ML20235N162
| ML20235N162 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/20/1989 |
| From: | SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235N141 | List: |
| References | |
| 87-554-OLA, OLA, NUDOCS 8903010070 | |
| Download: ML20235N162 (23) | |
Text
..
. -1 Wps. .a
.. .., g i [
- ' _ February 20,.1989'
- United States of America ,, . . _ ,,,
Nuclear Regulatory Commission
" ' "~ *'
q in the Metter of ) Docket 850-320-OLA 1 Generel Public. Utilities . ) - ASt.BP 887-554-OLA ]
Nucleer Corporation. Et Al ) (Disposal of q (Three Mile lsland Station, ) Accident Generated . 1 Unit 2) )- Water)
APPLICATION; FOR A STAY OF THE EFFECTIVENESS0F THE FINAL'
" INITIAL DECISION LBP-89-07 FEBRUARY 2,1989-i A final Initial Decision was issued on February 3rd 1989 in the metter of the disposal of radioactive ecclent generated water ( A0W) at Three Mlle island (TMI). This decision concluded q that all metters had been decided in favor of the Applicants (OpVN) and that the requested /
emendment should be authorized. The decision removes the present prohibition on disposal of the A0W, imposed by NRC 0roers of May 1981. Subsequent to those orders, the radioactive water was ordered to be processed through two systems, Epicor 11 and SDS, for safe storage onsite and use in clean-up operations, which are presently ongoing. The decision permits the Licensee to dispose of the radioactive liquid weste by evaporation of the liquid, mlisction.of the solids to be disposed at e low level weste site, and the vaporization and release of the liquid containing all the tritium, some s . strontium 90, cesium, plutonium and other alphe emittats through a heated stack into the air around TMI.
Joint Interveners (di) hereby, respectfully request a stay of the effectiveness of this '!
final initial decision in accordance with 10CRF 2.788. These regulations specify the four factors which need to be belenced when determining the outcome of an application for a ste/ ( 10 CFR 2.788 4(e)). To justify the granting of a stay, a movant need not alwers estabilsh a high probability of success on the merits. Cuomo,772 F2d at 974. Indeed the language courts have l used to describe the success factor has varied, and it has been determined that the four considerations are factors to be belanmd and not prerequisites to be met. De Loreen,755f 2d at gs o@@ 1229 i n.
@M SVA/TMI A IS LIKELY TO PREVAll ON THE MERITS !
.o30 '
! o 2: 1. The Board Erred in Not Permittino Liliantion of Ji's Cnntention 2, M JI's Contention 2 addressed the inadequacy of the NRC's evolustion of the no-action 7 ellernative, it was admitted for litigation following the Board's ruling on Licensee's Motion for
[ hg Summary Disposition (0roer on Summary Disposition, August 25,1988 Page 22). The Board agreed that the NRC had given inadequate' consideration to this alternative (ID Tr 105 and Tr 612). During the Hearings the NRC staff evaluated en alternative named " enhanced storage"
_____________ -. __ _ -)
e a,
2
', 9 - which was described as 30 years of storage followed by evaporation (Tr 762). This is neither the no-action alternative as described in PElS Supp. 2,3.5 nor JI's alternative (Tr 106).
The Board ruled that the insufficiency of the PEIS was " irrelevant at this stage" (Tr 104 Bloch) and therefore material issues of fact advanced by JI in Contention 2 were not litigated. The NRC had the responsibility to study, develop, and describe the no-action -
alternative (NEPA 42 USC 4332 (t)).
The Board then pramwiwi during the Hearings to demand that JI develop an alternative and prove that is was "obviously superior" (Tr 103 Bloch). This In spite of the fact that the courts have rejected the concept that an Intervenor had a burden to make any affirmative .,
showing. They have held that on Intervenor need only bring sufficient attention to the issue to stimulate the Commission's consideration of it. 547 F2d at 628.
- 2. The Board Erred in its klantation and Anolication of the Obvious 1v Eneior Standard.
The Bonrd adopted and applied tne "obviously superior" standard ( Memorendum and Order August 25,1988 P. 8). This standard affords a comparison between a site for which a -
permit has been granted and construction has begun (of a nuclear power plant), with an alternate site.
This was hardly a fitting analogy for two reasons. Firstly, until the Hearings JI had not offered a preferred alternative ( Final Initial Decison, P. 26). Instead JI entered the procedin0s with questions concerning the adequecies of the PElS and Licensee's proposal (Tr 580 Lines 22-44 Skolnick). It should be noted that JI developed an alternative under duress while the Hearings were on-going. The Board had permitted a ten ( 10) minute recess (Tr 586). The alternative described by JI was therefore similar to taking no-action which was in keeping with their mncerns admitted for litfgetion. Secondly, in previous application of this standerd a decision had been already made to take action (That is build a nuclear power plant) and the question of citing was at issue. In these proceedings the issue was whether or not to take action, that is, whether or not the water should be disposed and the amendment granted to the Licensee (Tr 3).
Additionally having adapted this standard the Board erred in its appilcation by demanding not only that JI mme forth with an alternative but must also show it to be obviously superior (Tr 103 and Final Initial Decision P. 26 Line 18- 19). Previous application of this standard shows that if a sight has already been developed it enjoys certain weight when making a decision about which is the best site.
Clearly Ji's allsenetive, i.e. storage onsite for an indefinite period ( Tr 106 Lines 12- 18 Skolnick) or maintaining the status quo (Tr 586-587) is to be equated with the site already developed. The Licensee's proposal on the other hand is a new proposal. Ji's alternative, initiated by NRC Orders in 1981, utilizes the treatment estems (Epicor/SDS) and the tankage which has stored the water for 8 years and as such should en)w the benefits given to
- y. j 3
- 9. a site alrandy developed.- In a case wherein the "obviously superior" standard was utilized the Court ruled "the likelihood that an alternate site will be selected as obviously
]
superior declines and the pressure against denying the '
application increases" New England Coalition v. U.S.N.R.C. 582 F2d 87 ( 1978)
Indeed the benefit given to the site already developed, in this case Ji's alternative, is clearly )
representative of the objectives sought by the Resource Conservation Recovery Act ( 1976). The ll Licensee's proposal is clearly a new proposal demanding the use of and investment in new equipment and the non-use of equipment already available. '
- 3. The Board MisrenraeantedJi's Alternative _
The Board stated that JI's alternative included storage for 30 years followed by evaporation (Final Initial Decision, Page 30). By doing this, the Board added on the costs of evaporation in 30 years. Nowhere did JI suggest that evaporation should be used at the end of a storage period of 30 years (See JI's description of alternative Tr 107, Tr 588, Tr 614).
Furthermore di explicitly stated that the 30 year period was a Li nsee assigned period, not JI.
It is incredible that the Board stated that JI had accepted this definition of a storage period in their response to Licensee's Motion for Summary Disposition. It is in that very document that di f states,
" Licensee assigned the period of 30 years, since JI did not specify an actual number. (Id P31831).
Furthermore, eventual disposal was put forth by NRC PElS Supp. 2,3.4.1.2, not Ji, and JI had used this interpretation in the context of explaining the NRC's definition of no-action (Tr 65). !
- 4. No-action Costs I ass Than Evannration_
The Board overinflated the cost of JI's alternative by tacking on evaporation costs and ,
the cost to retreat the water (Final Initial Decision P. 75-77) (a cost airend/ incurred by fulfillment of the NRC's 1981 Orders to make the water safe for storage and eventually disposal). The Board also underestimated the cost of evaporation by using the original estimate of $4.1 million (10 P. 75). This in spite of the fact that the cost of evaporation particularly in terms of dollars and occupational exposure should begin with the onset of use of the evaporator (Tr 787 Bloch). It was not until after the PEIS Supp. 2 was published that the Licensee announmd that it me/ use the evaporator to achieve base case levels, in lieu of Epicor/SDS (Tr 522, Buchonen). This cost must be included. Even the NRC admitted that Limnsee's proposal had changed (Tr 786 Munson). Aside from these errors the alternative offered by JI isless expensive (Tr 745).
- 5. The Board Erred in Aoolvina 10CFR 50 Ann I to this Prnrmiina.
This proceeding was concerned with an amendment being sought to remove a prohibition on disposal of radioactive water at TMl (Tr 3). It was not therefore enough to decide that if a disposal method was a@anced which complied with the design objectives of 10 CFR 50
e 4 V App. I, that the method was "itself obviously superior" (Final Initial Decisien P. 81). The alternative offered by JI also falls within the standards of 10 CFR 50 App. l. Indeed exposure to ionizing radiation only occurs at the time of an accident ( Affadevit of Dr. Piccioni and NRC Staff PEls Supp. 82 Table E.1 and Tr 1335). By using this approech, the question reised by the proceefngs remains to be answered - should the A0W be disposed or not. Application of 10 Cf R 50 App. I also denies the importance of the ALARA principle, to which the NRC committed itself in 1981 when it wrote that their main objective during clean-up was to keep exposures minimized (Nureg 0683, March 1981, Vol.1. Page 1- 17).. The applicability of ALARA was admitted by the parties (Memorandum and Order, August 25,1988, P.8) Its importance is heightened by the fact that TMI Unit 2 does not provide the associated benefit of electricity to j offset the risk associated with exposure to ionizing radiation. f urthermore it was agreed during the proceedings that tritium is the critical isotope (Tr 742 Munson). All the tritium is released into the air by the Licensee's proposal. Storing the water onsite contains the tritium and thus minimizes the risk to the public. Such a reduction in risk is in keeping with both NEPA and the Atomic Energy Act.
- 6. The Board Erred in failino to Discuss the Benefits of Ditnneino of the Water.
JI's Contention 2 , admitted by the Board January 5th 1988, P. 7 had stated that the ,
StefTs PElS failed to demonstrate clearly thet the adverse impacts of disposal by evaporation and vaporization are outweighed by the benefits of such disposal. When questioned about the benefits NRC's witness described benefits to the Licensee (Tr 793 Munson) and not the public. The Board erred in not addressing this important part of the cost / benefit equation of alternatives required by both ALARA and NEPA.
- 7. The Board Erred in tonorino the Information Set Forth bv JI's Fxcert Witnamaaa for example the Board dismissed Information supplied by JI's expert Louis Kosarekas irrelevant (Order on Summary Disposition August 25the 1988 P. 71). The Licensee ~s proposal assumed that he evaporator would achieve a demntamination factor (df) of 100. (Disposal of TMI 2 water July 1986). NRC Staff assumed a df of 1000 (PElS, Supp. *2 3.16) and accordingly made their dose assessments from this assumption. Kosarek suggested that the TMI 2 weter was not similar to that water used in evaporators studied by the NRC ( NRC provided documents to show their basis for assuming a of of 1000). The A0W contains detergents, notably Tritox X and thus it was incorrect to assume a df of 1000 without scientific basis. (See attached Kosarek affadvit). The information provided by Mr. Kosarek, after careful review of the NRC and OPUN documents, was rejected on the grounds that the A0W could be prne-t over and over to achieve the required quality. The Board neglected to reelize how this would offect cost, time j for proposal and the dose to the workers (Memorandum August 25,1988 P 42). Licensee !
recognized these factors (Tr 497,507, and 516-517). JI elerted the Board to this during the Hearings to provide the basis for assertions made in the PEIS (42VSCS 4332 n61). Subsequent
to the NRC adapting a'df of 1000, the Licensee then adapted same, but without providing any J.
beels (See GPUN Letter October 25,1988) or experimentation data.
The Board erred in striking much of Dr. Morgan's testimony (Tr 949-997). *3,
. Page 2 of Dr. Morgan's testimony was an attempt to show the wide variation in measurements of -
the radionuclides in the 25 location. This was particularly relevant to GPUN's reliance on a constant ration between Cs137 and the various radionuclides in setting their monitor to determine that the influent at the system isn't beyond appropriate levels or those levels noted in Table 2.2 PElS. (See Technical evaluation Report (P21)). 'dl explained that the testimony was .
relevant to Contention 3 but this wasn't accepted by the Board, who ruled that if it didn't apply to OPUN's ability to measure accurately, it was irrelevant (Tr 961).
The Board showed prejudice towards Dr. Morgen from the onset of his appearance. For example the Board denied Dr. Morgen the time to explain his position (Tr 1587) and constantly interrupted Dr, Morgen (e.g. Tr 1575,1578,1583,1584,1585,1580-1581).
The Board ignored the Ji's expert witnesses testimony when they wrote that JI "did not seriously challenge the estimates of the magnitude of
' release (Final Initial Decision).
(See testimony ofDr. Huver, Dr. Morgen and Dr. Piccioni which clearly state the adverse impact of evaporating and vaporizing radioactive substencesinto the atmosphere.)
The Board erred in dismissing Dr. Pimioni's testimony es irrelevant (See attached Piccioni affadevit).
The Board dismissed the impnrtana of the questions raised by Dr. Huver in his testimony. Dr. Huver's assertions about the toxicity of tritium cannot be easily dismissed because there is no data avellable on the effects of tritium exposure (Tr 1233 Fabrikant and Tr 1401).
THE PUBLIC WILL SUFFER IRREPARABLE DAMAGE The radioactive liquid weste to be vaporized into the air at TMI, Unit 2 contains over l 1000 curies of tritium, signiffmnt amounts of strontium 90, cesium 137, plutonium, antimony, and an arrey of alpha, gamma, and beta emitting radionuclides (PEIS Supp *2 Table 2.2). This 11guld waste is an ultra hazardous material, dispersal of which raises not only !
questions of technology, but also morel and ethical question, especially since other alternatives, whereby the radioactivity is contained are available. l There is no level of radiation exposure assumed to be safe (PEIS Supp *2 7.5.3. Page 7.24) and therefore zero risk cannot be assumed with the proposed release of ionizing radiation by evaporation and vaporization (See Affadevit of Dr. Piccioni). lonizing radiation causes cancer, genetic mutations, and other adverse health effects (Hazards of Low Levs1 Radiation by K.Z. Morgen, Encyclopedia Brittanica). Definitive answers mncerning damage from exposure to low levels of ionizing radiation are few because of the sparsity of date of human populations l _
6 exposed to low levels. Nonetheless damage does occur, and when germs cells or critical cells in the developing embryo are damaged, the damage is irreparable. See Affadevit from Dr. C. Huver.
The Board indicated in its decision that as long as an exposure to ionizing radiation fell within the NRC stonderds, it was acceptable (Final Initial Decision February 3,1989, Page i 60-81 ). This notion equated the NRC standards with a safe dose. However, in the famous Silkwood case the court recognized that injury muld occur below those standards and has. Indeed further mntrasts to the Boards decision an be found in a remnt statement by ICRP wi ich stated exposure below thct dose limit are only acmptable if they are as low as reasonable achieveable. -l Statement by ICRP on Radiological Protection Licensee Exhibition 4, Page 3.
This statement was prompted by recognition of the increased risks factor shown by recent analysis of the date of the Hiroshime-Negeseki victims.
The TMl population is unique in having suffered the impact of this nation's worst commercial nuclear accident. Chronically elevated levels of psychological stress exists among Middletown residents (Roone/ J & Prince Embury S. ( 1987)). A study released in August 1985 linked TMI related stress with immunity impelrments. Merjorie Amnodt showed a 6002 increase in concer in those areas directly affected by the radioactive plumes from the 1979 accident. Presently, over 2000 health suits have been filed against the designers and operators of TMI. The suite ellege health problems caused by the accident in 1979. Health effects on plant and enimal abnormalities are documented in the area. (See Attached from Mary Osborne). The matter of how much damage the accident has caused has by no means been resolved. It is this population which will suffer the impact of this additional dispersel of radioactivity by vaporization of radioactive liquid waste.
Irreparable legal damage will occur if the ste/ is not granted since the weste and its associated damage is irretrievable once dispersed and even if citizens were to continue to pursue their legal rights it would be meaningless to the protection of their health. JI's have shown that the NRC failed in its responsibilities under NEPA. The murts have stated that
" Irreparable damage is presumed when en agency fails to evaluate thoroughly the environmental impact of a proposed action" Furthermore the policies underlying NEPA, Weight the sceles in favor of those seeking the suspension of all action until the Act's (NEPA's) requirements are met ... .
Alpine Lakes Protection Society v. Schlaffer 518 F2d 1089,1090,(9th Circuit,1975)
WHERE THE PUBLIC INTEREST LIES The safety and health of the public deserves care and professionalism'in meking decisions on a metter such as is before us tode/. Disposing of 2.3 million gallons of radioactive water generated by this nation's worst commercial nuclear accident is clearly a precedent in this country. While evaporation is used throughout the nuclear industry to decontaminate and l
. 7 redum the volume of radioactive liquid warte, evaporation and vapori2etion of 2.3 million i
gallons of radioactive water generated by en accident involving partlei core melt (over 502), !
and used to cover melted fuel during clean-up has never been undertaken before et a nuclear l power plant. The proposal by GPUN has been before us sina July 1986. Numerous public j meetings held under the auspices of the NRC's Citizen's Advisory Panel for the Downtamination of Unit 2 brought out many citizens opposed to the proposel, and no public citizen appeared before the panel to speak in favor of the proposal. The panel voted against the GPUN's evaporation proposal in March 1987. At a special session held during the Hearings in Lancaster, the majority of citzens present voiced their opposition to the proposal.
The public interest has not been served by the NRC's and the Board's posture that the Hearings concerned the selection of a disposal method for the A0W and excluded the issue of whether or not diposal of the A0W is necessary (Tr 584 Bloch and Rr 580 Lines 11-16 1 Skolnick).
THE STAY WOULD NOT HARM OTHER PARTIES j A stay of the effectiveness of this decision is merely preserving JI's rights to en appeel, while maintaining the status quo et TMI, Unit 2.
Clean-up, which necessitates the use of the A0W, is ongoing. GPUN proposes to place .
Unit 11 In monitored storage following defueling and completion of certain tasks. The NRC has not yet given permission for this proposal. An ellernative to the Limnsee's proposal is that cleon-up promed for et least four more years. (PEls Supplement 83 ) The NRC Citizen's Advisory Panel for the Demntamination of Unit 2 has strongly opposed any efforts by GPUN to postpone the clean-up and implement their proposal known as PDMS. This panel voted 8-2 ;
against postponement of clean-up. (Citizens Advisory Panel Meeting, Sept. 20,1988, P 106.)
The future needs for the A0W are therefore undecided. An immediate effective decision to dispose j of the water by evaporation therefore precludes its use during future cleon-up, and overrides the NRC and OPUN's mmmitment to use the A0W for clean-up rather than generating additional liquids. (PE!S, Nureg 0683, March 1981)
The Licensee would not be hermed by the granting of a ster. Even if the Licensee was to argue economic loss emnomic loss is generally recoverable while inj unctive relief is eveilable only when legal remedies prove inadequate. Wisconsin Oss Co. v. F.E.R.C. 758 F2d 669,674 (D.C. Cire.1985). The Licensee had procured a vendor for the design of the disposal system in February 1988. They incurred the risk of investment prior to the outcome of these proceedings. A ste/ will in no wer prevent the Licensee from continuing to pursue this economic risk. As Judge Bloch stated in a correspondence December 19,1988, " Motion for Extension of l
Time" "There is no particular time pressure in this case . ...
l i
- _ - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - l
._ . _ , * ~ =-
- a EXHIBIT C AFFADAVIT OF LOUIS K0SAREK IN SUPPORT OF CONVENTIONS 3,4',AND '5-
-i n
1 i
.l l
l
(
- g" [ 50 ?- lhyf
. s Y
uJ .
l, e r. ...n_ ,~. . , _ e . . i-. . . . .o.. I .... -. r_. . . , , . r ce. es
. .. w .
........,,m.,
... r.. .m . n.. . -
- r
-. .~
PEFORE MC, THE UNDERSIGNED AUTHORITY, ON THIS DAY pee O* ALLY APPEARED LOUIS J. KOSAREK, KNOk: TO ME Tr' BE A CRC 0! ELE PEREOh' W'!O MA'.'ING BEE *1 UPON HIC O^.TH DEPOSES AND SAYC:
Tk!IS AcrIDAVIT W^S COMPILED ON PEHALF OF THE SUSOUAHo.*.!D VALLEY
- LLI ANC*I IN TF'E M^7TEP OF THE TREATMENT AND DISPOCAL O ACCI"*"N' t
,- . . :. 3 ,. r. n ..in - r - , . , . -ur .r,...
.,. . . , v r n. r e...i r*.n. ,- . . - - ----:
i-. -
r , . . e.
... p - - ,..e n ..., .r. e. - e e . . -,.
-.- r,. ,,r.,
- ,,., . . . n r r.-. . ...- s.. - -. , r,
.n.
- . ... - , c ._ - . ; , r. - , - -
-ve , -t.- ,s- e ,,..., , . c..- , ,,.r e..
. . , p - , r,. c. ., ,.. m.. , ,. -2 . rs - e .
! -- " . r. **'.c...- .,,.e-'--'r
- 3. r. .. . .- .s.s. - .n .,.3,--,.
. e c. . ,.. .. . c. . . e n . . - .
-r v- n - ,- ~.. , .u , . m ,. , m . e.--
r -e
.e_. . , r. e ,. r. . ., e. . ~.
e., ,..,.-.
. ._ ,, r.
m . ,,.
,- . . . . .e,...-... ..o.
s .n.
r : r. ,... ., . :. m. e
- c. - , ~ f - - - - - y . r- .-,..-e.e.--
c.r--;rpi 4.- . 7.r y g. c: cpr u n e , - , r -- - r - iw
..- . . . .. .. c. . . e , .,.-c.,,-.
. --.r...,....-.r. .
J- _..-
r..- a r. ."w.-.
es.tiv ...m ....,...
- v. u e., e ,3 ,.r.,,, ..
,.- ,,,.,.---,r..
.,.n.,
. 3 ,.. - , n_
. .n_.._-_,...,...
..a.. ,i e - - ~ - - - - - - , . . . + - ,- c , - _v - .- - - . . r. .-. .. s c aen.. r. .: . c . 2. r .-- r,. . r.- u.v. e. . . .
r n i. i e . . -. .' .n.' - + v...e- c. . r w. '.' i;. C
. RAr n., .
-.ie- rr. .,c-_ _ p.. n, .e . . . , . - , -
-- v.......n....,--
.. ...s..
a p r.. v. - m .
- r. .. c. i.s. e. . .- . rse o
, *% u-- c , ...a.r. v i. v. . v6s r.' e '.s .n . r'. r. ,. c. +a.. .. .- . ... ,u,e.
"U9THER DEPONENT SAITH NOT. .
1 e
_ _ _O.AA.M_ ._ _* __ . __________
,wo,w,. , r.a, , ,,-_.n.
. w. .
SUBSCRIBED AND SWORN TO BEFORE ME, THE UND ' IGNCD AUTHOFIT , ON
" 0 THIS THE J___ DAY OF _ ____ du__nf 198G EY__ h_ _ _ _ _<_e _ Q TO CERTIFY b'H I C H , WITN SS MY F'A*m AND EFAL OF EFICE.
0 st,___9___/_f_/__F_____ .
P f.'r- _ _
c.< .
. t ,9 ,.
m_ _ _ _' _. , . _ _
.4. . A-'(*...4.# ,.,.a.<4.,w
. r-L.
- ., u. . . . ., . .. -
^^^~
- OF '5 .
R'_ n E n UF Cih D I NA_ (s._T C , '.n . . . - _ vluc O5AL C, e r '., . + 1 . - e PCR DOvCNCNi WuRE J . . _. il; 2 al_.d; . :, EEPTEhLL . s .- i T.,
Di NUC_u. . REACTOR REGu_ATION OF THE NUCLEAR REDULAlu..'i LL'c C..o e u.
WERE FOUR DISPOSAL ALTERNATIVES WHICH THE NUCLEAR REGULATOR ( COi;i" R .n ON (NRC) CONSIDERED VI ABLE FOR TH2 DISPOSAL DF ACCIDENT GENEfinilD WAVER A7 UNIT 2 OF THE THREE MILE ISLAND F ACILITY OPERATED LY GENERA FUBLlu UTILITIES. THE FOUR ALTERNATIVES CONSIDERED BY THE NRC ON ? AGE 13 OF NUREG-0732 TO BE VIABLE BY THE NRC IN 1980 ARE:
"I) HOLDING THE PROCEEEED WATER IN TANKS AT TMI FOR APPROXIMATELY 60 YEARS,
- 2) RELEASING THE PROCESSED WATER TO THE RIVER AT TMI,
- 3) RELEASING THE PROCESSED WATER VAPOR TO THE AIR BY FORCED EVAPORATION AND,
- 4) RELEASING THE PROCESSED WATER VAPOR TO THE AIR BV NATURAL EVAPORATION".
REVIEW OF ORIGINAL ALTERNATIVES FOR DECONTAMINATION OF RADIOACTIVE WATER THE ACCIDENT GENERATED WATER CONTAINS RADIOACTIVE MATER 1A_S WHICh MUST BE REMOVED FROM YHE WATER TO MAINTAIN COMPLIANCE WITH 10 CFR PART 20, APPENDIX B (2) WHENEVER THE WATER IS DISCHARGED BY ANY OF THESE METHODS.
THE METHODS WHICH HAVE BEEN EVALUATED BY THE NUCLEAR REGw_ATOjY COMMISSION FOR DECONTAMINATING RADIOACTIVE WATER ARE LISTED IN NUREG-0732 (1). THE FIVE DECONTAMINATION ALTERNATIVES WHICH THE NUCLEAR REGULATORY COMMISSION HAD EVALUATED IN 1980 ON PAGE 10 OF NUREG-07 2 ARE AS FOLLOWS:
"A ZEOLITE AND RES1N SYSTEM, AN EVAPORATION AND REEin SYSTEM, DIRECT BITUMINIZATION, SOLIDIFICATION WITH PORTLAND CEMENT AND FILTRATION FOLLOWED BY STORAGE".
PAGE 2 OF 15
l-
- l l-V 1 m..a.. e .c p r;c u p w m OR_ .s :ma DIS:OssL c; . . . . . . _ . . . . - - -
- .ca u .. i WI1 r.IN DOCUMEr. ' 44 0s- uC -L-OU 12/ 03 ".br ' Wi . 4 i t Ls.a ir, L .v -
+ . . ,i + a d i. A OF GENERAL-PUBLIC UTIL* TIES. NUCLEAR DATED FEURuAdY 16, WSJ a, inE NRC DISROGAL METHOD CHOSEN DY GENERAL PUBLIC UTILITIES-TO Lid."USE OF THE ACCIDENT GENERATED WATER.IS NRC. ALTERNATIVE #3 AS OPECIFIED IN N.as.:__
g 0732 WHICH IS. RELEASING THE PROCESSED WATER VAPOR TO THE' AIR DY'FORCC5
]
EVAPORATION. PER DOCUMENT 4410-88-L-OO12/0335P WHICH WAG ISSUED BY F R STANDERFER OF GENERAL PUBLIC UTILITIES NUCLEAR DATED FEBRUARY 16 1988 (3), THE NRC RECOMMENDED DECONTAMINATION METHOD CHOSEN BY .
GENERAL PUBLIC UTILITIES TO TREAT THE RADIOACTIVE ACCIDENT GENRATED !
WATER PRIOR TO DISPOSAL IS SIMILAR TO THE NRC-ALTERNATIVE.ON PAGE 10 OF i JW4 EVAPORATOR AND RESIN SYSTEM.
IN DOCUMENT 4410-88-L-OO12/0335P WHICH WAS ISSUED BY F R STANDERFER OF j GENERAL PUBLIC UTILITIES NUCLEAR DATED FEBRUARY 16, 1988 '(3), THE.
DOCUMENT SPECIFIES ON PAGE 1 THAT AN EVAPORATION SYSTEM.IS PROPOSED.
TO BE USED TO ACCOMPLISH THE CONTROLLED DISPOSAL OF APPROXIMATELY 2.3 MILLION GALLONS CF " ACCIDENT GENERATED WATER". THE USE OF THE EVAPORATION SYSTEM FOR TREATING ACCIDENT GENERA 7ED WATER IS SUBJECT TC APPROVAL BY THE NRC PER NUREG-0683 AS SPECIFIED IN A POLICY STATEMENT
..; ii C: l 16 IN THE PROGRAMMATIC ENVIRONMENTAL IMPACT S'.HTEMENT OF 1981 (4;. -l THE EVAPORATION PROCESS IS DESCRIBED BY NRC ON PAGE 11 OF DOCUMENT NUREG 0732 (1) ISSLID IN SEPTEMBER.0F 1980 BY THE OFFICE OF NUCLEAk REACTOR REGULATION OF THE NUCLEAR REGULATORY COMMISSION. THE NRC DESCRIPTION OF EVAPORATION IN NUREG-0732 IS AS FOLLOWS:
-]
l "THE WATER WOULD BE REDUCED TO 1/30 OF ITS ORIGINAL VOLUME AND THE #
RADIOACTIVITY WOULD BE REDUCED TO 1/1000 ITS ORIGINAL CONCENTRATION (EXCEPT FOR TRITIUM)".
PAGE 3 OF'15
.:aCUlG A: itad iDN Fi.,C lOR ~ V Ci? a an;u , , . . .a r f 1 %'.> ni ..: . nr ' . i . r,
- . - - - - - - - - - - - - - - - - . . - . . - - - . . - - - - - - . . . .--..--l. - - .
iINCE A LLCONT AMINAT ION FAr. /Oci (L.; IG A l as.LD 06 t rQa C . a s. u_ .u t .
-0142 (5) AS THE. RATIO OF THE CONLCNTRm 4ON u? A GIVEN COMB Di.:.;4 I I a . i .1d FEED AT ANY TIME TO THE CONCENirbil .' OUR THE CAME COMPONENT ., THE iREATED WA1ER Al'THE SAME. TIM 2., 1HE 1/1000 REDUCTION SPECIidia . IN NURCG 0732 (1) IN 1980 IS' EQUAL TO A DECONTAMINATION FACTOR (Df) OF 1000.
IN DOCUMENT 4410-88-L-OO12/0335P WHICH WA5 ISSUED BY F R 01ANDERFEC OF GENERAL PUBLIC UTILITIES NUCLEAR DATED FEBRUARY 16, 1988 (3), THE DOCUMENT SPECIFIES ON PAGE 18 THAT THE DECONTAMINATION FACTOR FOR
. RADIOACTIVE PARTICULATE OF THE PROPOSED EVAPORATION SYSTEM IS 1000 (LEE TADLE 1). THIS DECONTAMINATION FACTOR C'F 1000 IS DEMONSTRATED UTILIZING .
THE DATA LISTED IN TABLE 3-2 (P 18) WHEN YOU COMPARE THE RATA 0 OF THE CONCENTRATION OF RADIOACTIVE PARTICULATE OF A GIVEN COMPONENT IN THE INFLUENT TO THE CONCENTRATION FOR THE SAME COMPONENT IN THE E FLUENT, THIS RATIO WHICH IS THE DECONTAMINATION FAL C..tCUALS 1000 IN ALL CASES.
OF RADIOACTIVE PARTICULATE. THE DECONTAMINATION FACTORS FOR TME VOALTILE GASSES TRITIUM AND IODINE-129 ARE 1.
l THE EVAPORATION PHOCEbS HS DtiSCRIBED BY NKU UN F' AGE 11 O t- DCJUMENI NUREG-0732 (1) ISSUED IN SEP1 EMBER OF 1980 BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE NUCLEAR REGULATORY COMMISSION HAS A DECONTAMINATION FACTOR OF 1000. THE PROPOSED EVAPORATION PROLE 8S DESCRIBED IN DOCUMENT 4410-88-L-OO12/0335P WHICH WAS ISSUED BY FR STANDERFER OF GPUN DATED FEBRUARY 16, 1988 (3), INCORPORATES A DECONTAMINATION FACTOR OF 1000. THE DECONTAh1 NATION FACTOR OF 1000 FOR AN EVAPORATOR IS FURTHER UTILIZED IN THE GPUN RESPONSE ON PAGE 22 TO INTERROGATORIES DATED FEBRUARY 19, 1988(6) IN ANSWER 528. THE S28 ANSWER SIATCb iHAT: ,
PAGE 4 OF 15
-. = ._ - --
- . # N
, - y '
%Ac '1' . . ; uN. AMINhiluN FAG iO;< UA. LULWi s w . i i i: 6 U. , _F .O .s.
.- . o m . da 1NF;UENT E.H Lv ;.s l h i u ci d ,' h: -. v _: 4 CONS flTUE.NT ' CONCE;;TRAT I ON . CONCENTRASIGN' DEUUNTMihATION -
uCi/ml uCi/ml .FACfOn TRITIUM O.130000000000- O.130000000000 1-CESIUM-137 0.000037000000 0.000000037000: l1000 CESIUM-134 O.000000880000: O. OOOOOOOOOE,80 '1000-STRONTIUM-90 0.000110000000 0.000000110000. 1000 ANTIMONY-125/
.. TELLURIUM-125m O.000002300000 .O.0000000C2300 1000
' CARBON-14 -0.000100000000 O.0000001C.4000 1000..
. TECHNETIUM-99 0.000001000000 0.000000002000 1000 IRON-55 0.000000480000 0.000000000480 1000 COBALT 'O.000000480000 O.000000000480 1000
' IODINE-129 0.000000600000 0.000000600000 1-
- CERIUM-144 0.000001800000 0.000000001800 1000 MANGANESE-54 0.000000040000- O.000000000040 1000 C. COBALT-58 O.000000040000 0.000000000040 1000-N I CKEL--63 0.000000600000 0.000000000600 1000 2INC-65 O.000000098000 0.000000000098 1000 RUTHENIUM-106/
RHODIUM-106 0.000000330000 O.0000000 450 1000
' SILVER-110m 0.000000056000 0.000000000056 1000 PROMETHIUM-147 0.000004800000 0.000000004800 1000:
EUROPIUM-152 0.000000000380 0.000000000000 1000
' EUROPIUM-154 O.000000044000 0.000000000044 1000 EUROP1UM-155 0.000000110000 0.000000000110 1000; URANIUM-234 0.000000010000 C.000000000010- 1000 URAN 1UM-235 0.000000012000 0.000000000012 1000 URANIUM-238 0.000000012000 O.000000000012 1000-PLUTUNIUh-238 0.000000012000 0.000000000012 1000 PLUTONIUM-239 0.000000014000 O.000000000014 1000 PLU7/NIUM-240 C.000000014000 O.000000000014 1000 PLUTON 1U: he, , O.000000650000 0.000000000650 1000 AMERICIUM-241 0.000000012000 0.000000000012 1000 CURIUM-242 'O.000000100000 0.000000000100 3 1000
. TOTAL PER REPORT O.130261494300 C.000000260894 ACTUAL O.130261494380 0.1300008609 1' PAGE 5 OF 15
" ,n . -i. G _ G,4.sa / Uv ; 6 ,,.; I I U N r Ur - .n.o .; ,; s c .. ..
T O as O . . ;. 2/1000).'
THE CARRY OVER OF 1 EFFLUENT TU AN I t#L.UENT UP l ta 0 2 v0 A.. d H DECONTAMINATION FACTOR OF 1000. FURlHER, THE S28 A WWLR IN 'lHE IN1ERROGATORIES DATED FEBRUARY 19, 1988 SPECIFIES Tlihi:
"T hi , 4't.Mtu FRACTION ( 0 . 1 7.) IS BASED UPON ROUT 1NE PERFORMANCE EX'PERIENCE WITH TYPICAL EVAPORATOR SYSTEMS, AND IS ALSU UTILIZED bY iHE NRC STAFF IN PEIS, SUPPLIMENT No.2(7)FOR RELEASE CALCULATIONS".
HENCE, A DECONTAMINATION FACTOR OF 1000 WAS USED FOR EVAPORATION BY THE NRC STAFF IN PEIS, SUPPLIMENT No.2 (7) FOR RELEASE CALCULATIONS. THE DECONTAMINATION FACTOR OF 1000 FOR AN EVAPORATOR IS FURTHER UTILIZED IN THE NRC RESPONSE TO INTERROGATORIES PAGE 20 DATED FEBRUARY 22, 1988 (8)
ANSWER TO INTERROGATORY 22. THE SECTION B ANSWER TO INTERROGATORY 22 STATES THAT:
"NUREG-OO17 REV.1 (MARCH 1985) PROVIDE (D) NRC STAFF RESULTS OF DECONTAMINATION FACTORS MEASURED AT SEVERAL NUCLEAR POWER PLANTb AND BASED ON A GENERIC REVIEW OF NUCLEAR INDUSTRY DATA. NUREG-OU1/ LlSTS A DECONTAMINATION FACTOR OF 1000 (i . e. O.1%) AS IHE BESf REFir. ..w. 3.,
ESTIMATION EVAPORATOR OPERATING PERFORMANCE".
THE DECONTAMINATION FACTOR OF 1000 FOR AN EVAPORATOR HAS BEEN USED BY NRC AND GPUN SINCE 1980.
A REVIEW OF NUREG-OO17 (9) AS CITED BY NRC STAFF IN THE RESPOrjsE TO INTERROGATORIES DATED FEBRUARY 22, 1988 (8) IN ANSWER TO INTERROGATOR 22, NUREG-OO17 STATES THE FOLLOWING ON RAGE 2-42.
PAGE 6 OF 15 l
l i
b__ _ __ _ _ _ _ __ )
-q 1
l l
- . \
_.2.21._ 64Scb l
THE U.:La TN..NA>aUN FAC10.W F un EV,w _,% . J.sG h:4. c. e *4 _L _. . . .
l F I N D ll & S U r: A UE4 nic REVIEW c CRNL w ,-e , mat i . n '. i s " . e , L t- : l OF EVAPOrr.tURo Ubic 1N THE NULLEAR i NL J c i . C. ( rh . J. , vin._ v< . i_ l PRINCIPst CONCLUSIONS RECHED IN THE REPOni ARE: 4 l
- 1. DECONTAMINATlLN FAUTOkd .m 10000 CHN Dt:. EXPECTED FOR NOlwVULA1;__.
RADIOACTIVE NJCLIDES IN A SINGLE S1EP EVAFORATOR.
- 2. DECONTAMINATION FACTORS FOR IODIDE ARE A FACTOR OF 10 LEsb HAN ;.:L J
Df FOR NONVOLATILE NUCLIDES. )
l
- 3. DECONTAMINATION FACTORS FOR WASTES CONTAIN1NG DE1ERGENTS Thni YEND TO FOAM ARE A FACTOR OF 10 TO 100 LOWER THAN Df 's EXPEC FED FOR NOE. FOAMING WASTES.
THESE CONCLUSIONS HAVE BEEN EXTENDED TO TAKE INTO ACCOUNT THE FOLLOWING FACTORS: l
- 1. FOR NONVOLATILE NUCLIDES IN THE NONFOAMING SOLUTION, A Di Cr 10000 AS USED.
- 2. THIS VALUE IS REDUCED TO 1000 FOR BORIC ACID WASTES BECAUSC THE TENDENCY FOR FOAMING IN THESE SOLU 110NS WEE 5 AD VC).
- 3. IF AN EVAPORATOR IS USED FOR DETERGENT WASTES, THE Df FOR TnE EVAPORATOR 15 REDUCED T O 100 ' TO REFLECT CARRYOVER DUE TO FOAM 1hG THAT REDUCES THE Df."
r PER THE ANSWER BY THE NRC STAFF IN THE RESPONSE TO INTERROGA70h.EU UF FEBRUARY 22, 1968 (S) IN ANSWER 10 INTERROGATORY 22 'thE NRC STe/F siATES
, THAT NUREG-OO17 PROVIDED NRC STAFF WITH A DECONTAMINaf1ON FAClua OF 1000 AND NUREG-OO17 SPECIFIES A DECONTAMINATION FACTOR OF 1000 IN ;rd BASE:
"2. THIS VALUE IS REDUCED TO 1000 FOR BORIC ACID WASTES BECAUSE THE
- TENDENCY FOR FOAMING IN THESE SOLUTIONS."
THEREFORE,THE ACCIDENT GENERATED WATER IS CONSIDERED A BORIC ACID WAGTE.
PAGE 7 OF lb I
l
\
i-U
-L
- .+_,ACCic a4i U d m?w IL.< Le N -L.LNb f uc.R. e - o WH i s_, s hnu ....n
.DiUUN TAM ' rsM IGN FsC i vi:. Ui; iv00 FU!i C.,i d iION-UF :.v ne t'h . . Uc Omi u40
- PERFORMANCE AS A 80RiL ACID Wsdid IN:
'NUREG-0732, 1980 (1) rdJREG-0683, 1981 (4) teUREG-0683 SUPPLIMENT No.2, 1987(7)
DOCUMENT 4410-88-L-OO12/33SP, 1988-(3)
INTERROGATORIES RESPONSE BY GPUN, 2/19/88 (6)
INTERROGATORIES RESPONSE BY NRC-STAFF, 2/22/88 (8)
APPLICATION.0F GENERIC EVAPORATION DATA TO PARTICULAR'TMI-2 CHEMISTRY SINCE THE EVAPORATOR OPERATING PERFORMANCE IN NUREG-OO17 IS DASED ON GENERIC DATA, TMI-2 WATER CHEMISTRY IS A SIGNIFICANT PARAMETER IN EVALUATING THE ACHlL H:;LE DECONTAMINATION FACTOR. PER THE GPUN HESPONSE-ON PAGE 31 TO INTERROGATORIES DATED FEBRUARY 19, 1986 (6) IN AubWER S43 IT IS STATED THAT:
" WATER ' WITH THIS F ARTICULAR CHEMIS1RY IS UNIQUE TO TMI-2. NO TWO BODIES OF WATER HAVE EXACTLY THE SAME CHEMISTRY".
IN APPLY 1NC THE GENERIC DATA OF NUREG-OO17,' THE DECONTAn1 NATION FACTOR OF AN EVAPURA1DR WILL BE EVALUATED FROM THE PERSPECTIVE OF WHAT THE INFLUENT WATER CONTAINS BE IT: NONVOLATILE NUCL1 DES IN A NONFOAMINU SOLUTION, IODINE, DETERGENT WASTES, OR BORIC ACID WASTES .
1 THE UNIQUNESS OF THE ACCIDENT GENERATED WATER AT TMI-2 15 FURTHER CONFIRMED IN THE CHEMICAL FORMULATIONS AND VARIOUS PROCESS CHEMICALS WHICH WERE ADDED SUBSEQUENT TO THE NUREG'-0732 4NALYSIS BY NRC IN 1980.
ON PAGES 36 AND 37 UF INTERROGATORIES DATED FEBRUARY IV, ,. , c 0 ( c ) IN GFUN ANSWER No. S52, CHEMICALS USED IN 1986 DURING THE CLEANUP INCLUDE:
COAGULANTS SUCH AS 38.6 GAL OF BETZ 1182, 0.75 Gi4L OF BETZ 1192 AND 2.4 GAL OF CALGON 289, DIATOMACEOUS EARTH SUCH AS 880 POUNDS OF STANDARD SUPER CEL PLUS 20 POUNDS OF CELITE 503, AND ADDITIONS OF 350 GALLONS TRITON-X-100 TO THE AGW INVENTORY u PAGt 8 OF 15
h iCca5114.UN 11-id ' W'Wi Eh. ' I Hc.i, i PMs ~ ;. s 4 .e ..c.t. .t : .. r.- -
PER5 CJiiVE YO NU.9EG-0017 (9), Thi. L -, .L i _T< 13 i ; LS U.- i i i_. . . .. . . .% vi _ uile_ :
~TO THE ACCIDENT GENERATED WATER IN THL uadATEST VOLUMd GnALD BE
- UNDERSTOOD TO SPECIFY-THE' CORRECT NUREG-OO17 EVAPORATOR IVCON1 MINAT10N FACTOR.- Gi..aum 6 Ur INTERROGATORIES DATED' MARCH 30, 1%3 (10L. IN-GPUN ANSWER No. 6, THE ADDITIVE TRITON-X-100 IS DESCRIBED AS FOLLOWS:
" TRITON-X'-100 IS A NONIONIC~ SURFACTANT WITH THE CHEMICAL NAME ISOOCTYLPHENOXYPOLY THOXYETHANOL ETHYLENE OXIDE. IT IS USED AS A A'DEGREASER AND A DECONTAMINATION AGENT FOR FLOORS, WALLS, PIPING AND MECHANICAL EQUIPMENT".
'.THE NONIONIC SURFACTANT. TRITON-X-100 IS MANUFACTURED BY THE ROHM & HAAS.
COMPANY' LOCATED AT INDEPENDENCE MALL WEST IN PHILADELPHIA, PENNSYLVANIA (11) WI7H THE PHONE NUMBER OF 2155923000. WITHIN THE ' ROriM AND HAAS SPECIALTY CHEMICALS DETERGENT FORMULATION MANUAL'(12), ON PAGE 126,.A A.NONIONIC: SURFACTANT IS DESCRIBCD AS:
" SURFACTANT'THAT-CONTAINS NEITHER POSITIVELY NOR NEGATIVELY CHARGCD (IONIC) FUNCTIONAL GROUPS AND LCEL N_.~. ION 14E IN SOLUTION. SUCH
- SURFACTANTS (eg ALKYLPHENOL ETHOXYLATES) HAVE BEEN FOUND iO BE PARTICULARLY EFFECTIVE IN REMOVING OILY SDit."
THE NALCO HANDBOOK (13), A PROFESSIONAL REFERENCE IN T HE MTER TREA'IMENT INDUSTRY DEFINES A SURFACTANT ON PAGE 6-8 AS A SURFACE ACTIVE AGENT; e
"USUALLY AN. ORGANIC COMPOUND WHOSE MOLECULES CONTAIN A HYDROHPYLIC GROUP AT ONE END AND A LIPOPHILIC GROUP AT THE OTHER."
PAGE 9 OF 15
Wi~niN T; C 'RaHM Ai:D hA4a SPECi4LYY DILMiCF L L. u/ - .
- R . C I 'f; M A.,,;4L 'C,,
. L; F AL 124, A LEGREASCR IS ULa J- -- = .16 "A SPECIALTY PRODUCT THAT REMOVES GREASE AND GREASY / OIL: E,UILS r N 3;*i HARD SURFACES. fHEIR BASIC INGREDIENTS ARE SURFACTANTS THAT kENETRATE AND I
EMULSIFY. lhEY hr$ 2 ALSO CON 161N ALCOHOL OR A GLYCOL den.VATiVE TO BOOL:
CLEANING AND AID SDLVENCY."
THE MATERIAL SAFETY DATA SHEET (MSDS) ISSUED BY ROHM A. HMAS ON iHIYON
-X-100 (14) SPECIFIES THE COMMON NAME OF TRITON-X-100 AE CCTYLPHENO).Y-POLYETHOXYETHANDL NONIONIC SURFACTANT. THE BOILING POINT OF TRITON-X 100 IS SPECIFIED IN THE MSDS TO BE 520 F. WITH A BOILING POINT OF 500 F, WHENEVER TRITON-X-100 ENTERS THE EVAPORATOR, IT WILL NOT BOIL BUT WILL CONCENTRATE IN THE EVAPORATOR AND ULTIMATELY BE CONTAINEO IN THE EVAPORATOR BOTTOMS TO BE SOLIDIFIED. THE TRITON-X-100 tMECIFICATION SHEET ISSUED BY ROHM AND HAAS (11) DESIGNATES THAT:
" TRITON-X-100 SURFACTANT IMPROVES THE DETERGENCY AND WET ~ RING PROPERTIES OF LAUNDRY, METAL CLEANING AND SPECIALTY FORMULAIIONL FL i ra '.- i4r4D INDUSTRY."
~
THE TRITON-X-100 SPECIFICATION SHEET (11) STATES THAT TRITON-X-100 IS A
" HIGHLY EFFECTIVE HARD-SURFACE DETERGENT."
PAGE 10 OF 15
+
s i
I
_ _ _ . _ _ . _ _ _ _ )
- CMEMICAL MDDI"T"^TIO" 9F AEW AT TM I-? '? DC DE-~ OGF"' t '""~ ~ ^ < " " ~~0f
' ' ' ~ ~ ' ' ~ ~ ' * "
Tl!E NRC (C' '-!AD DPC"I~IED TH^T THCY RELY CN NUF:55-M * '
REVIEW OF NUCLEAR INDUETRY Dr.TA FOR ESTIMATING EVAPORA*CR '-~5ATI'5 PERFORMANCE. PER THE MANUFACTURER, TRITON-X-100 IS A DETE:.2ENT (11'.
GPUN HAS STATED THAT TRITON-X-100 IS CONTAINED IN THE ACCIr:NT CC NE"9,* E D WeTCP (6). NUREG-0017 STATES THAT:
"3. IF AN EVAPORATOR IS USED FOR DETERGENT WA3 TEE, THC Df FOR THE EVAPORATOR IS REDUCED TO 100 TO REFLECT CARRYOVER DUE TO FOAMING THAT REDUCES THE Df." (9)
BASED ON THE ADDITION OF THE DETERGENT TRITON-X-100 BEFORE 1986 TO THE AGW, CITING NUREG-OO17, THE ACCIDENT GENERATED WATER SHOULD BE CLASSIFIED AS DETERGENT WACTE AND THUS THE EVAPORATOR DECON' AMINATION FACTOR USED FOR THE ACCIDENT GENERATED WATER AT TMI-2 IN 1CE? SHOULD BE 100 NOT 1000.
THE KNOWLEDGE THAT CHEMICALS SUCH AS DETERGENTS WILL AFFECT THC i
OPERATING EFFICIENCY OF AN EVAPORATOR HAS BEEN DEMONSTRATE BY GPUN.
IN THE AFFIDAVIT OF DAVID R. BUCHANAN, MANAGER / RECOVERY EN"-INE'ER!NG FOR CPUN (15) IN CTATEMENT 11, MR. BUCHANAN STATES THE FOLLOWI' 2:
"F'APORATCRC HAVE BEEN USED EXTENSIVELY AND FOR MANY YEARE. AND THE FACTORS THAT AFFECT THEIR EFFICIENCY ARE WELL KNOWN....THE *RESENCE OF " DETERGENTS" WHICH CAN REDUCE HEAT TRANSFER RATES AND Pc2 DUCE VAPOR WITH A HIGHER MOISTURE CONTENT." 6 IN THIS CASE " HIGHER MOISTURE CONTENT" REFERS TO A HIGHER LEVEL OF 9
CONTAMINATION IN THE VAPOR.
THE IRONY OF ADDING THE DETERGENT TRITON-X-100 IN 1985 IN PERSPECTIVE TO THE OPERATION OF AN EVAPORATOR WITH AN EFFICIENT DECONTAMINATION FACTOR IS THAT WHEN TRITON-X-100 WAS ADDED TO THE A G W THERE WAS NOT ANY CONSIDERATION FOR THE AFFECT ON EVAPORATOR EFFICIENCY EUT THE PAGE 11 OF 15
3 CONSIDERATION-FOCUSSED ON THE AbiERSE AFFECT OF TRITON-k . v :
SDS AND-EPICOR II SYSTEMS. THE USE OF THE LETERSENT TRITON-e . w GPUN AND ITS ADVERSE AFFECT IN PERSPECTIVE TO THE SD5 AND EPICC: C : d TE'15 IS STATED IN STATEMENT 16 IN THE AFFIDAVIT OF KERRY L HARNER ( :):
" TRITON-X-100....CAN ADVERSELY AFFECT THE SDS AND EPICOR II SYSTEMS...
AND HAS NOT BEEN USED SINCE 1985."
THERE IS NO CONSIDERATION FOR THE UNDESIRABLE USE OF A DETERGENT IN AN EVAPORATOR APPLICATION.
THE USE OF NUREG-OO17 DATA IN 1980 WHICH WAS APPLIED TO THE A2W FRIOR TO CHEMICAL ADDITIONS IN 1985 TO GENERATE A DECONTAMINATION FACTOR FOR AN EVAPORATOR OF 1000 IS UNFOUNDED ESPECIALLY WHEN THE FACTORS FOR A DECONTAMINATION FACTOR ARE: NONVOLATILE RADIOACTIVE NUCLIDES. IODIDE, BORIC ACID AND DETERGENTS. THE CHOICE OF THE DECONTAMINATION FACTOR OF 1000 FOR AN EVAPORATOR IS A CHOICE FOR GPUN BECAUSE PER THE ANSWERE TO INTERROGATORIES DATED MARCH 30, 1988 (10) IN GPUN ANSWER No.02(1st)
"THE CARRY OVER O.1*/. IS BASED ON ROUTINE PERFORMANCE EXPERIENCE.....AND NOT UPON TESTE OR RESEARCH."
THE CHOICE OF A DECONTAMINATION FACTOR OF 1000 IS ONLY A CHOSEN VALUE WITHOUT TESTING OR RESEARCH. NUREG/CR 1992 (17) SPECIFIES THAT THE k
DECONTAMINATION FACTORS ACHIEVED IN EVAPORATORS FOR RADIOACTIVE PARTICULATE CAN VARY WITH THE SAME INFLUENT SOLUTION BY A FACTOR OF 72 FROM 1667 TO 23 OVER TIME. THE CRITICAL PARAMETERS INCLUDE: FEED RATE.
RADIONUCLIDES CONCENTRATION IN THE BOTTOMS, MOISTURE CARRYOVER (FOAMING, ENTRAINMENT, SPLASHOVER). THE PARAMETERS WHICH CAUSE VARIATION OF THE DECONTAMINATION FACTOR FOR AN EVAPORATOR HAVE NOT BEEN ADDRESSED IN WRITING BY GPUN INCLUSIVE OF THE PROPOSAL OF 1986 (18). THERE IS NO )
i DEMONSTRATED BASIS TO OPERATE AN EVAPORATOR WITH A Df OF 1000.
PAGE 12 OF 15 l I
- - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ A
SUMMARY
.THIS AFFIDAVIT SPECIES THAT-IN THE INTERIM OF 1980 AND 1981. A PENERIC REVIEW OF EVAPORATOR DESIGN CRITERIA SPELIFIED A DECONTAMINATION FACTOR OF 1000. THIS DECONTAMINATION FACTOR OF 1000 WAS CITED IN A VARIETY OF DOCUMENTS INCLUDING: NUREG-0732 (1),NUREG-06S3/PEIS OF 1991 AND 1957 AND GPUN STATEMENTS (3.6) AND NRC STATEMENTS (8). SUBSEOUENT TO.THE ORIGINAL CITATION, A DTERGENT WAS ADDED TO THE ACCIDENT GENERATED WATER AND MODIFIED THE GENERIC CRITERIA UNDER WHICH THE ORIGINAL DECONTAMIN-ATION FACTOR WAS DERIVED. THE ACCIDENT GENERATED WATER SHOULD BE CONSIDERED AS A DETERGENT WASTE AFTER 19S5. THE DISPOSAL ALTERNATIVES AND THE PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT MADE BEFORE 1954 ARE NO LONGER VALID AND ALL CALCULATIONS REQUIRE REEVALUATION. THE REEVALUATION IS IN PERSPECTIVE TO THE QUANTITY OF RADIONUCLIDES RELEASED AND THE ASSOCIATED PROCE!- MODIFICATIONS SUCH AS BOTTOMS CONCENTRATION.
THIS AFFIDAVIT DEMONSTRATES WHAT CAN OCCUR WHEN A GENERIC DATA BASE IS UTILI2ED AS A DESIGN BASIS AND THE WATER QLIALITY IS CONSIDERED TO ,
BC A CONSTANT AND FURTHER SCRUTINY OF THE WATER IS NOT CONDUCTED TO UPDATE THE DESIGN BASIS. THE USE OF THIS GENERIC DATA BAEE SHOULD BE CONFIRMED IN TESTS OR RESEARCH TO DETERMINE THAT THE UNIQUE WATER CAN BE PROCESSED AS THEORIZED. &
PAGE 13 OF 15
4
.' I:EFEFEMCEE 11 NUREG-0730. 1980. ANCWERS TO FF:EO'JENTLY ASKED CUEST'!ONP ^ ~ ' . '
CLEANUP ACTIVITIES AT THREE MILE ISLAND, UNIT 2. I"SUCD P T!'E 27 'T OF NUCLEAR REACTOR REGULATION OF THE L' S NUCLEAR REGULATODY C C '~ :"?
- 2) CODE OF FEDERAL REGULATIONS. 1978. TITLE 10, PART 20, APPE CI X D.
- 3) DOCUMENT 4410-88-L-OO12/0335P. 1988. ACCIDENT GENERATED WATER DISPOSAL SYSTEM DESCRIPTION BY F R STANDERFER OF GPUN DATED FEFr".!ARY 16, 1988.
- 4) NUREG-0683. 1981. FINAL PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT ISSUED BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE U S NUCLEAR REGULATORY COMMISSION. ALSO SEE U S NUCLEAR REGULATORY COMMISE!CN POLICY STATEMENT 46 FEDERAL P"GISTER 24, 764.
- 5) NUREG/CR-0142. 1978. THE USE OF EVAPORATION TO TREAT. RADIOACTIVE LIQUIDS IN LIGHT-WATER-COOLED NUCLEAR REACTOR POWER PLANTS. CO-AUTHORED BY HW GOODBEE AND.AH KIBBEY OF DAK RIDGE NATIONAL LABOCATORY FOR THE OFFICE OF NUCLEAR REGULATORY RESEARCH OF THE U S NUCLEAR REGULATORY COMMISSION.
- 6) INTERROGATORIES RESPONSE BY GPUN. 1988. LICENCEE'S ANSWERS ~O SVA/
TMIA'S INTERROGATORIES TC GPU NUCLEAR CORPORATION BY F R STANDEFFER OF GENERAL FUBLIC UTILITIES NUCLEAR DATED FEBRUARY 19, 1988.
- 7) NUREG-0683, SUPPLIMENT No. 2. 1987. PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT, FINAL SUPPLIMENT DEALING WITH DISPOSAL OF ACCIDENT GENERATED WATER BY THE TMI CLEANUP PROJECT DIRECTORATE OF THE U S RESULATP"Y COMMISSION.
- 8) INTERROGATORIES RESPONSE BY NRC STAFF. 1988. NRC STAFF REEoONSE TO INTERROGATORIES FROM TMIA/SVA BY C P WOODGEAD, COUNSEL FOR M*C STAFF DATE FEBRUARY 22, 1988.
- 9) NUREG-OO17. 1985. CALCULATION OF RELEASES OF RADIOACTIVE MA~ERIALS IN GASEOUS AND LIQUID EFFLUENTS FROM PRESSURIZED WATER REACTORE.
ISSUED BY THE OFFICE OF STANDARDS DEVLOPMENT OF THE U S NUCLEAR REGULATORY COMMISSION.
10)' INTERROGATORIES RESPONSE BY GPUN. 1988. LICENCEE 'S ANSWERS ?O SVA/
TMIA'S SECOND SET OF INTERROGATORIES TO GPU NUCLEAR CORPORATION BY FR STANDERFER OF GENERAL PUBLIC UTILITIES NUCLEAR DATED MARCH 30, 1988.
I I
- 11) ROHM ^ND HAAS CO. 1986. TRITON-X-100 NONIONIC SURFACTANT DOCUMENT CS-427a. PHILADELPHIA, PA.
l
- 12) ROHM AND HAAS CD. 1986. SPECIALTY CHEMICALS DETERGENT FORMULATION i MANUAL CS-480a. PHILADELPHIA, PA.
l l 13) NALCD CHEMICAL CO. 1979. THE NALCO WATER HANDBOOK EDITED PY F N
! KEMMER AND PUBLISHED BY McGRAW HILL BOOK CO., NEW YORK, NY.
- 14) TRITON-X-100 MATERIAL SAFETY DATA SHEET. 1987. DATA PROVIDED BY ROHM AND HAAS Co., PHILADELPHIA, PA.
PAGE 14 OF 15 l
l l
p ,, ;,
]
l
.o l
- 15) AFFIDAVIT OF DAVID R. BUCHANAN. 1988. CONTENTIONS 4b IN PART AND 6 DN CHEMICALS DATED MAY 13, 1988.
- 16) AFFIDAVIT OF KERRY L. HARNER. 1988. CONTENTIONS 4b IN PART AND 6 ON CHEMICALS DATED MAY 13, 1988.
- 17) NUREG/CR1992. 1981. IN PLANT SOURCE MEASUREMENTS AT FOUR PWRs.
CO-AUTHORED BY JW MANDLER et al. AND ISSUED BY THE OFFICE OF NUCLEAR REGULATORY RESEARCH OF THE NUCLEAR REGULATORY COMMISSION.
- 18) GPUN PROPOSAL. 1986. PROPOSAL OF GENERAL PUBLIC UTILITIES NUCLEAR TO DISPOSE OF ACCIDENT GENERATED WATER.
PAGE 15 OF 15
_ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . _