ML20248J030

NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc

ML20248J030
Person / Time
Site:	Crane
Issue date:	09/29/1989
From:	Lewis S, Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#489-9247 87-554-OLA, LBP-89-07, LBP-89-7, OLA, NUDOCS 8910130009
Download: ML20248J030 (26)

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N r UNITED STATES OF AMERICA

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NUCLEAR REGULATORY C0i4 MISSION

'89 OCT -2 P4 :25 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD~c In the Matter of GENERAL PUBLIC UTILITIES Docket No. 50-320 OLA NUCLEAR CORPORATION, ET AL.

ASLBP No. 87-554-OLA

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l NRC STAFF RESPONSE TO APPEAL BOARD ORDER l

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Colleen P. Woodhead Counsel for NRC Staff Stephen H. Lewis Counsel for NRC Staff

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of GENERAL PUBLIC UTILITIES Docket No. 50-320 OLA NUCLEAR CORPORATION, ~ET AL.

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ASLBP No. 87-554-OLA

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(DisposalofAccident-Three Mile Island Nuclear

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NRC STAFF RESPONSE TO APPEAL BOARD ORDER I.

INTRODUCTION On September 13, 1989, the Atomic Safety and Licensing Appeal Board (Appeal Board) issued an Order to the NRC staff (Staff) asking several questions dealing with a recent Federal Register Notice of a Staff'c Environmental Assessment (EA) dealing with the disposal of accident generated water at Three Mile Island Station, Unit 2.

Specifically, the EA addressed (a) retreatment of the accident generated water (AGV) by use of the evaporator and (b) the pelletization and shipment in that form of the evaporator bottoms. Among other questions, the Appeal Board inquired whether the EA concerned new matters not raised during litigation before the Atomic Safety and Licensing Board (the Esard) or during appellate procedures before the Appeal Board. Before addressing the specific questions asked by the Appeal Board, the Staff would note that both matters addressed in the EA involve subjects that were known by the parties during the proceeding and appear in the hearing record, and are reflected in the Licensing Board's Final Initial Decision. LBP-89-7, 29 NRC138(1989). The Staff's response to the Appsal Board's specific questions is set out below.

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D I.

II. DISCUSSION The Appeal' Board's Order refers'to a September 11, 1989 Federal Register Notice (54 Fed. Reg. 37517-18) entitled "GPU Nuclear Corp; Environmental Assessment and Finding of No Significant Impact." The Federal Register Notice notes that the applicant, General Public Utilities Nuclear Corporation (GPU), modified its plans for retreatment of the AGW and for the packaging and shipping of the evaporator bottoms after issuance of the Staff's June, 1987 Final Supplement 2 to the Programmatic EnvironmentalImpactStatement(PEIS). Since the methods of retreatment of the AGW and packaging of radioactive wastes finally selected by GPU.

were different from those in Final Supplement 2, the Staff, upon determining that the impacts associated with the use of the methods selected might be different from those considered in Final Supplement 2, decided to document its consideration of the environmental impacts of the proposed modification in an EA even though they were already in the hearing record. The Appeal Board's Order asks the following questions regarding this EA in relation to issues litigated in the proceeding and the Board's decisions presently pending on appeal:

Q.1. Explain the purpose of the Federal Register Notice and its effect, if any, on the Licensing Board's findings, conclusions, and rulings now before us.

Staff Response: The Staff prepared an EA in connection with the pntreat-ment of the AGW and packaging for shipment of the evaporator bottoms because the Final Supplement 2 did not address retreatment of the AGW by use of the decoupled evaporator or the transportation of pelletized evaporator bottoms. Based upon the original GPU proposal, dated July 31, 1986, the Staff in Final Supplement 2 evaluated retreatment of ths AGW by 9

i usa of EPICOR and the Submerged Demineralized System (SDS), and mixture of the eveporator bottotas with cement prior to offsite shipment. Final Supplement 2, pp. 2.2 and 3.3.

The subsequently proposed method of evaporation and packaging were addressed during the hearing (See response to Question 2, infra) and the Final Initial Decision addresses this matter aswell(29NRCat145-148). Since both methods of retreatment and packaging af radioactive. waste were described in documents contained in the hesring record and since the impacts of the use of these v6rious methods are reflected in the Final Initial Decision, the issuance of the EA (See response to Question 4) does not raise any new consideration that should affect the findings, conclusions, and rulings now before the Appeal Board. All parties had ample opportunities to raise issues in cor.nection with the matters addressed in the EA.

l Q.2. In particular, the Staff should describe what it terms the applicants' " current proposal" and state when it was submitted.

Staff Response: GPU, in a March 1987 comment on the Draft Supplement 2, ihdicated that pelletization of evaporator bottoms was an option under consideration for dispasal of the solid waste remaining after evaporation of the ASW. See, Final Supplement 2, Comments at page A.28.

GPU did not, however, provide sufficient information at that time for the Staff to consider the option in the Final Supplement 2 to the PEIS issued in June 1987.

Subsequently, the " Preliminary System Description" dated February 16, 1988, submitted to the Licensing Board and parties to the proceeding, (GPUletterdatedFebruary 17, 1968) di> cussed various methods of dry solidification of the waste. See, Preliminary System Description, at p.12. The pelletization method finally adopted is described and assessed

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1 in the October 7, 1988 Technical Evaluation Report, which was GPU's

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I Exhibit 1 at the hearing. Tr. 488. Earlier, both the Staff and Applicant had addressed the impacts of pelletizatio9 during summary disposition procedures. See, Licensee's Motion for Summary Disposition, May 16, 1988, Joint Affidavit at 15; NRC Staff's Response in Support of Licensee's Motion for Summary Disposition, June 23, 1988, Affidavit of Linda Munson, at 5-6.

The option of using the evaporator to pretreat the AGW was first described in'the original GPU proposal for evaporation of the AGW dated July 31, 1986 and also was described in the Preliminary System Description submitted in February 1988. This use of the evaporator for retreatment was also extensively explored during discovery (Licensee's answers to SVA/TMIA's second set of Interrogatories to GPU Nuclear, March 30, 1988 at 15-16.) and was addressed in the applicant's testimony at hearing (Buchanan,Tr.457-59).

Q.3. Was this " current proposal" what was litigated below?

Staff Response: There were no issues litigated that explicitly challenged the means of retreatment of the AGW, nor was an issue litigated that questioned the specific means of packaging for disposal of evaporator bottoms. However, the issues in controversy encompassed comparisons of impacts of evaporation with those of the "no action alternative." As part i

of the evidence on these issues, the methods of retreatment of the AGW by means 6f the evaporator and pelletization of the evaporator bottoms were described. The alternatives chosen were made known to the Board and the parties before and during the course of the proceeding.

In addition, the Final Initial Decision discusses both the use of the evaporator for O

L retreatment.and the environmental _ consequences of the GPU plan to pelletize the evaporator. bottoms. See LBP-89-7, 29 NRC 138, 145-148.

Q.4. Does'the " current proposal" pertain to matters discussed in applicants' February 17, 1989 or April 17, 1989 submission.to the staff-(both of which were served on us and the parties by applicants' counsel).

n Staff Response: No. The letters referenced contain information concerning tests performed on.the evaporator-vaporizor system and do not deal with the subject of the EA. The subject of the Staff's EA was

.dascribed in, the documents indicated above in response to Questions 1 and 2.

Q.5. What does the notice mean by " proposed amendment"?

Staff Response: The proposed amendment is the amendment to the Three. Mile

-Island, Unit 2_ license'to delete the prohibition of disposal of the AGW.

The application was dated February 25, 1987 and was revised in April 1987.

As indicated in response to Question 6, infra, the " proposed amendment" was the amendment litigated in this proceeding and previously authorized by the. Commission in CLI-89-5. On August 31, 1989, the date of the EA, the amendment had not yet been issued and was still " proposed."

t Q.6. Has the license amendment that is the subject of this adjudicatory

. proceeding and that was nuthorized by the Commission in CLI-89-5, 29 NRC 345 (1989), been issued yet?

Staff Response: The amendment was issued on September 11, 1989. 54 Fed.

Reg. 30469. The EA was issued prior to and in conjunction with issuance ofthisamendment,asrequiredby10C.F.R.I51.35(b).

The adjudicatory proceeding and the Final Initial Decision are discussed in the Safety Evaluation attached to the amendment. The amendment, the safety

m evaluation of the amendment and the EA are attached to this response. GPU' and Joint Interveners were previously provided copies of these documents.

Q.7. If the notice does not pertain to any "new" proposal, what prompted its issuance now?

Staff Response: The EA was issued as part of the license amendment on September _ 11, 1989 because the Staff had not previously published its evaluation of the two matters-in Final Supplement 2.

While there a.e some differences between the GPU estimates of risk associated with the waste transportation and results of the Staff's independent evaluation of the risks, the conclusion reached by the Staff that the estimated dose to the general population along the truck route and the dose to the truck crew would be very low corroborates the Board's findings. LBP-89-7, 29 NRC at 147, 148.

Q.8 If the notice does pertain to new matters relevant to the issues in this proceeding, why were we and the other parties not advised of such new developments pursuant to the Board Notification process.

Staff Response: As previously explained, the two matter:; evaluated in the EA are part of the hearing record and the Final Initial Decision and thus do not pertain to new matters.

Respectfully submitted,

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l 4er Coll en P. Woodhead Counsel for NRC Staff q M. du Stephen H. Lewis Counsel for NRC Staff Dated at Rockville, Maryland this 29th day of September, 1989.

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,,- ten UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'89 OCT -2 P4 :26 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD haN i c 4

?1 P. m In the Matter of GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION, ET AL.

Docket No. 50-320 OLA ASLBP No. 87-554-OLA (Three Mile Island Nuclear

)

(Disposal of Accident-Station, Unit 2)

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Generated Water)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO APPEAL BOARD ORDER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system,- this 29th day of September,1989:

Peter B. Bloch Esq., Chairman

• Thomas A. Baxter, Esq.

Administrative Judge Ernest L. Blake, Jr., Esq.

Atomic Safety and Licensing Board Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 2300 N Street N.W.

Washington, D.C.

20555 Washington, D.C.

20037 Dr. Oscar H. Paris

• John R. McKinstry Administrative Judge Assistent Counsel Atomic Safety and Licensing Board Commonwealth of Pennsylvania U.S. Nuclear Regulatory Corm;ission 505 Executive House

- Washington, D.C.

20555 P. O. Box 2357 Harrisburg, PA 17120 Mr. Glenn O. Bright

• Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel (1)*

U.S. Nuclear Regulatory Commission U.S. Nuclear Regu'latory Commission Washington, D.C.

20555 Washington, D.C.

20555 Atomic Safety and Licensing Appeal Three Mile Island Alert l

Panel (5)*

315 Peffer Street l

U.S. Nuclear Regulatory Cocaission Harrisburg, PA 17102 I

Washington, D.C.

20555 1

Susquehanna Wiley Alliance Coward M. Wilber*

c/o Ms. Frances Skolnick Atomic Safety r.nd Licenting Appa l

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Board

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2079 New Denville P7ke Lancaster; PA 17603 U.S. Nuclear Regulatory Consnission Washington, D.C.

20555

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Mr. Robert E.' Rogan Richard P. Itather Director, Licensing &.

. Department of Environmental Nuclear Safety, THI-2 Resources GPU Huclear Corporation.

505 Executive House P.O.' Box 480 Harrisburg, PA 17120 Middletown, PA.17057-0191 Adjudicatory File *

' Jay Gutierrez, Esq.*

Atomic Safety and Licensing Board Regional Counsel U.S. Nuclear Regulatory Comission USHRC, Region I Washington, D.C.

20555 475 Allendale Road King of Prussia, PA 19406 Thomas M. Moore, Chairman

• Atomic Safety and Licensing Appeal Christine N. Kohl

• Board Atomic Safety and Licensing Appeal-U.S. Nuclear Regulatory Commission Board Washington, D.C.

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

20555 Office of the Secretary

• Attn: Docketing and Service Section U.S. Nuclear Regulatory Comnission Washington, D.C.

20555

] rhc 7/.64 Stephett H. Lewis Counsel for NRC Staff l

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UNITED STATES NUCLEAR REGULATORY COMMISSION

' s WASHING TON, D. C. 20555 e

September 11, 1999 Docket No. 50-320

-Mr. Michael B. Roche

.Vice President / Director Three Mile Island Hnit 2 GPU Nuclear Corporation

'P. 0. Box 480 Middletown, Pennsylvania 17057

SUBJECT:

ISSUANCE OF AMENDMENT (TAC NC. 62068) AFD APPROYAL OF THE TER CN PROCESSED WATER DISPOSAL SYSTEM (TAC NO. 71119).

The Comission has issued the enclosed Amendment No. 35 to facility Operating License No. DPR-73 for the Three tiile Island Nuclear Station, Unit Not 2, in response to you.i letter dated February 25, 1987 and revised April 13, 1987.

.(Technical Specification Change Request No. 56).

Additionally the Commission has approved, subject to the restrictions contained in the enclosed Safety Evaluation your Technical Evaluation R$ port (TER) on the Processed Water Disposal System submitted by letter dated October 7,1988.

The amendrent modifies the Appendix A Technical Specifications by deleting the prohibition, imposed by Technical Specification 3.9,13 and on disposal 'of the Accident Generatad Water (AGW).

The sir.endment does retair the requirement for prior NRC approval of procedures associated with the disposal of the' ASW. The approval of the TER on the Processed Wcter Disposal System approves disposal of the AGW by evaporation subject to the restrictions provided in the enclosed Safety Evaluation.

Also enclosed is a Notice of Issuance which has been sent to the Office of the Federal Register for pubitcation.

i Sincerely,

t Michael T. Masnik, Senior Project Manager Project Directorate I a Division of Peactor Projects - 1/Il Office of Nuclear Reactor Regulation

Enclosures:

1.

Amendment No. 35 to DPR-73 2.

Safety Evaluation 3.

Notice of Istuencr; cc w/ enclosures:

See next page

v Mr. M. B. Roche, Three File Island Nuclear Station.

GPU Nuclear Corporation Unit No. 2 cc:

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Frank Lynch, Editorial Regional Administrator, Region I The Patriot U.S. Nuclear Regulatory Comission 812 Market Street 475 Allendale Road Harrisburg, PA 17105 King of Prussia, PA 19406 Dr. Judith H. Johnsrud Robert B. Borsum Environmental Coalition on Nuclear Power Babceck & Wilcox 433 Orlando Avenue NJClear Power Division l

State College, PA 16801 Suite 525 l

1700 Rockville Pike Rockville, MD 20852 Ernest L. Bla ke, Jr., Esquire Marvin 1. Lewis Shaw, Pittman, Potts, and Trowbridge 7801 Roosevelt Blvd. #62 2300 N Street, N.W.

Philadelphia, PA 19152 Wathington, DC 20037 Secretary Jane Lee U.S. Nuclear Regulatory Comission 183 Valley Road Washington, DC 20555 Etters, PA 17319 Sally S.- Klein, Chairperson Walter W. Cohen, Consumer Dauphin County Board of Commissioners Advocate l

Dauphin County Courthouse Department of Justice Front and Market Streets Strawberry Square, 14th Floor Harrisburg, PA 17101 Harrisburg, PA 17127 I

Thomas M. Gerusky Director Mr. Edwin Kinter Bureau of Radiation Protection Executive Vice President

- Department of. Environmental kegoerces GPU Nuclear Corporation P. O. Box 2063 100 Interpace Parkway Harrisburg, PA 17120 Parsippany, NJ 07054 Ad Crable U.S. Environmental Prot. Agency l

Lancaster New Era Region III Office 8 West King Street Attn: EIS Coordinator Lancaster, PA 17601 Curtis Building (Sixth Floor) 6th and Walnut Streets Philadelphia, PA 19106 t!.S-. Department of Energy P. O. Box 88 Middletown, PA 17057 David J. McGoff Francis I. Young Office of LWR Safety and Technology Senior Resident Inspector (TNI-1)

I NE-23 U.S.N.R.C.

U.S. Department of Energy Post Office Box 311 Weshington, DC 20545 Middletown, Pennsylvania 17057 e

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Nr. M. B. Roche Three Mile Island Nuclear Station-GPU Nuclear Corporation Unit No. 2 cc:

G. Kuehn R. E. Rogan GPU Nuclear Corporation GPU Nuclear Corporation l

J. J. Byrne S. Levin GPU Nuclear Corporation GPU f:uclear Corporation.

W. J. Marshall GPU Wuclear Corporation Susquehana' Valley Alliance Three Mile Island Alert c/o Ms. Frances Skolnick 315 Peffer Street 2079. New Danville Pike Harrisburg, Pennsylvania 17102 Lancaster, Pennsylvania.17603 Thorts A. Baxter, Esq.

Richard P. Mather, Esq.

Shaw, Pittman, Potts & Trowbridge Department of Environmental Resources 2300 N Street. N.W.

505 Executive House Washington, DC 20037.

Harrisburg, Pennsylvania 17120 i

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4[o i *J UNITED STATES -

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NUCLEAR REGULATORY COMMISSION 1

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DOCKET NO. 50-320 THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 2 i

AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 35 License No. DPR-73 1.

The Nuclear Regulatory Comission (the.Comission) has found that:

A.

Tht: application for amendment by GPU Nuclear Corporation, (the licensee) dated February 25, 1987 and revised April 13, 1987 complies with the standards and requirements of the Atomic Energy Act of 1954, as amendec (the Act), and the Comission's rules and regulations set forth in 10 CFR Chepter I;

.B.

The f acility will operate in conformity with the application, the provisions of the Act, and the rules end regulations of the Comission; C.

There.is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations; D.

The issuance of this amendment will not be ir.1mical to the common defense end security or to the health and safety of the public; und E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.c.(2) of Facility Operating License No. DPR-73 is hereby amended to read as follows:

(2). Technical Specifications The Technical Specifications contained in Appendir A, as revised through Amendment No. 35, are hereby incorporated in the license. GPU Huclear Corporation shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment 15 effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION l

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' hn F. Stolz, Direc r ro'ect Directorate I-4 01 sion cf Reactor Projects - I/II 1

fice of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance:

September 11, 1989 l

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1 ATTACHMENT TO LICENSE AMENDMENT NO. 35 FACILITY OPERATING LICENSE NO. DPR-73 DOCKET NO. 50-320 Replace the following page of the Appendix A Technical Specifications with the attached page. The revised page is identified by amendment number 35 and contains vertical lines indicating the area of change.

Remove Insert Page 3.9-3.

Page 3.0-3 1

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LIMITING CONOITIONS FOR OPERA 7f0N-

)3.9.12.21 The Auxiliary Building Air Cleanup Exhaust System shall be OPERABLE.

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with one of the four system. air cleanup exhaust fans OPERABLE.

P APPLICABILITY:

MODES 1; 2,~3' ACTION:

With the Auxiliary' Building Air Cleanup Exhaust System inoperable, restore

'the system to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or, susperid all operations involving movement of. liquid and solid radioactive wastes in the Auxiliary Building (other than sampling evolutions required by the Technical Specifications or RECOVERY OPERATIONS PLAN), the release of which could-exceed 50% of the Appendix B Technical Specification instantaneous release rate for gaseous effluents,~until the system is. restored.to OPERABLE' status.

ACCIDENT GENERATED WATER L'

3.9.13 LACCIDENT GENERATED WATER shall be disposed of.in accordance with.

NRC-approved procedures.

APPLICABILITY:

MODES 1, 2.and 3 ACTION:

None except.as provided in'5 specification 3.0.3.

THREE MILE ISLAND - UNIT 2 3.9-3 Amendment 35

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UNITED STATES

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i y.....y SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

'RELATED TO AMENDMENT NO. 35 TO FACILITY CPERATING LICENSE NO. DPR-73 GPU NUCLEAR CORPORATION TfRCEMILEISLANDNUCLEARSTATION,UNITNO.2 DOCKET NO. 50-320_

1.0 INTRODUCTION

GPl' Nuclear Corporation (GPUN, the licensee) submitted a proposal to dispose of 2.3 millior gallons of accident generated water (AGW) stoeed at Three Mile Island, Unit 2 (TMI-2) using an evaporation process. Accident generated water is defined as:

a.

Water that existed in the THI-2 Auxiliary, Fuel Handling, and Containment Buildings including the primary system as of October 16, 1979, with the' exception of water which as a result of decontamination operations becomes commingled with non-accident generated water such that the comingled water has a tritium content of 0.025 uti/ml of tritium or less before processing; b.

Water that has a total activity of greater than one uti/ml prior to processing except where such water is originally non-accident water and becomes contaminated by use in cleanup; c.

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

The NRC staff, in response to the licensee's February 25, 1987 (revised April 13, 1987) application for a-change in the TMI-2 technical specifications to allow the disposal of the AGW, prepared Final Supplement'2 to the Programmatic Environ-mental Impact Statement (PEIS) related to decontamination and disposal of radioactive wastes resulting from the March 28, 1979 accident. Final Supple-ment 2 to the PEIS, issued in June 1987, evaluated the licensee's proposal to evaporate the AGW as well as a number of alternatives. A Notice of Consideration of Issuance of Amendment and Opportunity for Hearing in connection with this action was published in the FEDERAL REGISTER on July 31, 1987 (52 FR 28626).

A hearing before an Atomic Safety and Licensing 8 card Panel (ASLBP) was held

.in November 1988. On February 2,1989 the ASLBP issued a final initial decision findirg in favor of the licensee in all relevant matters and recommending that the requested amendment to the license be authorized. On April 13, 1989 the Comission affirmed the Licensing Board's February 2,1989 decision and determined that the license amendment would be effective imediately upon issuance by the NRC staff. The Comission found no reason to stay the effectiveness of the Licensing Board's decision pending completion of the appeals process.

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1 GPUN subtritteo a system description (reference b), 3 technical evaluation report (reference i:) and additional supporting documentation (ref d and e) in response to NRC staff requests for further information (reference f and g) as a result of the staff's detailed review of the processed water disposal system.

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2.0 DESCR'pTION OF THE EVAFORATOR SYSTEM The processed water disposal system has two subsystems the evaporator subsystem and the packagirg subsystem.

The evaporator subsystem actually contains four separate components which change water from the aqueous to a vapor form. Two of these coraponents are designated as evaporators, one as a dryer, and the final one is designated as a vaporizer, Water to be evaporated is routed to a source or feed tank where it is sampled and analyzed to verify proper influent specifications.

This influent water will have an average influent concentration of approximately 4000 ppm of solids, principally boron and sodium. The influent water then passes through a vapor-recompression vaporizer. The distillate from this process will normally have achieved a decontamination factor (DF) of 1000 or greatef.

During initial operationc the distillate will be routed to a distillste tank for sampling and analysis to verify that the required DF has been achieved.

The water will then be pumped through a vaporizer where it will be heated under pressure then flashed to steam. After verifying that boron concentration in the distillate can be used to monitor DF, the licensee may use a coupled mode in which the distillate will go directly to the vaporizer. The concentrated solution, (bottoms) containing about 5-10 times the dissolved solids content of the influent is' continuously recirculated through the concentrate tank. A portion of the recirculating concentrate is continuously drawn off to feed an auxiliary evaporator and auxiliary concentrate tank for further concentration.

The distillate from the auxiliary evaporator will be returned to the main evaporator system. The bottor.s from the auxiliary concentrate tank which will be in the 20-40% solids concentration range will be sent to a dryer and pelletizer. The dryer uses electrical strip heaters to dry the incoming liquid or slurry. The vapor from the dryer is condensed and the distillate returned to the main concentrates tank.

The dry solid waste from the blender / dryer is transferred to the second major subsystem of the processed water disposal system the packaging subsystem.

The selids are discharged to a pellet mill and extruded into solid pellets.

The pelletizer and drum filling station are in an enclosure which is maintained under negative pressure by a high efficiency particulate absolute (HEpA) filter system. The dried pelletized bottoms will be packed intu 55 gallon drums and shipped by truck to the low level waste disposal grounds near Richland, Washington.

Final Supplement 2 to the PEIS assumed certain criteria for operation of processed water disposal system. Operating the system within the criteria provided by Supplement 2 would result in an deceptable level of impact.

These criteria pertained to the characterization of the influent AGW, the decontamination factor of the disposal system, the system inventory of AGW at any given time (for estimating the potential impacts associated with accidents) and the characteristics of the evaporator bottoms and the associated shipping campaign (for estimating impacts associated with processing, packaging, and shipment of the evaporator bottoms).

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'3- 0 ~ EVALUATIOii The technical issugs concerning the evaporator system are:

1.

Preprocessing cf water to actieve the base case radionuclides concentrations described u PEIS Supplement 2 (reference a).

2.

The ability of the evaporator system to achieve a decontamination factor (DF) of 1000 while processing base case water.

3.

The ability of the licensee to mo?itor effluents from the process stack and the building ventilation during routine and off normal conditions.

4.

Potential accidents' associated with the use of the evaporator.

5.

Potential for any safety problems in tha transporting of evaporator bottom to the LLW disposal site.

The licensee has several systems which could be used alone or in combination as a preprocessor to achieve tne base case assumed in PEIS Supplement 2.

These

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include the EPICOR system, the Submerged Demineralized System (SDS, which would have to be reactivated prior to use), the defueling water cleanup system (DWCS), and the evaporator system itself in a closed cycle mode. Verification that preprocessing has achieved base case or lower concentrations is easily confirmed by the licensee's samplin.g program. Samples will be taken and analyzed after preprocessing prior to using the water as a feed source to the evaporator systt:m. The staff is satisfied that the licensee has adequate resources available to achieve and verify base case (or better) feedwater to the evaporator system.

The staff has evaluated GPUN's systera description (reference b),(technir.a1 evaluation report (TER). (reference c), evaporator test report, reference h) and the supplemental information on the TER (reference f). The staff has concluded that the evaporator system is capable of achieving a DF of 1000 or greater in the feed to the vaporizar. This determination is based on a detailed review of the system, the results of surrogate AGW testing by the manufacturer, and the ability of the licensee to change the processed control system to vary the DF. GPUN has satisfactorily described a program which will L:se boron concentrations and effluent samples tp control the process such that the required average DF is being achieved. Alternate control methods may prove more advantageous after the licensee coinpletes as additional onsite testing program using a non-radioactive surrogate. The staff finds it acceptable to use alternate control systems provided that they ara either incorporated in procedures subject to NRC review and approval er a revhed description is

-submitted to the NRC in licensing basis documents.

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The licensee's process ano effluent monitoring system shall include a compositing sample on the vaporizer feed line and a continuous air monitor (CAM) in the process area near the building ventilation exhaust. GPUN radiological controls personnel will evaluate the positioning of the CAM on a quarterly basis to assure that the results from this device conservatively represent the effluent from the building exhaust.

In the event that the compositing sampler or CAM become inoperable, grab samples may be taken every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for up to 1 week.

If the sampling equipment is not returned to service within I week, the evaporator system shall be shut down. The licensee has the capability to measure routine and non-routine effluents from the evaporation process and from non-process sources such as maintenance and system leaks.

The staff also evaluated potentia'1 accidents associated with the evaporator system. The source tenn in the accident generated water, which is fully described in PEls Supplement 2 (reference a) is small and very dilute. Only a small fraction of the water an! resulting solids would be in the process building at any time. Potential offsite dose consequences of liquid spills, dry spills and filter failure were evaluated by the licensee and the NRC.

In all cases, the results were less than 0.1 mrem. This is a small portion of 10 CFR 50 Appendix I objecthes and very small in relation to 10 CFR 20 or 10 CFR 100 limits.

Transportation of the solidified evaporator bottoms was evaluated in PEIS

. Supplement 2 and an additional environmental assessment dated Radiation levels at 3 ft. from an individual 55 gallon drum are expected to be less that 0.2 mrem / hour. The pelletized waste will be shipped in accordance with Department of Transportation (DOT) regulations. Routine exposure from the shipments was conservatively estimated to be 7.1 person-rem, approximately half of which is attributed to the truck crews. The probabilistic exposure risk from transportation accidents which integrates probability and outcome was 0.16 person-rem for the entire shipping program.

4.0 ENVIRONMENTAL CONSIDERATION

The staff fully considered the environmental consequences of the proposed action in Final Supplement 2 to the PEIS published in June 1987, and an I

environmental assessment and finding of no significant impact was published in the Federal Register on September 11, 1989 (54 FR 37517). Furthermore a hearTng was held in November 1988 to further supplement the record on environmental considerations. The staff concludes that the proposed action will not have a significant effect on the quality of the human environment.

5.0 CONCLUSION

S The NRC staff has reviewed and evaluated the proposed use of the processed water disposal system to evaporate the accident generated water at Three Mile l

Island Unit 2.

These activities, subject to the limitations in this safety evaluation, fall within the scope of activities previously considered in PEIS Supplement 2 and the staff's environmental assessment.

l

m t,. '

l,

1 We have concluded, based on the considerations discussed above that 1 there is reasonable assurance that the health and safety of the publIc will(no)t be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public.

6.0 REFERENCES

a.

Programmatic Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from March 28, 1979 accident at Three Mile Island Nuclear Station, Unit 2, Supplement 2 (NUREG 0683, supplement 2), June 1987 b.

GPUN letter 4410-88-L-0012/0335P dated February if,1988, from F. R.

Standerfer to NRC with attached Accident Generated Water Disposal System Description.

c.

GPUN letter 4410-88-L-0168/0428P, dated October 7,1988 from M. B. Roche to NRC with attached Processed Water Disposal System Technical Evaluation Report (TER).

d.

GPUN letter 4410-89-L-0038/0455P dated April 17,1989 from M. B.

Roche to NRC re Processed Water Disposal System TER e.

GPUN letter 4410-89-L-0067/0469F dated June 7,1989 from H. B. Roche to NRC re Processed Water Disposal System TER f.

NRC letter dated February 16, 1989 from J. F. Stolz to M. B. Roche, GPUN, re Processed Water Dit,posal System TER g.

NRC letter dated May 31, 1989 from M. B. Masnik to'M. B. Roche, GPUN, re Processed Water Disposal System h.

GPUN memorandum with attachments, dated February, 16, 1989 from J. A.

Thomas to D. R. Buchannan re Licon Aquavap Testing Program Principal Contributors: Lee H. Thonus, Linda F. Munson Dated: September 11, 1989 I

7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION GPU NUCLEAR CORPORATION DOCKET NO. 50-320 NOTICE OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE The U.S.. Nuclear Regulatory Commission (Comission) has issued Amendment No. 35 to Facility Operating License No. DPR-73 issued to GPU Nuclear Corporation (the licensee), which revised the Technical Specifications for operation of 'the Three Mile Island Nuclear Station Unit 2 located in Dauphin County, Pennsylvania.

The amendment is 5ffective as of the date of issuance.

The amendment modifies Appendix A Technical Specifications by deleting

~ the prohibition on disposal of the accident generated water (AGW) at the

- plant.

In 1986 the licensee submitted a plan to dispose of the AGW by forced evaporation and atmospheric release of the 2.3 million gallons of AGW resulting. from the March 28, 1979 accident at TMI-2. The NRC staff updated the 1981 Programmatic. Environmental Impact Statement (PEIS) in June 1987 with the publication'of the final Supplement 3 to the PEIS dealing with disposal of the AGW.

On February 25, 1987 the licensee requested a change to the Technical Specifications deleting the prohibition for disposal of the AGW. This request to amend the license was revised on April 13, 1987.

1 4

p

o L-

.. The application for. the amendment complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations. The Commission has made appropriate findings as required by the Act and the Commission's rules and regulations in 10 CFR Chapter I, which are set forth in the license amendment.

Notice of Consideration of Issuance of Amendment and Opportunity for Hearing in connection with this action was published in the FEDERAL REGISTER on.

July 31,1987 (52 FR 28626).

A hearing before an Atomic Safety and Licensing Boaro' Panel ( ASLBP) was held in November 1988.

On February 2, 1989 the ASLBP issued a final initial decision finding in favor of the licensee

.in all relevant matters and recommending that the requested amendment to the license be authorized. On April 13, 1989 the Commission affirmed the Licensing Board's February 3,1989 decision and determined that the licensee's application for an operating license amendment, when issued by the staff, should become effective immediately. The Commission found no reason to stay the effectiveness of the Licensing Board's decision pending completion of the appeals process.

Based upon the findings of Supplement 2 to the PE15, the ASLBP final initial decision and the staff's safety evaluation, the Commission has concluded that the issuance of this amendment will not have a significant effect on the quality of the human environment.

For further details with respect to the action see (1) the application for amendment dated February 25, 1987, revised April 13,1987,(4) Amendment No. 35 to License No. DPR-73, which includes the NRC staff's Safety Evaluation 4

._____._..__._.__._____.________._________m

9 (2) the Commission's related evaluation of this amendment is contained in Supplement 2 to the Programmatic Environmental Irpact Statement dated June 1987 and a Safety Evaluation dated September 11,1989, and (3) the Comission's Environmental Assessment dated August 31, 1989 published in the FEDERAL REGISTER on September 11, 1989 (54 FR 37517). All of these items are available for public inspection at the Comission's Public Document Room, the Gelman Building, 2120 L Street N.W., Washington, D.C. and at the Government Publications Section, State Library of Pennsylvania, Walnut Street and Commonwealth Avenue, Box 1601, Harrisburg, Pennsylvania 1,7105. A copy of items (2) and (3) may be obtained upon request addressed to the U.S. Nuclear Regulatory Comission, Washington, D.C. 20555, Attention: Director, Division of Reactor Projects -

I/II.

Dated at Rockville, Maryland this lith day of September 1989.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Masnik, Project Manager Project Directorate I-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation I

O

'l Podesel Regimese,f pal es,So. esse / 44onday. September 11,' fees / Netsoes 37317 are avaBeble for ; 2 M,

u t abe tsup6smestatten sf ee finan==='s plan campaign is estomated at om and DJO07 a

i

,a Comedesion'sPuIdic DocessetRosen., wooid roselt he hupones abEarent than a,, LJy. For the entire ablpping j

213DLStmet.NW Washington.DC these for te ha===*s a=%~P the dose of the trud crews assEL

,~

w pc, in typlar==ne ano the PEIS.

was setunated at RJ person-rem and the d

Sensd at macheL. nasryland thes sik ery ArrfmrimeM9}sqpacts EfddW estimated done to the seneral pubhc of september assa.

ggg, along the shipping route (1.3 million People)is SJ person-run.

per the Nedser Resslatory tw-d i==

. %' g,"whid wu r'18138o 8 8 mall probability that P

P"**I SermeseIL weise.

a ehl accident saa b menear.NoAmurJi EnosmaalAssmos treated by los to a tw 2,se,annyordanm to rasaltin the be severe d a weste i

Areesornar Qrassas c(Jteaaesrhipsser E sesotainer and release of some of the TM vancfsenciaIAwecerofwv.weser 8vaForstar.& snajority d the Hapdd weste.To detemdne the risk of i

Doc.

Ptled s+4R arts em) con the staf used odel euses cose russ.es a and &e % mouwdink h fee that estimates the stion dose by j

sobdiscanon.he soEd wassa would multiplying noddent (the 1

fDechet 80s. EM301

+

then be to a commerical expected anInbar d eastets) by NRCU lowlaval wasta dispa==t anddent consequences.Ustag these GPU Pemesse Corp; Ertvtronowrtal site near Fdiand. Washieston.N methodology the staf estimated that a Aeoestmerit and Firusng etleo tots! sohdlSed volume was expected b doae of about 0.16 person-rem would algnmoent hupact be between armo end eamoit.

reisult from aaddents daring afpment of 8

& U.S Nuclear R st57 Ae"- tah eD m 250 shipants h M wnW %M cut d betwena DG-2 and malana the dry penetized waste is estimated at Commission (NRC or r'ammiazion) is considering fuuancs of an amendment WWndWMN N

number ofin}uries and fatalir=s doe to Based on the redaoed level of injuries

[g**G e. icpuN &ebce,soo,m l

U trucking accidents estimated for the

.and fatalltfu associated with the i

syfrom 0.04 to 1J respecthrsly&

estimated dose to the general populstion g m~ # ran.ed f,oeJ.1 ndu-d n-ber d *>pm-se -u co,,o,.

nree MlleIsland Nuclear Gen ooccupe 4

al og b tmck rum ed ee lowinel Station. Unit No. 2 (n0-2) located crews resultfag bes7oahipping of the of truck enw the std De"Pb Con'Y"'""3 ' A-evapors noe bottosos was expected. No condudes that are no significant i

Envirn=mantal h======f routine redrological does to the pubbe adverse environmentalimpacts Idaupadon afm-r -s',Acdon was calcidated due to &~ now speciBc associated with the proposed action.

l e

ocevity d tk ookdiSW weak and ee h.&e std @es est h proposed amendment would self shielding charactaneum of the the beensee's proposal would resntt in a revise the Appendix A Technical Partiand r===nt btoder. likerise no significant decrease in the amount of Specifications (TS) relating to the rediation exposure to the public In the waste to be dispossd and a significant dispmal of the Accident Generated event of a trucking accident was reduction in the overall cost of shipping.

Water (AGW).h proposed action is in expected since dispersal of the schch$ed response to the licensee's application evaporator bottoms war urhly.h Aftematires to theProposedAction.

dated February 25.1987 and revised total cost of shipping the solidi 6ed Since the staf concluded that there April 13.1987.

waste was estimstad to be between,,,

,,, no,s,stm,, environmental dects 6

000 that would from the d

& Needforthe ProposedAarjan propwalis to b NRC staff,in response to the still evaporate the AGW is a j

vb cts ne not boensec's appbcation for a change in the commerically available evaporator.

(",ta technical speciScstions to aDow the However, the evaporstcir may be used in aluated, h principal altemative s came wouM disposalof the AGW, prepared ofion exchange for retreatment.

p, wgg Supplement 2 to the programmatic solid waste stream may contain Environmental Impact Statement (pEIS) radionuclides that trere expected to be

""' " d,hd*,"g"*$ [. to related to decontamination and disposal shipped offsite in spent ion edence gpment..

g, of radioactive wastes resulting from the besin liners. For the purposes of this altamative would reeuk in increased March 28,18 9 accident at 30-2. Final assessment the ma rienum concentration owl inmean wasta, and incmaad Supplement 2 to the pEIS, issued to June permissible in class A wasta was Potential fa transputanon related 1987, evaluated the licensee's posal assumed for determining dosa.

accidents without e afsnificant reducuon and a number of altematives the Additionally the evaporatar bottosas in radiation dose to efear &a puWe or d'sposalof AGW.

will, not be mixed with a binder and 6e tmek arews.

Subsequent to the lasuance of Final solidified. Insteed the bottoms will be Aftemouve f/se ofResowoes.

Supplement 2 the licensee has modiBed pelletized, dried and the peBets its plans for retreatment and for the packaged in 58 sallon dmms and

%1s action does not involve the use of packaging and shipping of the ahlpped to RIMand Washington, m any resources not previoush considered evaporator bottoms to the mmmmical pa and shipmentdthe dry in Bupplement 2 to the pEIS dated June low level waste disposal site near ~

pelle wasts will be la conformane, 1887.

Richland. Washington. Since the current with allregulations gove shipment

@acles andPp C$nsulted.

proposal is different than that evaluated oflowlevel wastes.N num of in Final Supplement 2 the staff has shipments is expected to be 14.N -

N NRC staff reviewed the licensee's evaluated the impacts associated with number of infuries and fatalities ice to request and did not consult other this change and has determined that.. trucking acd6ents for the shipping agencias or persons

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wm have made Bndings required by the be tissued to estters weets to sospo et par nuest detans with respect toIbis M

Atomic Enap Ad of1954, as aansaded ttu masedmont ander casederness. A esden,em $eapp h nanIer (the Act) ano the Comentesios's petitionerwho fuAs to me sasha ammad==at dated isly 31.1980. e414 is modemse e i By October t sees, the licenses muy 7 suppjennut wkse esame t'**

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