done in a timely  ! l () Heritage Reporting Corporation (202) 628-4888 l r I 1 I h a

f i 517 i i mariner once we get started. This proj ect is no different 2 than any other proj ect. 3 Q So the truth of the matter is, isn 't it, that two 4 years might be the upward bound in your estimations but you  ; 5 may not have figured certain things in so it could be a 6 longer period than two yeare? 7 A (Buchanen) My estimate is two years. "Estimate" I 8 is the key word. 9 JUDGE BLOCH: As I heard your communication. Ms. t 10 Skolnik made a fair interpretation. You said it 's an 11 estimate, there 's operational continget.cies, it 's  ! 12 conservative, but it could take longer. Is that right? 13 THE WITNESS: CBuchanan) That 's correct. j i 14 BY MS. SKOLNIK: i O 15 u So if it takes longer, the occupational dose would [ 16 be increased? j 17 A C"'rpinian) Yes. It could increase. 18 Q . Thank you. Could the cost increase?

19 A (Buchanan) There would be some additional cost. [

{ 20 yes.  ; t 21 JUDGE BLOCH: Mr. Tarpinian, if it takes longer. l i 22 and you process the same amount of radioactive materials, 23 why would the dose increase?  ; t , 24 THE WITNESS: (Tarpinian) It could take longer [ t 25 for a number of reasona. Some of those would be maintenance  ! () Heritage Reporting (202) 628-4883 Corporation  ! p

   , , -  - - - - , _   .- , .-.-,.,_,n,                   ..-,n_-,...       ~ , - , . . .                   ._.

t i 518 , 1 items. I 'm assuming. The calculation is based on 16.000 l ( 2 person-hours aad some maximum dose rate that I assumed and I 3 some additional work for packaging the evaporator bottoms. j 4 .I wouldn 't expect that nutaber to change much because the [ 5 volume of waste as stated before would remain the same. i

 ,                                                                                                                                                                                                                                  l 6                                                                     JUDGE BLOCH:              Okay.          So your belief that the dose 7     would go up is based on a belief that the number of actual                                                                                                                                     f 8     hours working in the area of the evaporator would 2o up; is                                                                                                                                    l 9     that correct?

10 THE WITNEJS: (Tarpinian) That is correct. i 11 JUDGE BLOCH: Because some futures in which you l 12 take more than two years, the number of hours in which the 13 inachine is working would not be increased. But you 're j 14 saying the dose could go up if the number of hours in

                          }

15 operation and maintenance were to go up? l 16 THE WITNESS: (Tarpinian) Right. i

.                                                                                                                                                                                                                                   i J                              17                                                                     JUDGE BLOCH:              Am I correct. Mr. Buchanan, in some                                                                  l
 ,                            18      instances you could take more than two years but the number
  ,                                                                                                                                                                                                                                 i 19     of hours of maintenance and operation would not go up?                                                                                                                                         (

f

;                             20                                                                     THE WITNESS:              (Buchanen)                       I think that 's true.                                               ;

21 You can structure your estimate in several different ways. l 22 I don 't disagree with what you 're said. 23 BY M5 SKOLNIK: 24 Q Mr. Tarpinian, you have estimsted your workers to 25 have 16.000 person-rems. Okay? l i () Heritage Reporting Corporation (202) 628-4888 l o, e q e -,e- m- nm-,-,w., +,--m--- - ,--p -..w~,.w-. .me-wwy er ,- w a- ~

l 1

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519 1 A (Tarpinian) 16,000 person-hours. 2 Q Person-hours. Okay. Person-hours. That's two 3 workers working every day. So every day is 48 hours, j 4 person-hours. Is that right? l 5 A (Tarpinian) Person-hours -- ' 6 MR. BAXTER: Mr. Buchanan just Eave that testimony. l t 7 as 16 hours a day. Two people. No weekends. Two years. 8 MS. SKOLNIK: Okay. I want to clarify it. 7 t 9 BY MS. SKOLNIK ( 10 Q Are there two people working at the evaporator on l 11 each shift? [ 12 A (Buchanan) That 's the assumption that we have l 13 made. l 14 Q Two people. How long will the evaporator run each 15 day? , 16 A (Buchanan) I assumed 16 hours per day. 17 Q So that 's 32 person-hours per day? l l 18 A (Buchanan) Whatever it works out to be. t i 19 Q Well, it 's important. because what we 're doing l 20 here is evaluating your proposal against the no-action j f 21 alternative. So obviously, the occupational -- , 22 JUDGE BLOCH: I will take notice that your ( 23 calculation is correct.  ! 24 MS. SKOLNIK Thank you. So I don't need to keep l 2S working for two years? () Heritage Reporting Corporation (202) 628-4888  !

520

1. JUDGE PARIS: Your question was are there two l

( . 2 people working at the evaporator each day? He said yes. , 3 You said it's 16 hours. Does that mean that two people are ) 4 working 16 hours or one person is working eight hours and 5 the second person is working the other eight hours? l r 6 THE WITNESS: (Buchanan) It 's two people. on each l 7 of two eight-hour shifts. 8 JUDGE PARIS: Oh. Okay. . 9 JUDGE BLOCH: So I assume that you know it 's 32 [ 10 person-hours. Is that correct?  ! 11 THE WITNESS: (Buchanan) Sounds good. 12 JUDGE BLOCH: Of course. Mr. Buchanan also assumes , 13 7S percent availability and on some of those shifts that {} 1A wouldn 't be there.

15 BY MS. SKOLNIK

! 16 Q Yes. But when the evaporator is not working for 17 the other 25 percent. isn 't it true that it 's being j 18 maintained by another worker or the same work tr? 19 A (Buchanan) We have not gotten into ' hose types of  ! 20 details with our contractor in terms of exactly how he 1 21 atends to run it. And we have a vendor coming on site to 22 operate the machine. It is his resoonsibility to operate 23 this machine in the manner he sees fit, with his staffing. I ( 24 If he wants to operate 24 hours a day, if he wants to l 26 operate seven days a week, that really is his option. We [ () Heritage Reporting Corporat ion (202) 628-4888 [ t f r i

521 i have developed these numbers for our estimation of time and 2 cost and radiation exposure, et cetera. It doesn't say that j 3 the vendor -- he may elect to do it a little different way. 4 His option. 5 Q But isn't it true that his option of working the 6 evaporator is limited by the capabilities of the evaporator 7 itself? It 's not just his choice if he wants to run it 24 8 hours. Isn't the 75 percent the maximum efficiency rate of 9 an evaporator? 10 A (Buchanan) No. It 's our assumption of required 11 down time. 12 Q Isn 't it also the NRC 's assumpt$cn? 13 A (Buchanan) I do not know. 14 Q Mr. Tarp 1nian, what influent criteria is necessary 15 for Class A waste?

;                                                            16       A    (Tarpinian)            The specific concentrations?

17 Q Is it above or below or is it the same as Table 1. 18 Column 2? 19 A (Tarpinian) The concentrations are as I remember 20 above the values stated in Column 2, 21 Q Above? By how much? 22 A (Tarpinion) I really don't recall. 23 Q Is it true, does it say that you are reserving the i 24 right to choose to decide whether or not to decontaminate 25 the water in the evaporator other than the EPICOR DWCS i i I () Heritage Reporting Corporation (202) 628-4888 I l

i 522 1 syntem? 2 A (Buchanan) That 's correct. as long as we can meet 3 our criteria that are set forth in the TER, then it becomes 4 an operational choice. 5 Q At what point will you have decided that you are 6 able to meet your criteria? 7 A (Buchanan) When we 're ready to do a batch of 8 water,- It could be the day before, the week before. 9 Q In other words, it could be af ter the amendment is 10 granted? 11 A (Buchanan) Naturally. Absolutely. It becomes an 12 operational decision. As long as we meet the technical 13 requirements, that primarily being the effluent criteria, {} 14 15 then, you know. structure our procedures around these requirements and those become operational guides. 16 JUDGE BLOCH: The testimony is that the procedures 17 have not yet been developed.

l. 18 (Pause)

, 19 BY MS. SK0LNIKi 4-n 20 Q Mr. Tarpinien, in Page 4 of ycur testimony you 21 estimate that the occupational dose for the no-action 22 alternative is approximately 15 person-rems? l 23 MR. BAXTER: Are you speaking of the Joint 24 Intervenors ' Alternative addressed in Answer 67 r 25 MS. SKOLNIK: The no-action alternative, I guess l i Heritage Reporting Corporation f (f

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523 1 I 'm referring to the no-action al ternative. O- 2 MR. BAX1ER: There 's no reference in the testimony 3 to the no-action alternative. . There 's testimony on the 4 Joint Intervenors ' alternative. 5 MS. SKOLNIK Okay. I'll take possession of the 6 no-action alternative. The Joint Intervenors ' no-action 7 alternative. And you 're saying it 's 15 person-rems. 8 BY MS. SKOLNIK: 9 Q If the water was all processed to the achievable 10 case which is documented in PEIS Table 2. 2, wouldn 't the .I 11 occupational dose from storage on the Island be even less l 12 than 15 person-rems? < 13 JUDGE bLOCH: Let 's break that out. Can you tell 14 us roughly what the occupational dose would be from

15 preprocesring it in that manner? You want to preprocess it j 16 to what lesvel now?

17 MS. SKOLNIK: To the, what is termed by the NRC as 18 the achievable case. If the water was put through EPICOR 19 SDS. if 100 percent of it was put through EPICOR SDS it 20 would arrive at what is called the achievable case. , 21 JUDGE BLOCH: Okay. I thought your witness -- you 22 can correct me -- I thought your witness wac asking actually 23 that it be put through the evaporator until you achieve the 24 levels just prior to vapori=ing. 25 MS, SKOLNIK I 'm not sure because I don 't -- i

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524 1 JUDGE BLOCH: Mr. Piccioni wanted -- l 2 MS. SKOLNIK: I don't believe he intended for the [ 4 3 evaporator to be on the Island. '

4. JUDGE BLOCH: Okay. I think he did. But you can 5 go ahead and get the testimony the way you 'd like it. You 'd l F like to know the amount of -- first of all. vhat 's the amount of radiation -- did you anticipate on amount of  !

8 preprocessing before the stuff would be stored on the f

                       +

9 Intervenor 's alternative? , j 10 THE WITNESS: (Tarpinian) Yes. I assumed 31 11 percent of the water would be processed. 12 BY MS. SKOLNIK: 13 Q The achievable case that 's dccumented in Table 2.2 14 of E(S is 100 percent. That would mean thut all of the

                                      )

15 water would be put through again. The base case is only the i l 16 40 percent. So if all the water was pu'. through again. [ ] i

17 wouldn 't it reduce the occupat te ;al dose from storage?

18 A (Tarpinian) I assumed te occupational dose , it associated with the storage of the water. In the case b 20 evaluated here I only assume dose associated with the i  ! 2 21 p ocessing of the water prior to storage and some i 1 l 22 assumptions that I made concerning the dose associated with l

 .                                                                                                                                                                                                                1 23     the eventual disposal of the water.                                       I made       'n. I assumed
!                                                                                                                                                                                                                 t 24     that th"re was no dose associated with the storage of the                                              ;

l 25 water for that period. i l () Heritage Reporting Corporation (202) 628-4888 I

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l 525 j 1 Q But in order for the water to be disposed, no j

        'O ,

t 2 matter what manner, it has to achieve a certain level. So l 1 3 if alloof the water, whether it 's going into the evapora6or 4 or Coing to be stored on the island, is processed in that 1

   !           O manner, then the worker dose of 15 person-rem would cancel 6 out. Isn 't that true?

7 A (Torpinian) I 'm not sure I follow your logic. I 8 don 't understand -- 9 JUDGE BLOCH: Let 's break it up. First, if I 10 understood, what is the percentage you assumed would be 11 preprocessed? 12 THE WITNESS: (Terpinian) 31 percent of the total 13 inventory. 14 JUDGE BLOCH: If you assume that 100 percent would 15 be preprocessed, do you have any notion of how that would 16 affect the dose? l 17 (HE WITNESS: (Tarpinian) The dose for proceesing 18 100 percent would be increased. 19 JUDGE BLOCH: Do you know by what amount ? l 20 THE WITNESS: (Tarpinian) I don 't know of fhand.

 ;           21  It would be increased by some amount.       One could postulate 22  it could almost triple.

23 JUDGE BLOCH: Ycur rough guess would be it might 24 triple? 25 THE WITNESS: (Tarpinian) Might triple. ' O "eritese aenortt"e cornoratt a (202) 628-4888 i i

526 l 1 JUDGE BLOCH: And then would there also be some O 2 reduction at the end of 30 years in the -- is that what you 3 assumed? When did you assume that the waste would be 4 dumped? r 5 THE WITNESS: (Tarpinian) After 30 years I 1 6 assumed that we have to process it in some manner. 1 7 JUDGE BLOCH: And would the dose at that time it 8 your estimate be reduced because you 've preprocessed 100 9 percent of the water previously? i 10 THE WITNESS: (Tarpinian) Most liXely there would i 11 be a certain reduction, yes. 12 JUDGE BLOCH: Can you put a rough bound on that? i 13 THE WITNESS: (Tarpinian) I cannot because I i 14 haven 't evaluated what the. specifically the effect of the { 15 reduced concentration would be on the dose rates that the i 16 workers would be working at at that time. ) . 17 (Continued on the next page) 8 18 20  ! f 21 t i

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t 23 , i 24 I 25 t 1 I () Heritage Reporting Corpo rat ion (202) 628-4888 [ i

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527 1 JUDGE BLOCH r Did you allow for the decay during i; O 2 the period of time before you estimated the worker exposure 3 and the subsequent disposal? 4 THE WITNESS: (Tarpinian) Yes. I assumed that the: 5 ' principal radionuclides that would contribute to the gamma 6 radiation dose would be reduced by one half for a storage of $ 7 30 years. 8 BY MS. SKOLNIX: 9 Q It 's true that the water has to be processed in

10 order for it to be disposed. Is the level at which it would 11 be stored the same as the level that would go into the 12 evaporator?

l 13 MR. BAXTER: I 'm sorry. Mr. Chairman, the i 14 Intervenor is asking us to define their alternative. I

    ~)

i 15 think he's stated three times now what he has assumed in 16 terms of the level of preprocessing for storage. 17 JUDGE BLOCH: I think. Ms. Skolnik. you didn't .I 18 mean quite the question you asked. ) 19 MS. SKGLNIK Pardon? 3 20 JUDGE BLOCH: You want him to assume that it is 21 that level? 22 MS. SKOLNIK: Yes. 23 JUDGE BLOCH: You want to ask about some 24 consequence of that. l 25 M3. SKOLNIX: Okay. i

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528 7 1 JUDGE BLOCH: That was what I attempted to do and 2 he said in order to preprocess to that level, the worker 3 exposure at that time would be about three times of what he 4 had estimated for that phase, roughly three times. 5 And then there would be some reduction at the end 6 of the storace period as a consequence of having reduced the 7 value earlier. 8 He also stated that he 's e Saumed no exposure 9 during the storage period. So that can't be reduced. 10 BY MS. SKOLNIK: 11 Q Mr. Tarpinian, when you worked out the exposure to 12 evaporation process, you said there was 16,000 person-rems ! 13 per-evaporation process and 3,500 person-hours oh, person- {} 14 15 hours for packaging the bottom. Are the persons who are evaporating the water not l 16 exposed to the -- 17 JUDGE BLOCH: Stop. You 've got to ask the l 18 question clearly 'ie said lever said 16.000 person-rene so 19 let 's just stop and make it and get in your mind first and 20 then say it. 21 BY MS. SKOLNIX: 22 Q Is the person who is working at the evaporator , 23 bottom the same person who is working at the evaporation 24 process? 25 A (Tarpinian) He might be. He doesn 't have to be () Heritage Report ing Corporation (202) 628-4888 l 1

529 - g 'i but he might be. It would still be the same crew of people 1 U 2 doing both jobs. I 3 Q So a worker could be exposed not only to the 4 radiation field of the evaporator, they would also be 5 exposed to the radiation field of the bottom? 6 A (Tarpinian) Yes. 7 Q So would that increase your estimation of the 8 worker dose?  ! 9 A (Tarpinian) No because the total dose is l 10 calculated irrespective of the individual that does the 11 work. ' f 12 It 's the total number of labor hours times the  ! 13 dose rate in the areas those people would be working.  ! 14 Q In answers to interrogatories GPU -- I 'll have to 15 pass that. I can't find the reference.  ; a  ! 16 Mr. Tarpinian or Mr. Buchanan, if you -- you may l 17 have answered this before but I would like you to answer it  ; 18 again, please. i 19 How much waste will be created -- will there be  : 20 additicr.nl waste created if the water goes through more than l 21 one time? 22 A (Buchanan) No. 23 Q Could you explain? Why not? l 24 A (Buchanan) Well, there 's only so much dissolved  ; l 25 solids in the sIter. And whether vou remove those solids in h i I !(]) Heritage Reporting Corporation (202) 628-4888 L l e i i i 4

( t

 )                                                                                          530 one-pass or two passes, it really doesn't make any
   ,/ }                    i 2 difference.

3 The total amount of solids predefines it so to 4 speak. 1 5 Q Will the variation in the boron ef fect the amount l l 6 of waste that you have at the end? l 7 A (Buchanan) Yes, it does. 8 Q Could you explain how if the boron concentration l l 9 is at 6,000 parts per million, how would that be in relation  ! 10 to the boron concentration of 3,000 parts per million? } l 11 A (Buchanan) Well, you divide your concentrations l

                                                                                                 ?

4 12 by your DF. You know if you start with the 6.000 parts per ( 13 million of boron, divide that by a DF of a 1,000, you get 14 a (]) six. f 15 There was 3,000 to start with, I 'll have three. i 16 So it 's j ust a matter of your doing the arithmetic. 17 Q But isn 't the boron falling into the waste, the ! 18 bottom?  ! ! I 19 A (Buchanan) You certainly want it to be. But your : t 20 question also, is there some carryover? Yes, there 's i t i 21 carryover in the boron just as there is with any of the 1 22 particulate material. 23 Q If the influent contains 6.000 parts per million r I 24 of boron. what will that waste contain? [ 25 MR. BAXTER: Obj ect ion, Mr. Chairman. I don 't l l () Heritage Report i ng Corporation (202) 628-4888

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4 531 believe there ara any material issues of. fact dealing with {}- i 2 the disposal of boron. 3 I'm totally lost as to how this relates to any of ., 4- the material issues that are -- i 1 5 JUDGE BLOCH: How does this relate, Ms. Skolnik? l 6 MS. SKOLNIX: If the boron effects the amount of i 7 waste created, it would also affect the number of trucks 8 that it would take to transport the waste offsite. 9 And therefore. it would affect the number of

10 accidents that were estimated and also tne dose to the 11 driver who would be driving the truck.

12 And of course it would af fect the cost of 13 transporting the waste. () 14 JUDGE BLOCH: So which of the issues that were 15 left for this hearing in order is this related to? 16 MS. SKOLNIK: It 's related to the occupational 17 dose assessment in the testimony of the Licensee. 18 MR. BAXTER: Mr. Weaver does describe -- well, he 19 does an accident risk analysis for the trucked shipments. 20 I 'm not sure if that 's what it relates to. 21 JUDGE BLOCH: Let 's continue on the basis that it 22 could expand the total amount of shipments. 23 MS. SKOLNIK: Pardon? 24 JUDGE BLOCH: It 's relevant possibly to the tosal 25 amount of shipments.

       )                   Heritage   Reporting Corporation (202) 628-4888

i 532 1 MS. . SKOLNIK Yes. k_T

     /                                                                                                                                           l 2            JUDGE BLOCH:                             So we 'll continue for a little while 3  lortger and see where we get.                                                                                                        :

4 MS. SKOLNIK: f)Roy. It would also be relevant to  ! S the worker dose. 3 6 JUDGE BLOCH: Well, let 's ask the witisess a few  ! 7 things. 8 MS. SKOLNIX: Okay. + 9 BY MS. SKOLNIX: 10 Q Poes the concentration of boron in the influent  ! 11 affect the quantity of bottom that will be produced by the  ! 1 I 12 evaporator?

t 13 A (Buchanan) Yes. i

() 14 Q By what? If the boron is 6.000 parts per million? 3 15 'A (Buchanan) 99.9 percent of the starting amount of i 16 the boron will be in the bottom. 17 JUDGE BLOCH: Mr. Buchanan, how did you estimate )  ! 18 the amount of boron that would be in the bottoms? 19 THE WITNESS: (Buchanan) Well, assuming whatever j 20 your concentration is and applying your DF of a 1.000 which f 6 21' is the same as saying 99.9 percent.  ! I 22 JUDGE BLOCH: So how did you assume the 3 23 concentration? Where did you assume that? i 24 THE WITNESS: (Buchanan) Oh. the 6.000. I believe  ! 25 the 6.000 is taken out of one of our documents. 6. 000 cones 1  ! ( Heritage Reporting Corporation j (202) 628-4888 j

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[

l 533  ; {} i 2 from the maximum allowable concentration of boron of the reactor coolant system. That'- where I assume you got the 3 number. 4 BY MS. SKOLNIX: 5 Q Is 6.000 the maximum or is it the maximum? 6 A (Buchanan) The maximum allowablo for the text 7 specs for the reactor coolant system and the systems which 8 feed the reactor coolant system. 9 JUDGE BLOCH: Io you assume that the amount would 10 be the .naximum allowed? 11 THE WITNESS: (Buchanan) Ho. I did not. 12 JUDGE BLOCH: What did you assume? 13 THE WITNESS: (Buchanan) We assumed 3.500 was the () 14 basis for our calculations. 15 JUDGE BLOCH: What 's the basis for the 3. 500? 16 Where does that come from? I 17 THE WITNESS: (Buchanan) It 's based upon 18 sampling. It *s based upon our sampling and then doing the 19 arithmetic averaging. 2 20 JUDGE BLOCH: Okay. 21 BY WS. SKOLNIK:

'i 22      Q     But doesn 't the reactor vessel contain boron with 23 averages, with 6.000 parts per million boron?

24 A (Buchanan) It 's not quite 6. 000 1 25 Q Doesn 't your table on specifications state that it 1 () Heritage Reporting Corporat ion (202) 628-4888 i b r

534 i has to be between 4.360 and 6.000? {~ } . 2 A (Buchanan) Yes. 3 Q So the average of 3. 000 doesn 't reflect the 4 percentage that would be -- that would be 40 percent of the 5 water? 6 A (Buchanan) It does reflect. We entered that all 7 into our calculation whenever we ca:culated our average of 8 3.500. 9 Q But the average does not go into the evaporator. 10 It 's dif f erent tanks. And if the tank has 6.000 parts of 11 boron. that is what the evaporator has to deal with, is that 12 correct? i 13 A (Buchanan) On that batch, yes. 14 MR. BAXTER: We 're tal. ting about waste management (]) 15 volune, waste volume production as I understand it. 16 JUDGE BLOCH: The earlier answer you got was that 17 the total ancunt of waste in the water before you start 18 processing it, is hoing to be the enount of waste that 's in 19 the bottoms when you 're done with the one, one-thousandth 20 being missed. 21 But basically it 's 999 parts out of a 1.000 of the 22 waste you start with is going to wind up in the bottoms. 23 And it docar.'t matter whether some of the batches 24 have more and some of them have less. You 'r- still going 25 to wind up with 999 over a 1.000 parts of the original solid l () Heritage Reporting Corporation (202' 628-4888 1 -\' 1

l 535 !

,               1 weste in the bottoms.

2 It doesn't go up because some batches have trore  ; 3 and others have less.  ; 4 BY MS. SKOLNIX: 5 Q But if it 's 99 percent, is 99 percent of three i 6 parts per million more or less than 99 percent of 6,000  ! f 7 parts per million?  ; I 8 JUDGE BLOCH: You know the answer to that and so 9 de I. What's the relevance of it? l 10 BY MS. SKOLNIX: 11 Q Is waste classified by the amount of boron?  ! 12 A (Buchanan) No. The classification, whenever I l 13 was referrinE to LSA waste, whet have you, that has to do , l O 24 ith the =o" eatretioa or redio""citoee- - 15 You know, boron is not a radioactive species. l = 16 Q But will the boron affect the dryer, the blender-  ! t 17 dryer, the capability? l 18 MR. BAXTER: Obj ect ion. The blender-dryer [ 1 i

19 capabilities are not at issue here.  ;

20 MS. SKOLNIr.: But the amount of waste that is

21 created by the process is an issue.

!! 22 JUDGE BLOCH: Will it affect the what dryer? l 23 MR. BAXTER: It 's a component in the disposal l 24 system that packages and produces the waste form. I 25 JUDGE BLOCH: What 's the relevance of that Heritage Reporting Corporation

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536 question? .{} 1 2 MS. SKOLNIK The relevance is, d'es the boron 3 affect the efficiency of the blender-dryer? 4 JUDGE BLOCH: Your belief is that if they have the j 5' amount of boron that they have that they haven't properly 6 accounted for the' efficiency of this. system? 7 MS , SKOLNIK: Partly that but also -- I want to l l 0 know if the concentration of the boron affects the amount of [ 9 pellets that will be produced.  ! 10 JUDGE BLOCH: L e you done anything to change  : 11 their assumptions on what the concentration of boron will be j 12 overall? ( r 13 I do n ' t see anything you 've done that changes j (J 14 their assumptions about the amount of boron, average amounts 15 of boron. 16 They seem to have done that correctly. { 17 MS. SKOLNIK There 's a -- that the average amount l 18 of boron is 3.000 parts per million. l i 19 THE WITNESS: (Buchanan) 3.500. , l 20 MS. SKOLNIK: But there are certain amounts of l 21 water that will have 6,000 parts per million? ( 22 THE WITNESS: (Buchanan) Yes. 23 JUDGE BLOCH: That 's consistent with an average l 24 amount being 3.500 They agreed to that. Yes, there are 25 certain parts that will be more. l 4 () Heritage Reporting Corporation (202) 628-4888 i

l'j l 537 l r~s i MS. SKOLNIX: And I 'm saying when it 's more -- U 2 JUDGE BLOCH: Well. no. when it 's more it will l l l 3 affect -- l 4 MS. SKOLNIK: If it is nore, will it affect the l l 5 amount of waste that is created? l Will it affect the efficirney of 6 JUDGE BLOCH: l 7 your system to have more in some of the batches? 8 THE WITNESS: (Buchanan) It doesn 't make any 9 di f f erence. You know, the ef ficiency of the evaporator has l 10 a DF of a 1. 000 regardless of what 's, particularly within 11 the ranges that we 're talking about, it does not -- whether 12 I've got 3.500 or 6.000 or 1,000 I'm still going to have a 13 DF of a 1.000. () 14 Out of that gallon of water I will have, do the 15 arithmetic and determine how much bottom will be generated. 16 The higher concentrated volune, you know, will add 17 solid material faster, certainly. 18 JUDGE BLOCH: Please continue. 19 BY MS. SKOLNIK 20 Q I would like to turn to the diagram in the 21 technical evaluation report. I 'd like to turn to it but 1 22 don 't have it. 23 JUDGE PARIS: Where in the diagram. Ms. Skolnik? 24 MS. SKOLNIK: Pardon? 25 JUDGE PARIS: Where is the diagram? () Heritage Reporting Corporation (202) 628-4888 l

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538  ; j 1 MS. SKOLNIK: In the technical evaluation report. l 2- JUDGE PARIS: Yes, where? 3 MS. SKOLNIK: I'n: looking for it. 4 JUDGE PARIS: Oh, okay. I 5 MS. SKOLNIK: I 've removed it f rom my technical 6 evaluation report. { i 7 JUDGE BLOCH: The system diagram? 8 MS. SKOLNIK: Yes. 9 JUDGE BLOCH: It was placed near the back of the r l 10 report entitled. TMI Unit 2 Evaporator Plant System. Which ; t 11 diagram? l 12 MS. SKOLNIK: It 's figure one.  ! i 13 JUDGE BLOCH: Figure one. 14 MS. SKOLNIK: Page 36. 15 JUDGE BLOCH: Okay. Processed water disposal  ; 16 system? j t l 17 MS. SKOLNIK: Yes. l 18 BY MS. SKOLNIK: t i 19 Q Is it true. Mr. Buchanan, that the VC-300 i l 20 concentrate tank is 75 gallons? Is that correct? i 21 JUDGE PARIS: Is it true, what? l l 22 MS. SKOLNIK: That the VC-300 concentrate tank is l 23 75 gallons? f l  ! i 24 THE WITNESS: (Buchanan) That 's correct. t f 25 e E Heritage Reporting Corporation (202) 628-4888 t C i [ f

1 r 539 , t BY MS. SKOLNIK

                 }  1 l

2 Q Is it true that the seed is coming from the PWST-3 27 4 A (Buchanan) That 's one of the f eed tanks. yes. 5 Q Wi?i there be another tank attached to the 6 evaporator? 7 A (Buchanan) We can also feed from a tank we call 8 CCT-1 also. 9 Q Do you have any other capabilities of feeding into 10 the evaporator? 11 A (Buchanan) Not at the present time. 12 Q How will you nove the water f rom the other 23 4 13 locations to either the PWST-2 or the CCT-17 () 14 A (Buchanan) Through our plant piping systems.

,                  15                  Q           Is that piping system already in place?

16 A (Buchanan) Yes. 17 Q Will there be any additional cost to bring in

18 those pipes into the PWST-27 Will anymore costs have to be 19 incurred?

. 20 A (Buchanan) To get the -- 21 MR. BAXTER: Obj ect io n. Costs beyond what. 22 current estimate? Or. costs above =ero? 23 MS. SKOLNIK Okny. 24 MR. BAXTER: When you say, additional. I don 't 25 know what you mean beyond. () Heritage Reporting Corporation (202) 628-4888 l i

9 l 540 BY MS. SKOLNIX: {} 1 2 Q Okay. Costs above what you estimated the 3 evaporation proposal? 4 A (Buchanan) No. Getting water into the PWST is 5 part of our processing activity so that element which we 6 refer to as pre-processing. I suppose you could say an 7 element of that cost, you 're moving water around. 8 Q Will the PWST-2 be filled to its capacity of 9 500.000 gallons? 10 A (Buchanan) Not necessarily. 11 Q What will determine the amount in there? 12 A (Buchanan) When we 're ready to go. That 's purely 13 an operational decision. 14 Will you estimate the tanks. the -- will you (]} Q 15 follow a process of selection of tanks in order to feed them 16 into t),e PWST-2? Or. will it be random? 17 A (Buchanan) We 're not sure yet. We 'll nake a 18 decision to isolate a tank and take samples and then 19 process. 20 We can process that tank until it 's empty or we 21 could stop at any time and then move to another tank. I 22 don 't see that it makes any dif ference. 23 Q Would you mix tanks? 24 A (Fuchanan) If there is any mixing, that will be 25 done before in what I 'll call, final isolation of the tank. 4 Heritage Reporting Corporation (202) 628-4888 I

541 {) 2 i Yes, the TlCR gees through that. You take a staging tank. You decide that you 've l 3 got the watet- that you want there. You sample what you have  ! 4 for your it:f'.uent e..id then proceed with the processing, j 5 Once ycu have drawn your sample, you 're not going i 6 to add any more water to that tank. l 7 Q In the flow rate of five gallons per minute does , t 8 that refer to the flow between the PWST-2 and the VC-300 ) 9 concentrate tank? f i 10 A (Bechanan) It works out to be, yes. l 1 i j 11 Q Is the flow rate between the VC-300 concentrate i t 12 tank and the VC-300 main evaporator the same rate? l 13 A (Buchanan) No. j () 14 Q What will the rate be between those two tanks? [ i 15 A (Buchanan) Well, it will be somewhat higher. [ 16 Because there 's a recycle stream that goes f rom the 17 evaporator back to the concentrate tanks. [ 4  ; 18 You know, the net result going through the system l t i 19 is 5 GPM. But the flow going down any given pipe way be j 20 different.  ! 21 Q What would be the -- is there a maximum for the f i 22 flow between the concentrate and the main evaporator? l 23 MR. BAXTER: Obj ec t ion. The flow rate of the f 24 system was thc subject of contention 4(d). It has been t 25 decided by the Board in summary disposition that the system ( Heritage Reporting Corporation ! (202) 628-4888 1 l 4 l t

542 1 is going to run at 4 GPM, 5 GPM. 2 I see no relevance of this to Mr. Buchanan 's 3 t es t irrony. 4 JUDGE BLOCH: Ms. Skolnik, why are you so 5 concerned about the flow rate? 6 MS. SKOLNIK Because I am trying to -- could I l i 7 come back to it?  ! [ 8 JUDGE BLOCH: Only if you cun tell me why it 's j 9 relevant. l i 10 MS. SKOLNIK Richt. Now do I have to? 11 JUDGE BLOCH: There 's a motion riCht now to strike { 12 it.  ! 13 MS. SKOLNIK: Okay.  ! ( 14 JUDGE BLOCH: Ms. Skolnik. I know it 's dif ficult 15 to do this for a non-lawyer. But I really want you to know l 16 what your questions are relevant to before you ask them so I 17 that when someone asks you why is it relevant, you know. { 18 MS. SKOLNIK: I know. 19 JUDGE BLOCH: We can waste a lot of time if you l [ 20 don 't know why things are relevant, j 21 MS. SKOLNIr.: Wel1. it 's relevant because I 'm j i 22 leading up to a question. j 23 JUDGE BLOCH: About what? 24 MS. SKOLNIK: About the -- when the water leaves l 25 the main evaporator it 's recycled into the concentrate tank. l l Heritage Reporting Corporation (202) 628-4888 l L..____

i 543 (}' 1 JUDGE BLOCH: Yes. And? 2 MS. SKOLNIK Does it mix? Does it become a part 3 of the next amount of water that is fed in? 4 JUDGE BLOCH: Why does that matter? ) l 5 MS. SKOLNIK Because the water that will be ) 6 recycled from the main evaporretor will be, will contain the l 7 radioactivity that has been removed by the evaporator. 8 So it 's going back into a tank. l 9 JUDGE BLOCH: Okay. You want to know whether any ( 10 of the removed radioactivity will be recycled into the 11 system subsequently? f 12 MS. SKOLNIKt No. I know it will be recycled and 13 it 's going into the VC-300 concentrate tank. That water is t () 14 going back in there. 15 What I 'd like to ascertain is, is it mixing with  ! 16 water already in there and the tine is relevant to the time p ( 17 when it leaves the VC-300, it 's going through the evaporator  ! 18 and back into the concentrate tank. [ i 19 Is it tine enough for the concentrate tank to have j t 20 been emptied or is the recyclable stuff going back in to mix i t 21 with what was there orih?nally? 22 MR. BAXTER: And what would be the consequence of 23 that ?

                                                                                                                                                                                       ?

24 MS. SKOLNIK: The consequence of that would be an [ I 25 increased radio isotope concentration going into the j () Heritage Reporting Corporation (202) 628-4888 I

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s 544 {} 1 2 evaporator. MR. BAXTER: You 're saying the evaporator somehow ( 3 is creating more radioactivity than goes into it? l t 4 MS. SKOLNIK: The evaporator changes the  ! 5 concentrations of activity in the batches.  ; 6 JUDGE BLOCH: You want to know whether any 7 condensed bottoms are somehow going to get back into the [ 8 system? f 9 MS. SKOLNIX: No. I 'm not talking about the l I 10 co ndensed, the bottom. } 11 JUDGE BLOCH: What is going to get back to the j i 12 system? I 13 MS. SKOLNIK: In the diagram -- f 14 JUDGE BLOCH: What 's that? I (]) 15 MS. SKOLNIK In the diagram?  ! 1 16 JUDGE BLOCH: Yes.  ! i 17 MS. SKOLNIK: A certain percentage of the water --  ; 18 JUDGE BLOCH: Okay. So you want to know what goes l 19 back, is that right? What is recycled from the VC-300 back i 20 from the main evaporator to the concentrate tank? Is that l 21 your concern? What le it that goes back to the concentrate f i 22 t ank? { t 23 MS. SKOLNIK: I believe I worked it out.  ; i 24 BY MS. SKOLNIK:  ! l 25 Q How much water coes back out of the main i () Heritage Reporting Corporation (202) 628-4888 l t

1 545 ' {} i 2 evaporator into the recycling stream which takes it back into the concentrate tank? l 3 A (Buchanan) I don 't see it here. Try to look f 1 4 throuch the TER. The TER provides a description of how the i 5 system works and how it ties together.

6 My thinking is that it's three or four, you know.

7 GPM per vat. That 's an intricacy of the machine. 8 JUDGE BLOCH: What are the things that go back to 9 the concentrate tank? 10 THE WITNESS: (Buchanan) Well, there is the -- t i 11 JUDGE BLOCH: What 's the contento of it? 12 THE WITNESS: (Buchanan) Well, it 's concent rated I 13 water. () 14 JUDGE BLOCH: Concentrated water? 15 THE WITNESS: (Buchanan) Yes. 4 16 JUDGE BLOCH: I didn't know there was such a thing 17 as concentrated water. I thought water was water.

18 THE WITNESS
(Buchanan) It has a higher 19 concentration of particulates in it.

2

                 'O                                                                           MS. SKOLNIK     Of radioactivity, i

21 JUDGE BLOCH: Of radioactive particulates? 22 THE WITNESS: (Buchanen) Sure. 23 MS, SKOLNIK Yes. 24 JUDGE BLOCH: Why do you do that ? Why do you eend 25 the radioactive -- l ) Heritage Reporting Corporation (202) 628-4888 l l

046 ( t 1 THE WITNESS: (Buchanan) Because this is the way { }_ 2 -- we 're now getting into the heart of this man's, or this 3 company designed system, f 4 This is part of his package which we are leasing  ! 5 from him to do the work. This is how the company designs 6 their system. 7 JUDGE BLOCH: It works better to do that. 8 THE WITNESS: (Buchanan) It works this way. 9 JUDGE BLOCH: It 's j ust the engineering design to 10 be able to 1.000 part reduction. 11 MS, SKOLNIK2 I think what I 'm really -- 1 12 JUDGE BLOCH: Do you have some reason to question 13 that basic engineering design? 14 MS. SKOLNIK: I guess I do, yes. (]) ? 15 JUDGE BLOCH: What is that? 16 JUDGE PARIS: What is it? 17 MS. SKOLNIK: Because the concentrate from the 18 evaporator is going back into the concentra+,e tank. And i t 19 could increase the radio isotopic content af the water 20 coming in there. 21 So that in effect. the radioisotopic content te getting stored up. JUDGE BLOCH: Well. the purpose is to concentrate 24 things so that they can come of f as bottoms later. That 's 25 the very purpose of the machine. l ( Heritage Reporting Corporation 4 (202) 628-4868 i 4 4

  --,--------,.---------.--------,---.,,----------------------------------------------------------,.-------,----,----------------,----,------,3 S47

{} 2 i I 'd suggest that I haven't heard anything of an engineering nature that would suggest that you really have a 3 problem with it f rom the sophistication of an engineer. 4 This is a really complicated process. You need 5 some notion of what the engineering of it is. You can't 6 just look at it and say. I 'm a layperson and I don't like it 7 going back. 8 I mean, that 's j ust the way the machine works. It 9 would be like saying. I don't like the way TV works. 10 MS. SKOLNIK I 'm not really saying. I don 't like it it. j 12 JUDGE BLOCH I don't understand then. You 're not 13 understanding and not being an expert in it really isn't () 14 very important.

15 JUDGE PARIS
Is it the concentrate f rom the main 16 evaporator that is the bottom stuf f that 's going to be 17 recycled back to the concentrate tank?

18 THE WITNESS: (Buchanan) Yes. it does.

19 BY MS. SKOLNIK:

I 20 Q Did you look at any other designs? ] 21 JUDGE BLOCH: That was ruled out. 22 MS. SKOLNIK: Okay. 23 JUDGE BLOCH: That was ently. , 24 MS. SKOLNIK: Can I please take a break? f 2! JUDGE BLOCH: I don't mind a break but I 'd like it  ; 4 i Heritage Reporting Corporation ( j (202) 628-4888 j i 1 1 I

L t i i 548 I 1 to be more efficient when we get back. I 'd like you to know {

j. 2 what things are relevant to when you ask them.  !

3 And if either counsel for the Licensee or myself  ! t 4 asks. what 's it relevant to. I 'd like you to know that i s 5 because that 's why you 've asked it. [ 6 We 'll take a 10 minute break. We 'll be back at l 7 4:18. I have 4:08. 8 ( Whe reupon, a short recess was taken.) i 9 JUDGE BLOCH: We are back, i i 10 MS. SKOLNIK: Okay. I 'm Boing to leave the line t I i i 11 of questioning about the evaporator for the moment. And I 'm  ; d

!            12 going to go back to Mr. Buchanan's testimony on page 10.                                                                                                              !

J 13 BY MS. SKOLNIKi  ! () 14 Q The eighth line up f rom the bottom. Mr. Buchanan. 15 it begins. "therefore the joint intervenor 's alternative"? $ i 16 Okay ? { l 17 Also could you please cet out the Licensee 's i , I 18 answers to SVA 's second set of interrocatories. March 30. l i I 19 1980, page seven. l (Buchanan) 20 A Page seven is a table chart?  ! 21 Q Yes, a table, yes. If the sum of the operational , i' 22 capacity for all of these 25 locations is over 2.800.000  ; f 23 gallons, why is there a need to build additional tankage for j 24 the joint intervenor 's alternstive? 25 A (Buchanan) The arsumption there that there was to j ( HeritaRe Reporting Corporation 1 (202) 628-4888 1 J

549 i be no tankage inside the reactor building or the fuel 2 nondling auxiliary building. 3 In other words, tankage would be outside. 4 Q Which tankage is on the inside? S A (Buchansn) Within this list? 6 Q Yes. Are you saying that the tankage inside could 7 not be used for storage for a long term storage period? 8 A (Buchenan) What we tried to arrive at had kind of  ; 9 falling process. TWST wanted to or the primary, you know. l 10 their large storage tanks. 11 An additional tank that is outside that could be 12 used in the borated water storage tank which is also { t 13 approxirnstely, vell, a little bit less than a half million j O 24 ceito"= ceracitv-l 15 If I wanted to have additional capacity for long 16 term storage that would not interfere with the other l v 17 programs that have been forecast or made for the plant. X l t 18 would need to have the additional tankage outside. ( 19 Therefore. I would need to construct approximately [ t 20 another or what we assumed was two more half million gallon t i 21 tarRs. { ( 22 JUDGE BLOCH: Is that the sentence prior to the  ;

                                                                                                                       +

23 one that you had your atter'a. n called to? Is that the I f, 24 meaning of that sentence? i l 25 THE WITNESS: (Buchanan; That's correct. [ h Heritage Reporting Corporation l (202) 628-4888 j

                                       .. .__ __       .=            -   ._.    . _ _ .

I [ 550 1 JUDGE PARIS: Where are the -- { l 2 JUDGE BLOCH: Wait a minute. Ir<'s finish with 3 this first. 4 JUDGE PARIS t I 'm sorry.  ! l 5 BY WS. SKOLNIX: i i p .6 Q Are you sayinC that all of the tanks other than  ! 1 7 tne PWST 1 and 2 and the borated water storage tank. are 8 they inside the reactor building? j u 9 A (Buchanan) No. They're in vLrious locations. 10 JUDGE PARIS: Where are they? 11 THE WITNESS: (Buchanan) Well, come are inside j 12 and there 's the CCT-1 is also an outside tank. There are 13 twc of these tanks which are in the EPICOR buildinC. i () 14 BY MS. SKOLNIK: iS Q I 'm sorry. In the upper. 16 A (Buchanan) No. let 's start again. 17 Q EPICOR? 10 A (Buchanan) I made a mistake. Let me start again. 19 COT 1-A is an outside tank. CCT-1 and CCT-2 are in what I 'll 1 20 refer to as the EPICOR building, i 21 The rest of the tanks are in either the auxiliary 22 buildina, fuel handling buildin8 or the reactor building. 23 Q When the utility has placed unit-2 in the storage 24 mode known as PDMS. why would these tanks be in the way of 25 PDMS activity? () Heritage Report i ng Corporation (202) 626-4888 1

    ""':_rt'-r.   -

r- - . - - -

? , I l l 551 _ 1 A (Buchanan) One of the assumptions of the PDMS 2 program is that we'l1 maximine the draining of alI systems l l l 3 tanks et cetera. [ l  ! 4 JUDGE DLOCH: You 11 do what?  ; l 5 THE WITNESS: (Buchanan) Maximize the draining or l l 6 the removal of tiquids from many of the piping system tanks f I 7 inside the fuel and aux handling building and reactor  ; l 3 l 8 building.  ! ! 9 That 's one of the assumpt tons for the PDMS ( f 10 program, i 11 JUDGE BLOCH: And the purpose of the assumption l 12 is? 1  ? 13 THE WITNESS: (Buchanan) Well, it really kind of,  ! I i O 24 t detteve- rei tee to eccideat - <o" x" e re trviae 1 15 minimi=e the mobility of radioactive materials. The I 16 residual materials may be lett behind. 17 So that 's a tenant of that program. the removal of l 18 water. i f 19 JUDGE BLOCH: So somehow there's nore risk l 20 associate with leaving it within thore reactor systemn than ( 21 putting it another storage container? 22 THE WITNESS: (Buchanan) I'm not sure of the risk - ( l 23 trode off. k l 24 JUNE BLOCH: So there may not be any saving of j 25 risk in taking it out of those systems and putting it in 1 Heritage Reporting Corporation J (202) 628-4888 l i I ! t

4 5 #u- - 4 4 (r ' I 552 fr~') i separate storage? Al 2 THE WITNESS: CBuchanan) I 'm really not able to J 3 answer that question. I think. you know, the question where 4 we got started was, the assumption that we were going to 5 store the water for a long term. 6 I think you then have to make the assumption that 7 this storage does not interfere with other programs and 8 other activities. 9 JUDGE BLOCH: But that 's what Ms. Skolnik is-10 asking. How does it interfere? You have only said that 11 it 's part of the goal of the other program not to do it but 12 we still don't know why it interferes. 13 THE WITNESS: (Buchanan) The assumption of the () 14 post de-fueling monitored storage is that we want to

15 minimize to the maximum extent possibility, the mobility cf 16 any residual redioactivity material.

17 The most prevalent mobility is water. 18 JUDGE BLOCH: But you don 't know why it will 19 minimize that mobility by moving it from where it is to 20 these tanks outside the container? 21 THE WITNESS: (Buchanan) Well, surely if the 22 water is no longer in the building then that reduces or 23 eliminates the mobility of the mobile force of any residual 24 material left in the buildings. 25 JUDGE BLOCH: By definition in the building, it () Heritage Reporting Corporation (20?) 628-4888

553 (' N 1 does, but it just moves the location of the problem, does n 't d 2 it? 3 THE WITNESS: (Buchanan) Yes. The water is now 4 outside, certainly. 5 JUDGE BLOCH: Why is that an advantage? 6 THE WITNESS: CBuchanan) I didn 't say it was an 7 advantage. It was an assumption of the program that 's being 8 set forth. 9 JUDGE BLOCH: I suspect some other witness knows 10 the answer to this? 11 MR. BAXTER: I 'm not sure, Judge Bloch. I 'm 12 confused by the question myself. We 're proposing to dispose 13 of the water. () 14 We 're not proposing to store it anywhere. We have 15 attempted to make a good faith evaluation of the 16 intervenor 's alternative. 17 They had a contention eight in containment 4 18 storage. That 's beea disposed of. We then asked them in 19 discover, where would you propose we store the water? 20 We got answers like, the best place, the safest 21 place. We have now made a good faith assumption that we 22 vrould use the two PWST 's. PWST and build two more tanks. I 23 That is to evaluate their alterrative. 24 JUDGE PARIS: It has been my understanding -- 25 MR. BAXTER: The wisdom of PDMS is rot on trial Heritage Reporting Corroration (202) 628-4888

_~, r i 554 1 here. 2 JUDGE PARIS: It 's been my understanding is that 3 there are not enough existing tanks to store the water that 4 needs to be stored. is that true? Anybody ? 5 JUDGE BLOCH: Who are you asking? , 6 JUDGE PARIS: Anybody? i 7 MR. BAXTER: Mr. Buchanan? 8 THE WITNESS: (Buchanan) Well, certainly. I mean 9 it's all stored somewhere now. It 's not all in tanks. Some i 10 of it is in canals it will have to remain in the canals.  ; 11 JUDGE PARIS: Is there some of it in the bottom of 12 the containment building too? 13 THE WITNESS: (Buchanan) Yes, but there is (~T 14 tankage room. We could move that water out of the reactor us/ 15 basement and put it into a tank. So that in itself is not a 16 limitation. 17 JUDGE PARIS: Okay. 18 THE WITNESS: CBuchanan) But the water in the 19 canals, there is not enough tankage to remove that water and

20 put in it any other tankage.

) 21 JUDGE BLOCH: Counsel, you may want to clarify 22 because I don't understand why it can 't be lef t where it is. 23 I j ust don 't understand because then we would save. 24 MR. BAXTER: Is the current source locations of l l 25 the water appropriate for long term 30 year storage? i

       )                  Heritage   Reporting Corporation (202) 628-4888                              l

s 555 1 JUDGE BLOCH: Well, first, do you know whether [} 2 it 's appropriate? 3 THE WITNESS: (Buchanan) I 'm not comfortable with 4 the question. I 'm not sure of my answer. One of the things 5 that concerns me is there is a number of tanks -- 6 JUDGE BLOCH: Stop. I'd like you first to say 7 whether you know whether it 's appropriate to leave it where 8 it is as opposed to putting it in another tank. j 9 THE WITNESS: (Buchanan) I 'm going to say -- 10 JUDGE BLOCH: Then you can clarify it. 11 THE WITNESS: CBuchanan) I 'm going to say, I do 12 not know. , 13 JUDGE BLOCH: Okay. And you can clarify that now? () 14 THE WITNESS: (Buchanan) Yes. The first thought 15 that comes to mind is that there are o number of tanks. 16 You know, the monitoring of those tanks and 17 insurance of valves not leaking, the integrity of the tanks 18 will become a monitoring problem with the passage of time. 19 These tanks were not -- many of them were not 20 designed for long term storage but they 're processing 21 equipment. 22 Therefore you do have active isolation that you've 23 got to keep your eye on. We are encunibering the company 24 with a fair anount of work, I believe, if you use existent  ! 25 tankage for long term storage, i

     )                  Heritage   Reporting   Corporation (202) 628-4888                           :

i i

i l 56G i JUDGE BLOCH: I 'm not - tu e what the current 2 condition of the equipment is, bu 'asr. 't . it designed for 3 high pressures and a lot of dif feren' stresses that it 's no'.

                                                                                 ]

4 receiving right now? 5 THE WITNESS: (Buchanan) With an active , 6 maintenance program also. 7 JUDGE BLOCH: Yes. With an active maintenance 8 program it was designed to have continuous cycling ttr lugh 9 nuclear pressures. 10 THE WITNESS: (Buchanan) That 's true and there is 11 an active maintenance program going on. That 's why I 'm not 12 comfortable with giving you a definitive answer like my 13 opinion is what I 'm really expressing is. g () 14 That I don 't like it is one of the things that 15 makes me a little nervous is the issue of assuring, you i 16 know, high quality containment over a long period of time. 17 JUDGE PARIS: Are there canals in which come of the water is stored. open canals? I 18

19 THE WITNESS
(Buchanan) Yes. They 're inside a [

20 building but ventilated building. They are open, yes. 21 JUDGE PARIS: I thought you said you did not have  ! 22 tanks for those? 23 THE WITNESS: (Buchanan) There is no tankage.  ! 24 there is no available tankage to transfer the water out of [ 25 the canals into a tank. t 1 [ ( Heritage Reporting Corporation I (202) 628-4888 i l

557 l l {} 1 2 JUDGE PARIS: So it is inh?rently undesirable to have radioactive water' stored in open canals for a long

           .3 period of time?

4 THE WITNESS: (Buchanan) No , again, those canals 5 were designed to do that. So, you know, it 's certainly 6 within their design criteria. It could be done. It 's j ust 7 that we have never talked about doing that to the best of my 8 knowledge. 9 BY MS. SKOLNIK: 10 Q But regardless of where the position of the tank 11 would be, isn 't it true that some of the tanks some of the 12 time would meet the criteria for adequate storage? 13 A (Buchanan) Well, the answer has to be, yes. Yes. () 14 they are high quality tanks. 15 Q Isn 't it true -- 16 A (Buchenan) But you know it 's j ust, you know, it 17 could be done. 18 Q Isn 't it true. Mr. Buchanan, that when the NRC 19 ordered that the water be processed and be put into tanks 20 that they were thinking of at least of a period of up to 60 21 years and the water was to be stored safely? 22 Therefore when the NRC commissioned -- 23 JUDGE BLOCH: Okay. Stop. Ftop. Do you know 24 whether it 's t rue that the plans for these tanks involved 25 storage up to 60 years? Do you know whether or not that 's ( Heritage Reporting Corporation (202) 628-4888 4

r, - 558 1 true? 2 THE WITNESS: CBuchanan) I do not know what 3 you 're referring to, no. Which order? 4 BY MS. SKOLNIK: 5 Q ~The order when the NRC Commissioners ordered for 6 the EPICOR SDS system to process the water and 1 hen the 7 water was to be stored in tanks. Are you aware of that 8 order for a period up until the time when disposal would be 9 decided? But that period was not specified. 10 A (Buchanan) I don't know what the order specified 11 in terms of time. No, I do not. 12 JUDGE BLOCH: Where did you 60 years from?

13 MS. SKOLNIK
60 years was a period which one of 4

() 14 my witnesses has referred to. I believe it 's in the 15 question about -- 16 JUDGE BLOCH: One of your witnesses? 17 MS. SKOLNIK: Pardon? 18 JUDGE BLOCH: That one of your witnesses referred 19 to? 20 MS. SKOLNIK: No. A witness. A person that had

21 to write testimony in. Louis Gazarra. It 's an NRC document, i
22 an NUREG document, one of the most frequently asked 23 questions about cleanups.

24 JUDGE BLOCH: Okay. Let 's continue. 25 BY MS. SKOLNIK: I () Heritage Reporting Corporation (202) 628-4888 l l ! l

559 1 Q Isn 't it true though that when these storage tanks b'~~; 2 were chosen for storage that there was not a time limit on

        -3  the amount of storage? That these tanks --

4 JUDGE BLOCH: I 'm not sure what you 're contesting. 5 I don 't think the applicant 's are stating that the tanks its 6- in are unsuitable for continued storage. 7 If I understand correctly, it 's the systems within 8 the containment building that they 're concerned about 9 leaving it in. 10 Am I correct about that. Mr. Buchanan? 11 THE WITNESS: (Buchanan) The only reason I 'm 12 stumbling a bit because the proposal is different then. I 13 guess I 've been caught of f guard a little bit with the () 14 questions of utilizing the existing tanks. 15 It 's j ust that, that is not something that or it 's 16 just not an idea that we had, that we had developed. Or we 17 did not even think that, that was a question that was or en 18 answer to any questions that were posed to us. l 19 JUDGE PARIS: Did you not say a few minutes ago

20 that some of these tanks were processing tanks and were 21 really uncultable for long term storage? ,

22 THE WITNESS: (Buchanan) I went to raise that 23 question with the tanks. And again, I 'm shooting f rom the

                                                                                     ?

24 hip. 25 And even though they 're processing tanks, they are Heritage Reporting Corporation (202) 628-4888 i l

l l 560 {} 1 2 good tanks. I'm just a little concerned with the amount of maintenance that we might be asking for ourselves to have to 3 do over the storage period of time. 4 It 's not as passive in terms of people or 5 responses as just having a few, you know, larger tanks. 6 JUDGE BLOCH: The problem that I have tha'c in 7 order to accept some estimate from the Licensee of the cost 8 of the intervenor 's proposal and there may be some changes 9 in what they proposed as of their beginning testinony today. 10 But in order to accept that, it has to be somehow 11 sympathetic to what they 're proposig. And I 'm j ust. I 'm 12 not hearing right now. 13 THE WITNESS: CBuchanan) And again I think part () 14 of my reluctance or my reluctance to kind of jump on it is I 15 that it is in conflict with the dir( tion that we 're heeded 16 with the PDMS program. I 17 JUDGE BLOCH: I haven 't heard what the conflict 18 is. It 's j ust that ther assumptions are dif ferent. I know 19 the assumptions are different but I 'm not sure what the 20 conflict is. 21 But you said you don 't know either. So, let 's not 22 continue on that. , 23 THE WITNESS: (Buchanan) Okay. I have to do some 24 homework. 4 25 i I () Heritage Reporting Corporation (202) 628-4888 i l J

c 561 ( 1 BY MS. SKOLNIX:

 ~().

2 Q But you-did come up with a figure for additional 3 tankage? 4 A (Buchanan) Yes, I did. 5 JUDGE BLOCH: May I ask you this, Ms. Skolnik? 6 Are you still arguing the tankage proposal that you were 7 previously arguing? 8 Or are you now arguing that you'have to have 9 11.000 gallon tanks which was what your first witness was - 10 arguing? 11 MS. SKOLNIK: I 'm looking at a variety of 12 alternatives. 13 JUDGE BLOCH: Okay. Because you understand that , () 14 building all 11.000 gallon tanks will be probably a lot more 15 expensive than this? 16 MS. SKOLNIK: So I 'm investigating the use of 17 tanks already in existence. 18 JUDGE BLOCH: Okay. 19 MR. BAXTER: But that's part of the problem with 4 20 preparing with this hearing is a totally ill-defined l 21 alternative that jumps around from moment to moment.  ; , t 22 MS. SKOLNIK: The reason the alternative is ill- l 23 defined is because really the no action alternative has l l 24 never really been defined by the NRC nor has it been fully f 25 investigated. i ( Heritage Reporting Corporation - (202) 628-4888

T 1 1 562 1 MR. BAXTER: Okay. The NRC -- l (*)) t ' 2 JUDGE BLOCH: It must be defined by you. It must 3 be. Because you 're trying to show that something is clearly 4 superior obviously superior to what the applicant 's are a proposing. 6 MS. SKOLNIK: Well, you have placed that -- t 7 MR. B.tXTER : I must respectfully suggest to Judge 8 Bloch that it should have been defined at the contention 9 stage, not in the process of an evidentiary hearing. - 10 MS. SKOLNIK: Well -- 11 JUDGE BLOCH: Let 's get out of the cross fire 12 because I can't go back to the contention stage now. I 13 can't even go back to summary disposition. () 14 MR. BAXTER: No, but I don 't think -- I don 't 15 think it can be suggested that now is a good time. You 16 know, if you j ust want to give it some thought overnight and 17 come up with it tomorrow, we 'll all respond. 18 We have to live with the situation as best we have 19 it here. And the indication through discovery and the 20 responses to discovery has always been that there is going 21 to be tanks constructed for con'.ention two 's alternative.  ! 22 You were asked where the tanks would be located. 23 how many there would be. You never said, it 's not in my 24 mind to have tanks. We 're not proposing -- l r 25 JUDGE BLOCH: Are you making a notion at this ( Heritage Reporting Corporation (202) 628-4888  ! I i

l 563 a

 /~    1 point?   If there is, I might be able to act on it.      But I (T) 2  don 't hear a motion.. I just hear kind of frustration which 3  we 've heard f rom the intervenors too.

4 But frustration doesn't get us anywhere. If 5 there 's a motion, I might be able to do something. 6 MR. BAXTER :' I'm sorry for frustration in my 7 voice. But the purpose is to explain a little bit of the 8 record and why I think that it 's inappropriate at this point 9 for the intervenors to be asking questions about leaving 10 water in its current storage location. 11 That is not their alternative. That 's my point. 12 JUDGE BLOCH: But is there a motion? 13 MR. BAXTER: There 's not' a question pending, I () 14 guess there 's no motion. 15 JUDGE BLOCH: Okay. Continue. 16 (Continued on the next page.) 17 18 19 20 21

     ??

23 24 25

Heritage Reporting Corporation (202) 628-4888 i

564

     /"i  1            MS. SKOLNIK:   The reason first of all, that I 'm
    '\-)                                                                              ,

2 talking about the no action alternative is that -- 3 JUDGE BLOCH: There is no motion for you to 4 respond to. 5 MS. SKOLNIX: Okay. 6 JUDGE BLOCH: Just continue with your questions.  : 7 BY MS. SKOLNIK: 8 Q When you state that the above estimate includes 9 the cost of heat tracing for 500,000 gallon tanks for 30 10 years, are the two PWST-2 tanks already in existence? Do 11 they have heat tracing? 12 A (Buchanan) Yes, they do. 13 Q So you would not need to heat trace for the cost. () 14 the cost that you have thought for four tanks really should 15 have only been for two tanks? 16 A (Buchanan) No. We 're talking chout the operating 17 costs, the cost of electricity to heat 'our tanks for 30 18 years. 19 Q Are the tanks in which the water is presently l 20 stored heat traced? 21 A (Buchanan) Yes. 22 Q Every tank? 23 A (Buchanan) Outside tanks. 24 Q You say that it 's possible to design two 500,000 25 tanks for $1 3 million? I 'm sorry, page 11. I ( Heritage Reporting Corporation l (202) 628-4888 1 l ______J

vo ( 565 (~) 1 A (Buchanan) That*u correct.  !

    %j 2      Q     The $1.3 million cost refers to the two 500.000 3 gallon tanks. But the larger figure refers to which tank?

4 A (Buchanan) The larger figure and I assume you 're 1 5 referring to the 9.1 million gallons? 6 0 Yes. 7 A (Buchanan) Was a set of tanks which would satisfy 8 the criteria of generic letter 81-38. That reference came 9 to us through some suggestions I believe in some of your 10 earlier documentation. 11 We took a look at that generic letter, saw what 12 its requirements were and then developed a conceptual cost 13 estimate of what that meets. () 14 Q But are the two 500,000 gallon tanks which would 15 cost 31. 3 million, do they meet this criteria?

                                                                               ~

16 A (Buchanan) No, they do not. 17 Q Are they suitable for long term storage? 18 A (Buchanan) Yes, on the basis that the existing 19 tanks have been approved for the use of storage, you kno 20 storing water. 21 So we just said, well, the NRC has approved those 22 two tanks. And you know the safety evaluations related to 23 those tanks. We 'll build two more j ust like it. 24 And again it 's also an assumption of course that 25 the contents of the tank would be within the bounds of the Heritage Reporting Corporation (202) 628-4888

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   .. .   .v .     ,

566 (~) i ' existing safety evaluation. U 2 So that 's how we got there. Yes, we believe those 3 tanks are good for long term. 4 Q But is it also possible that some of the tanks 5 aisted on page seven would also be sufficient? Do they meet 6 the same criteria as the PWST-2 tank? 7- A (Buchanan) They 're both dif ferent criteria i 8 because they had a different design purpose. , 9 Q Are they suitable for storage? Could you identify ( i 4 10 the ones that would be suitable for storage? 11 A (Buchanan) Every tank is suitable for storage i

.              12     because it is a tank. you know.        Now you have to ask          !

i' 13 yourself, do I have, am I satisfied with the level monitoring? Am I satisfied with integrity? (]) it [ 15 People will have to go in and check these once in

16 a while. Am I asking them to go into a radiation area where 17 they 're picking up some radiation exposure? Is that a wise  !

18 thing to go do? I r 3 19 So, yes, we could use tanks that are inside the 20 building. They 're good quality. So again maybe I 'm j 21 changing my answer just slightly from what I said before. 22 But, you know. I 'm not going to say that there 's a j 23 zero cost associated with using the existing tanks either. 24 Q But it would reduce then the cost for our e

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25 alternative, wouldn't it? i s () Heritage Reporting (; ]2) 628-4888 Corporation  ! i t i r

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567 i (~)/ 1 'A (Buchanan) I have a problem looking at this 2 program totally independent of what GPU is seeking to do fot' 3 the post de-fueling monitored storage program. 4 You know, there is a conflict of what you 're  ! 5 proposing. That conflict obviously has to be resolved. So 6 you 're asking me why can 't I use these tanks. 7 I'm answering you partially because I know what j 8 the company is also trying to do on another program and  ! 9 there 's that conflict. l 10 Q Okay. But aside from that conflict, what I 'd like 11 you to state is whether or not the tanks are suitable, j 12 JUDGE BLOCH: He has answered that question. 13 MS. SKOLNIK: Okay. l(]) 14 (Pause) 15 BY MS. SKOLNIK:  ; 16 Q Mr. Buchanan, on page 13 you say that the cost of 17 disposing and after 30 years could cancel each other out and 18 therefore you would be left with the additional cost of $1 9 < l 19 million? l 20 A ( Bucha nar.-) Yes. 21 Q But if you could use tanks that were already in i i i 22 existence, the cost would be less than the $1.3 million? l (Buchanan) 23 A I don 't know that. It might be lower. 24 It might be higher. 25 Q Isn 't it also true that it could be possible to 1 ( Heritage Reporting Corporation (202) 620-4888 I 1 l

I~ ' 568

    . i dispose of the water in years to come with costing less 2  money?

3 A (Buchanan) I don't have any basis for agreeing or 4 disagreeing.  ; i 5 Q So you don 't have any -- okay. j 6 A (Buchanan) When you say -- well, certainly the l l 7 cost of -- I would expect that the cost of getting rid of I 8 the bottoms is going to go up. 9 mear. if activity over the last 10 years is any { 10 guide, it will have gone up substantially within the next 30  ; 11 years. 12 Q That 's if we evaporate the water? 13 A (Buchanan) Well, you 've got to do something with i 14 the bottoms. 15 Q If we didn 't evaporate the water though, if there j 16 was another method used, isn 't it possible that it could 17 cost less? , 18 MR. BAXTER: I obj ect. That question is so open i 19 ended and vague, it is meaningless. l 20 JUDGE BLOCH: Could you restate it, please? [ 21 BY MS. SKOLNIX: l l l I

22 Q Is it possible that in 30 years' time, disposal of

[ 23 the water might cost less than the evaporation process { i 24 today?  ! 25 JUDGE BLOCH: I 'll answer that. It's possible. j Heritage Reporting Corporation (202) 628-4888 4

t 569  ! i It doesn't get you much because anything is possible. J '} 2 MS. SKOLNIK: I'd really like to call a recess. 3 Judge Bloch. I really don 't think I can continue today. 4 JUDGE BLOCH: I would like you to finish with S these witnesses today. 6 MS. SK0LNIK: I know. I would like to too. But I L 7 cannot continue because I am exhausted. 8 JUDGE BLOCH: Could you tell me what the areas 9 are? My concern is that it 's always possible to work 10 overnight and cone up with more questions. 11 And I would rather have you prepared to finish i 12 with a panel and not be going through repeated times of 4 f' 13 breaks and overnight breaks in order to come up with more () 14 questions.  ! 15 If there 's something really important I expect 16 that you know it now. You had plenty of time to prepare for 17 the hearing. L i 18 (Pause) r l  ! 19 JUDGE BLOCH: I think it 's only going to get L 20 worse. We 're only on the second day. We 've got two or a 21 three more days this week. , i 22 MS. SKOLNIX: I don 't wish to question the l 23 witnesses any furthe .

                                                                                 ?

24 JUDGE BLOCH: You didn't ask anything about ( l . 25 accident risks. Was that intentional or have you forgotten j l 1 Heritage Reporting Corporation I L (202) 628-4888 4 { r i . I

l: 4 570 i i about it? { {- 2 MS. SKOLNIK: I reel 1y cannot formulate any more j 3 questions today. ! 4 JUDGE BLOCH: Okay. Does the staff have any l 5 questions? l 6 MR. STEPHEN LEWIS: No questions. 1 l 7 JUDGE BLOCH: Pedirect? 8 MR. BAXTER: Can I have just a minute. 9 (Pause)

10 MR. BAXTER
We don 't h.sve any redirect.

) 11 JUDGE BLOCH: I do have one question, Mr. 12 Buchanan. You said that you thought that if the water was i

13 left in its present place in the containment that the cost i

O 14 =teht de ee cree

  • or areeter the" *1 3 mi> > to"-

l 15 Could you tell me something about your basis for i i 16 that belief? I 17 THE WITNESS: (Buchanan) My main basis is I l j 18 really haven't had time to sit down and think what all the r 19 problems might be. l f 20 It 's a lar;e piece of my reservations. One of the l l 21 things I got to thinking about is that our program for PDMS i l i l 22 is to make the plant extremely stable to the point of ! l [ 23 shutting down the ventilation system. j i i l 24 If I have water in the tanks and am going to have I 25 to be making f requent excursions just for routine Heritage' Reporting Corporation (202) 628-4808 { l i i

i 571 (} 2 1 monitoring, perhaps I need to be leaving.the ventilation system in place. 3 That in itself is a f air chunk of cost. 4 Winterization again our assumptions were along the lines 5 that we would, by draining the water out of all of the tanks 6 et cetera, we could let the temperature drop in the building 7 with no consequence. 8 Now that I 've got tanks full of water I'm going to 9 have to be worrying about heat, maintaining heat in the 10 building. 11 Also, you know, a lot of cost for that also. l 12 JUDGE BLOCH: So you just really don't know what . 13 the costs would be to other plant systems and to continued () 14 operations if you left the water in place in the systems in 15 which it 's located? l 16 THE WITNESS: (Buchanan) That is correct. J 17 JUDGE Bl.OCH: Does that give you more redirect? 18 km. BAXTER: No. ! 19 JUDGE ELOCH: Okay. Ms. Skolnik, re-cross based , 20 on what just happened? l 21 MS. SKOLNIX: No. 1 22 JUDGE BLOCH: Thank you. I 'd like to thank the 23 panel for its participation and you 're excused f rom the 24 s t a nd. ] I 25 (#hereupon, the witnesses were excused.) !( d Heritage Reporting Corporation (202) 628-4088 c

e 572 ('T

  %)

1 JUDGE BLOCH: We 'll resume in the morning. Off  ; 2 the record. 3 (Discussion held off the record.) 4 JUDGE BLOCH: On the record. Based on Ms.  ; 5 Skolnik 's motion of this morning. I 'd like - to start at 6 9:15 tomorrow morning. 7 So we#11 begin at 9:15. We may also go to 5:15 in 8 the evening or later if it 's appropriate based on where we 9 are at that time. We are adj ourned. 10 ( Whereupora, at 4:55 p.m.c the hearing was recessed 11 to reconvene, tomorrow, Wednesday. November 1, 1988 at 9:15 12 a.m.) 13 () 14 15 16 17 18 19 20 21 22 23 24 25 e i Heritage Reporting Corporation (202) 628-4888 4

572 1 JUDGE BLOCH: We 'll resume in the morning. Off (-)') t 2 the record. 3 (Discussion head off the record.) 4 JUDGE BLOCH: On the record. Based on Ms. , 5 Skolnik 's motion of this morning. I 'd like us to start at 6 9:15 tomorrow morning. 7 So we 'll begin at 9: 15. We may also go to 5:15 in 8 the evening or later if it 's appropriate based on where we 9 are at that time. We are adjourned. 10 (Whereupon, at 4:55 p.m., the hearing was recessed 11 to reconvene, tomo rrow, Wednesday. November 1. 1988 at 9:15 12 a.m.) 13 ( 1 15 16 17 18 19 20 21 , 22 23 t 24 l 25 , i Heritage Reporting Corporation (202) 628-4888 1 1 l l l

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1 Il 1 CERTIFICATE LJ 2 This is to certify that the attached proceedings before the 3 United States Nuclear Regulatory Corrrnission in the matter 4 of: I i 5 Name: General Public Utilities Corporation, et al. 6 Three Mile Island (Unit 2) License Amendment 7 Application j 8 Docket Number: 50-320 OLA 9 Place: Lar. caster, Pennsylvania 10 Date: November 1. 1988 11 were held ac herein appears. and that this in the original l 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Corraission taken stenographically by me, and 14 thereaf ter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing l 17 proceedingo. r i 18 (s/ *Oh M 19 Signature ty}ied: Joan Rose 20 Official Reporter 21 Heritage Reporting Corporation I 22 23 , 24 25 l 1 Heritone Reporting Corporation i (202) 628-4888}}