ML22230A097
| ML22230A097 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1979 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M791004 | |
| Download: ML22230A097 (62) | |
Text
RETURN TO SECRETARIAT RECORDS NUCLEAR REGULATORY COMMISSlON IN THE MATTER Or:
PUBLIC MEETING DISCUSSION OF RADIOACTIVELY CONTAMINATED WATER AT TMI
& RELATED SUBJECTS (EPICOR II )
Place -
Washington, D. C.
Date -
Thursday, 4 October 1979 ACE - FEDERAL REPORTERS, INC.
Official Reporten 444 North Capitol Street Washington, D.C.20001 NAT10NW1DE COVERAGE* DAILY Pages 1-60 Telephone:
(202 ) 347-3700
I I
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DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on
'Ihursday, 4 October 1979 in the Commissions's offices at 1717 H Street, N. W., Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not *necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Commission may authorize.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PUBLIC MEETING DISCUSSION OF RADIOACTIVELY CONTAMINATED WATER AT TMI
& RELATED SUBJECTS (EPICOR II) 7 Room 1130 1717 H Street, N. W.
a Washington, D. C.
2 9
Thursday, 4 October 1979 10 The Commission met, pursuant to notice, at 9:42 a.m.
11 BEFORE:
12 DR. JOSEPH M. HENDRIE, Chairman 13 VICTOR GILINSKY, Commissioner 14 RICHARDT. KENNEDY, Commissioner 15 PETER A. BRADFORD, Commissioner 16 JOHN F. AHEARNE, Commissioner 17 ALSO:,,:PRESENT:
18 Messrs. Denton, Hoyle, Gossick, Vollmer, Collins, Slaggie, 19 Snyder, Malsch, Bickwit, and Dircks.
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P R O C E E D I N G S CHAIRMAN HENDRIE:
Let's get started.
The Commission meets this morning for a discussion with the staff on contaminated water matters at Three Mile Island and related subjects, the EPICOR-II system and so on.
The first item of business that we ought to bring up is for me to ask my colleagues to join me in voting to hold a meeting on less than* one week's notice on this subject this morning.
Those in favor?
(A chorus of'ayes.)
CHAIRMAN HENDRIE:
So ordered.
I guess the best introduction could be provided by those across the table.
Please go ahead.
MR. GOSSICK:
Mr. Denton~ill introduce the subject.
MR. DENTON:
I sat down late last night with the Commission paper on the use of EPICOR-II for processing the water.
Dick.Vollmer has a detailed presentation.
I think the best way to proceed is to let him discuss the issues that need resolution.
We have concluded that the use of EPICOR does not require preparation of an environmental impact statement.
It deals only with the use of EPICOR.
We are preparing an environmental assessment on the disposition of the water that would be produced by EPICOR.
Therefore, in our conclusions regarding the lack of need for a formal environmental statement
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on EPICOR itself, we are recommending that the use of EPICOR-II be authorized by the Commission.
Dick, why don't you discuss this specifically?
MR. VOLLMER:
Okay.
There appear to be ~hree major issues revolving around the use of EPICOR-I.
On the first slide these are indicated.
The first is to the adequacy of the environmental assessment.
(Slide.)
The environmental assessment, as you know, was prepared in response to the Commission's May 25th statement, and was put out for public comment on August 20th of this year.
And a number of comments were received, both technical and otherwise, in response to that environmental assessment.
I will discuss that one.
But, for completeness, I recall, I want to point out to you that the fact that there still is a need for consideration, as brought up prior to this, whether or not a construction permit is needed for the -- as it turns out, already completed EPICOR-II facility.
And, thirdly, as to whether or not an amendment is needed to amend for operation of EPICOR.
We prepared a paper on that which indicated -- it appeared to us it would be needed, based on the fact that effluents, the release points are normally part of technical specifications* and are
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normally identified in the technical specifications.
So, since the EPICOR facility does have such an effluent monitor, it would likely need to be part of the technical specifications although the facility itself and the operation itself would not normally be part of the technical specifications.
As far as the adequacy of the environmental assess-ment and the response of the public to the August 20th Federal Register notice, we received about 40 comments.
36 of these I characterized as es:pressions of opinion.
Many of these were expressions that they did not want any water dis-charged, did not want any krypton gas released, which were really not part of the scope of the environmental assessment.
But many of these, inherently or explicitly didn't say they wanted EPICOR operated.
35 of these were expressions against the use of EPICOR.
One of these was an expression for the use of EPICOR.
There were four other commenters that provided more substan-tive comment.
COMMISSIONER GILINSKY:
Could I stop you for a moment.
Did those who objected to the use of EPICOR suggest alternatives?
MR. VOLLMER:
There were a couple of suggestions in a very brief way, things like the water should be shipped off or it should be evaporated.
But they were not in a great deal of detail.
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25 CO.MMISSIONER AHEARNE:
From the standpoint of arguing that we should have evaluated the alternative to a greater extent, as opposed to saying evaluate --
MR. VOLLMER:
The more substantive commenters, three were received that were opposed to the use of EPICOR:
the City of Lancaster, Susquehanna Valley Alliance, and two profess~rs from Franklin and Marshall College.
One of the cornmenters, the Commonwealth of Pennsylvania, had some technica comments and was in favor of the use of EPICOR for processing of this water.
COMMISSIONER AHEARNE:
Did Met Ed respond?
MR. VOLLMER:
No, we did not get a response from Met Ed.
Other agencies -- I understand that in the last couple of days we got a response from HEW that had some technical comments.
But I guess we characterize this as in favor of the use.
EPA was given copies, CEQ, and they did not*respond.
Next I would like to briefly run through the system, and then I would like to describe what the major issues were raised by the comments, both from the issue point and from the technical point.
MR. COLLINS:
On the three slides you have in front of you, slide number one is just a plan view to orient you with respect to the EPICOR building that was part of the
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original cdnstruction of the plant.
(Slide.)
And in relation to the auxiliary building, the reactor building, and the fuel-handling building.
The fuel-handling building, of course, contains the temporary storage tanks that were constructed and placed in the fuel rool for Unit 2 to provide additional stcrage capacity.
COMMISSIONER GILINSKY:
Are you going to go through the slides at some point?
MR. COLLINS~
Yes.
The next slide very briefly shows you the concentra-tions expected to be processed through the EPICOR system.
These are probably the maximums that are contained principally in the react6r coolant bleed tanks.
Many of the.other tanks have lower concentrations than that.
But just to give you an idea of the type of activity levels that we are talking about, with their expected half-lives.
COMMISSIONER AHEARNE:
You have assumed levels.
MR. COLLINS:
These numbers have fluctuat~d, because many of the tanks have been topped off with other water that has diluted them down.
We have not made it a requirement on Met Ed that they continually measure the concentration in those tanks, because ~f the problem of increased exposure to the operators.
Of course, prior to processing any of the water,
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each one of those tanks will be sampled for its radioactivity and its chemical content, prior to the prcessing, so that we know for sure what those concentrations will be.
These are the principal isotopes that we will be dealing with, in that order of magnitude.
MR. SNYDER:
Are there any of these tanks in which the water is of significantly lower activity than some?
Has there been an attempt to segregate on that basis?
MR. COLLINS:
I think I indicated that there are tanks with lower activity levels in them.
What I tried to depict in this slide is that this is the activity one would expect to see in the bleed tank, which contains the highest activity.
MR. SNYDER:
The worst case?
MR. COLLINS:
Yes.
Many tanks would have activity lower, but still above what one would expect to see in a normal operating reactor.
MR. SNYDER:
There is the possibility, if_ the system were operate~ to run the lower activity through first.
MR. COLLINS:
That would be the proposed plan, as Met Ed has described it to us, that they would handle lower activity tanks-first, processing that water, and then get on with the higher activity.
I think the next slide is probably the most signifi-cant slide.
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(Slide.1).
It is a block diagram of what the EPICOR process consists of.
And you can see on the left-hand side it shows the auxiliary building tanks,.the contaminated storage tanks and temporary storage tanks, and they feed into a series of piping systems into the first stage of the EPICOR, which is a pre-filter, which iri this case is a demineralizer.. It then is processed through a second demineralized bed, another catalyst to remove principally the cesiu~, and then the third bed, the second demineralizer, is a mixed-bed demineralizer.
-The water is then taken back to the clean water receiving tank, where it is then sampled.
If it meets the requirements for either reuse or discharge, it could then be pump~d over to their concentrated or their waste evaporator condensate test tanks, where it would be sampled prior to release or recycle back into the plant.
If the water do~s not meet discharge or reuse requirements, then it would be pumped back to the-~ referred to as the off-spec batch tank, and then recycled through the EPICOR system.
COMMISSIONER BRADFORD:
"Off-spec" means contami-nated?
MR. COLLINS:
That it is higher than the requirements placed on the water for either discharge to the Susquehanna or for reuse in the plant, both chemically and radioactivity.
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25 COMMISSIONER AHEARNE:
Let me make sure I understand what you just said.
It seems to me you had three alternatives for that water after it left the receiving tank:
One was, if it was -- it would go back for reprocessing ifi it was off-spec.
The other was.for reuse in the plant.
You mean going back into the cooling system for makeup?
MR. COLLINS:
I would like to refer to that.
At the present time, there is we are prohibited from discharging, so that.the alternatives to discharge at the present time would be either to store that water --
COMMISSIONER AHEARNE:
That is what I was trying to get to.
Storage doesn't seem to be one of the ones you were t*alking about.
MR.* COLLINS:
Storage, of course, would be one of the alternatives.
Another one would be to reuse it in the plant.
COMMISSIONER AHEARNE:
At the moment, at least, and maybe longer than that, discharge is not an alternative, right?
MR.. COLLINS:
At the present time, discharge is not an alternative.
But the water coming through here would be sampled.* If discharge were permitted, at that point a deter-mination would be made.
COMMISSIONER AHEARNE:* As far as use at the present time that you are proposing, discharge is not one of the proposed --
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25 11 MR. COLLINS:
That is correct.
Storage -- after processing of the EPICOR at the present time, it would be storage.
COMMISSIONER GILINSKY:
Where would the water be stored?
MR. COLLINS:
It could be in two places.
Of course, you do have the capability to store water in that receiving tank, because you have 130,000 gallons capacity, and you are processing through at a nominal processing rate of 10 gallons per minute, or you can*process water and*store it in that tank.
The other thing that could be done with the water would be to take the water back to its original tank, if that tank were empty.
Because those tanks are pretty heavily contaminated.
They will have to be flushed out, anyway~
So you could use that water as a flushing mechanism.
CHAIRM..Z\\.N HE:NDRIE:
The reactor water storage tank?
MR. COLLINS:
The miscellaneous waste holdup, the various tanks in the auxiliary building.
COMMISSIONER KENNEDY:
You would use this clean water as part of your --
CHAIRMAN HENDRIE:
The major storage tanks for the plant, condensate storage, reactor water storage tanks, have very large capacity.
These, you say, are contaminated now?
MR. COLLINS:
All of the tanks in the auxiliary
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25 12 building fur Unit 2 contain contaminated water.
that now.
CHAIRMAN HENDRIE:
Of one kind or another.
MR. COLLINS:
Yes.
MR. VOLLMER:
Including the tank farm.
We are using MR. DENTON:
But just recycling it within the plant doesn't solve the problem, because there is an in-leakage of 1,000 gallons a day.
So eventually, you have to store it some~lace that it is not stored today.
It might be over in Unit 1 or in railroad cars or inflatable bladders brought on site.
But there is a need eventually to create additional storage other than that presently available.
COMMISSIONER GILINSKY:
But you have added at least 100,000 gallons of storage capacity in the system.
MR. COLLINS:
After cleanup, because these tanks do not contain the shielding that would be required.
COMMISSIONER GILINSKY:
After the cleanup, these tanks are set up and ready to be used?
MR. *coLLINS:
Yes~
CHAIRMAN HENDRIE:
At this stage, what do they call the reactor water storage tank?
MR. COLLINS:
The reactor coolant bleed tanks, the three large bleed tanks for ble~ding to the makeup system.
The reactor coolant tank is inside the containment building.
The borated water storage, the reserve water.
Basically, that
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25 13 is the borated water storage tank, which is 300,000 galons, between 300 and 400,000 gallons.
COMMISSIONER GILINSKY:
Isn't that outside?
MR. VOLLMER:
Yes.
CHAIRMAN HENDRIE:
That ought to be pretty well empty now.
MR. VOLLMER:
There is still a fair amount of margin of water there.
And in Unit 1, Unit.l needs further tech specs, a certain amount of additional capacity, because that water goes irtto the coolant system in the event of a pipe break.
It is also used in the makeup, for the fuel pool and so on.
It is the main supply of borated water.
COMMISSIONER GILINSKY:
The tanks for Unit 2 are needed for Unit 1, even in its present condition?
MR. COLLINS:
No.
MR. VOLLMER:
A borated water tank for each facility.
I was speaking generically.
They need to contain a margin of water available for contingencies, in case you get_some sort of a pipe break or leak or something like that.
COMMISSIONER GILINSKY:
Why can't this be some of the water?
Can't you borate this water?
MR. VOLLMER:
I think John was referring to putting it back into the system, both as flushing material or probably, if it is chemically adequate to be put in there.
MR. COLLINS:
Chemically, it would have to be very
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25 14 adequate, because at that point you are keeping your low concentrations of chlorine and other chemicals that you don't want in your primary system.
So if it could meet it chemically it could be used as that source.
I think the most likely thing would be to use it as a flushing mechanism for reducing the activity levels in the various piping,!systerns and the tanks
~rom which it came from.
COMMISSIONER GILINSKY:
How do you decontaminate these pipes and tanks?
Do you flush out?
Or is there any more --
-468 02 01 kap EW/d 15 Mr~. COLLIUS:
rl"u:3hinq of wat,3r is the principal 2
mecn.anis11.
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COW1(lSSIOr4ER Ai-lEAr?NEt Th::ire com"'!s a point \\'/hen you are taking the water in the aux tanks, running it
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thr*'.)Ugh and then putting it back th.rough th9 clean water o
receiving tanks.
If you ar~ doing a flushing system 9 you I
are in a cycle unJ since you have in-leakage building and 8
at same stage you will have filled up this whole cycle.
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!,ff?. COLLIN'S:
At some point. you h,we to store that IJ water in.a separate tank.
11
. COMMISSION ER GILINSKY2 But you have another I 00 12 days capacity, h~re.
13 CO!,P.HSSIONER AHEAf~NEg Or more than that, since 14 yqu have th3 batch tank.
15 Mi(. VOLLMt;:R~
You would ft~el comfortable with 15 receiVing the clean water.
That is substantially different I/
tha~ we would w~nt to put contaminated water so railroad 13 cars or blaaders -- there are a number of ways to alleviate I~
the clean water storage problem.
2J COMMISSICL'JER GILINSKY:
[,\\/hat is the capacity of 21 the railroaj car?
?M?. COLLil'lS:
8008 to 10?000 gallons.
The ones W9 23 hava on the site at the present time.
24 CO\\{MISS ro;~ER BRADrORDi
- 'Ji th regard to the borated 2
- ::i water stora*;;e tank, why does the chemical content of the
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16 wat9r in th3re matter as ~uch in this plant as it would in an operatin9 reactor?
J,,m. COLLINS~
\\lie l'loulJ not want to put in high concentrations of chlorides into the primary system.
You
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could end u~ with a corrosion problem, stress corrosion problem in the primary system 9 which could then eventually cause additional leakage.
8 COM/HSSIONER Bl?ADrOP.Dt Even ',*Ji th the plant in Y
this condition?
10 J.,ffl. COLLINSg Even with the plant in this.
11 condition.
12 Ma. VOLLMERg We are looking into more specifics.
13 But assuming it is going to be a fairly lengthy period in 14 which we want integrity of those systems, we would like to 13 kee? them as ~lean as possible.
16 Mi-?. COLLINS:
I beU.eve the other item on that 17 slide would be, of course, depicting how the prefilters and 18 the demins would be removed after they have been exhausted 19 through radiation, through a lead shield that transfers and 2J then on to a waiting truck.
Inside of another concrete 21 22 23 2-}
25 shield.
And then transferred to the staging area.
And then, on to th~ licensed burial ground.
CO!*MHSSIONE!? AHEMWEg The staging area is what?
,\\m. COLLii~s:
There are two staging areas.
On'3 is refsrred to as an interim staging facility that*was ouilt to
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17 handle a certain number of 28 liners, until a more long-ter~
concrete structure could be ouilt 9 which we would ho~e would have no mora longevity than of about two years.
This would provide adequate on-site holding
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capacity until the shipments could oe made to a licensed 6
facility.
fhere are not enough licensed casks to make the I
shipments as these liners are moved from the EPICOP. syst3ms, 8
so the staging arga became essential to h6ld these until we Y
had the cas{s that could make a transfer to another burial 10 ground and return to the* site.
II COMMISSIONER AHEMrnE:
!*\\/hen will the concrete --
1-2
,.rn. COLLDIS:
It was scheduled to be completed by 13
- November th9 1st.
It is now scheduled for December the 1st 14 15 16 I '
because of tha rains we have had these past several w~eks.
It has hampared the Met Ed from pouring concrete.
So, it has now slipped that schedule back about a month.
COM\\DSSIONER AHEAt*fNEa And the interim staging 13 area, could you desciibe th3t?
Jy MR. COLLINS:
It is a series, and I think it is 20 described a little ~it in the report, too.
It consists of 21 some corrugated metal pipe that has been placed in the 22 ground with an underlying drip planned and sealed with epoxy 23 resin on th9 *inside.
Then the liner would ~rap down inside 24 the corrugatea pipe and a 3-1/2 foot thick concrete shield 2j bloc~ rests on top.
The -- it is bermed around it and the
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I le 18 ground has oeen sloped and covered with asphalt.
There are d
test wells that we have installed to monitor water that may 3
leak out of the system.
It is principally an interim
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facility.
CO':(:\\'iISSI08ER AHEA.:?NEg I noticed in the final 6
paragraph here, in Harold's mem0 9
- that he m9ntions that at
/
some point the certification system will be installede a
Would that then be in association with that staging area?
9 Mi~. COLLINS g That has not been dee ided y,3 t, as to 10 how that will interface with that staging area.
I don't II really have an idea of how it would look, whether it could 12 De placed at that facility, whether it could be placed 13 a djac: ent to the EP ICOR build i nq.
That has not been l oo'.<3 d 14 l:S at.
CHAH?MAN HENDRIE; I have been down there9 and 16 loolc~d at it, John.
The resins in the lin"::rs, the 1,
contaminated resins in the liners at that point in the 18 staging area are if you are going to get them out of I~
those liners you have to pump a lot of water back in and 20 flush or you are going to have to go in with a shovel, 21 because th~ -stuff is really relatively dryo These things 22 are done in concrete pits.
23 In any event, you have to haul them up out of that 24 and do some sort of an area where pipes can be attached again.
It just isn't clear whether the solidification
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10 l I 11-13 14 15 16 I I I c3 19 20 21 2.2 23 24 2j 19 facility could be hooked on to th9 processing building tnat is hare 9 so the material doJsn't go through a dewatered staga and tnen into storage and has to come back out, or whether you can get the solidification facility into this area or next to it 9 in any re3sonable wayo And you are indeed going to have to go to staging..
COMMISSI01~ER KENN:::DYg Are l*te ~10ing to discuss that solidification proposition?
MR. DENTONx We can do it now 9 if y0u like.
We have our technical staffs that talk bac~ and forth about it.
Bill 0ircks and I have reached an agreement that we should use the EPICDR the way it is designed until such time as the solidification can be reviewed and installed 9 anJ we would require that the capaoility be made for easy inst3llation of a solidification unit to take the resins as they come out of this one.
I would treat.the resins that have ~!ready been exhausted -- but once the solidification unit -- we move over to using the solidification unit.
CHAIRMAN HENDRIE:. Can they g~t one hooked on here?
lvH?. DENTO:~i Let me ask John to respond.
1,{.-,. COLLI:--!S:
No thought has been given to it.
I would agree with you, though.
I think it would be tight
/468 02 06 kapl3Wrl 20 puttin-;J it ine
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CHAIRMAN HENDRIE:
You may have to unhook the J
liner vessel, the pipes in the liner vessel without going 4
through, in particular, the vacuum dewatering stage, and
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pie~ it up into a shield and ta~e it over to a 5
solidification facility where you reconnect ~iping to it and I
be able to flush rasin out of the liner tank and into a 3
mixer.
And use whatever --
COMMISSIO>IE:R GILINSKYi Let. me understand what you.
JO are saying.
You said until such time as solidification is II available.
Are there some plans for making it available?
12 MR. DENTON:
We would propose that we would put it 13 in 99nding the tech spec.
14 CO/f~HSSIONER AHEAqNEg How long would it take to b
build it?
16 MR. COLLINS i There are a number of al ternati V9 I,
ways that certification can be handled.
One, of course, 18 would be to construct a facility that you could transfer the I~
linars to, and thsn put in the solidification from a 20 permanent solidification system.
21 Another way would be to redesign the liners such 2.2 23 24 25 that it could be possible to do in-lining s0lidification.
In any event, I think any modification wouLJ be in the order of nine years to a year -- nine months to a year.
(Laughter.)
lt468 02 o7 kap3Wi-1 21 COMMISSIONER KENNEDY:
Starting wr1en?
2 MR. COLLL*fSi If we were to start now., it would be 3
that length of time.
4 COMMISSIONER KENNEDY:
How can we start now, when we h3Ven"t even -- as I understand it -- concluded what 5
would be the best approach?
Mr?. COLLii,JSg Ihat"s correcL 8
COMMISSIONER i<ENNEDY8 How long is it going to 9
take to reach that conclusion?
10
- CHAIRMAN HENDRIE:
And *will we.have to do an 11 environmental assessment on that?
12 MR. D.ENTON; tfa are requiring solidification of 13 reactor wastes on new plants.
And this has been the 14 position in John's branch for some.,_.
l, 1me.
/fo have not IS
.i."'equired this on existing plants, but with the increasing 16 concern over transportation and the ultimate storage of 17 these wastes, NMSS was very interested in having this.as 18 well as most resins.
COMMISSIONER GILINSKY:
The amounts of wastes are 20 very much larger here.
21 i',m. DENTON:
It seems that even these resins are 22 dried fairly well and shift in what we call Class B 23 containers, which provide a lot of protection, but at th3 24 same time, it seems like if we can move toward 2S solidification in the long term it would be one more prudent
/ 46f3 02 08 lcapBWH 22 thinJ to do.
C:-!AI!~MAN HcNDRIE:
It also se3rns to me that -- are 3
the levels in the reactor buildings substantially higher?
4
- '~R. COLLL~S:
As a comparison, the primary water
~
in the case of cgsium is about 200.
6
/~F{. DENTON~
About -five times hi*Jher.
CO:.PHSSIO,\\iER AHEMU~E~
I wonder if Bi 11 Dire Jes 8
could co~ment on this question 9 about ths solidification.
COMMISSIONER GILL'-ISKY1 Before he does that 9 could 10 I ask anoth::ir question., John?
If we wait a year 1 dqes that 11 mean, in effect~ that that wi 11 not.o:1pply to the 12 decontamination of -- of ths water in the auxiU.ary 13 buildin9?
14 I don't beli:'!ve that the public I~
interest would lie in waiting to solidify these wastes.
I 16 think *th-a risk in shipping the vacuum dried ones is very I,
smal.l.
It can be made sm3ller through solidification but I I '1 0
think continuing not to use EPICOR, to sit there with the I) water that has potential for human error or mechanical 20 failure, that might be released 9 when I weight those two 21 pros and cons 9 I would favor shipping the resins.
22 CO/,{MISSIOrffP. GILHIS;<Yi I understand, but as a 23 practical matter, does that mean 24 C:nt:\\ISSIONER AHEA:?NE:
If you started using EPICOR --
/468 02 09 kap!JWH L
4
'.:)
V I
8 y
10 11 12 L3 14 b
16 Ii 18 1 :-)
20 21 22 2 ")
- .J 2,.i 2::S 23 COi',H*,IISSIOii::R GIL-It'6KY:
This facility could handla IO, OJO qal10ns a day?
- -,*[~. COLLL-JS:
10,DOO a minute would be your optimum through-put, it would b9 more like three gallons a minute oecause you have change-outs.
COMi,1ISSID>lcF? GILL'lSKY:
As a.:Jractical matter 9 it would not apply to the decontamination of the water in the auxiliary building?
Mf?. DENTON:
Six months ago --
(Laughter.)
MH. DENTON:
been much further along.
I might have thought we would have CO~f.~USSIONER GILINSKYg Things may not move as fast as we think they will.
!,Ft. DEi{fO,>l:
It s*eems like we have got so much contaminated water up there that CO MMI SS I ONcF? AHEARNE:
If it does perform at the rste at which it is piedicted --
MR. DENTON:
It seems to me that it wouldn-'t b3 a total waste of resources to have a solidification ~nit at least under _desi9n 9 and maybe by the time it is designed and the staff has reviewed it, we can reassess.
CO.'/i.\\HSSIONEf~ GILINSKY:
,11:i have g,::it all the water in t~e cont3inment 9 which is highly contaminated, and there is a lot more of it.
468 02 10 24
- '.H. COLLINSg Ylith resµ9ct to that, the 2
solidification process for treating high level waters in ths 3
reactor ouilding anJ ~rimary system, the licensee has be9n
~
advised to design into his clean-up system for thosa water,
~
a solidification process, and h9 has --
C0:,1/HSSIO:H:R KENNciJ"'{;
He has committed to do it.
I
- ,,IR. COLLL*ISt He has it under consideration.
I d
have not se~n his proposal yet, for his solidification *and 9
for his processing of those highly. cohtaminated -- we have*
IJ riot received the formal proposal.
11
'co:-.fMISS ro:*JEf? KENNEDY:
As to the i-<1ater in the 12
_containment ouitding~ not that in the aux building, but in 13 the containment building, he has been informed that he must 14 15 design into his system solidification processes?
!:U. COLLPJS:
That is correct.
1:5 ccH-rnrssro;*JER K:::NNEDY:
i-I~ has-not yet responded to 1,
thi3.
We d:> not Icnow 9 ther3fore, whether he is actually 18 doing ~tor whether he is going to argue ths matter, or Jy pro:eed.
,Ve don"t know.
Is that correct?
20 r,H. VOLLMER:
It is correct.
21 COW,HSSIONi.:R KENN;;:JY:
One more q*Jestion before W3
- 22.
CJO on.
As to the aux building water,* has he been inforrn1d 23 that there should be any consideration on his part of 24 2:S solidification'?
MK
- CO LL L~ S i No ~
146.J 0.2 11 25 CO,WHSSIOiH:f~ iCENNE:L.JY:
He has noL
!'IU" COLL I i*JS:
No.
3 4
COMMISSIONER KENNC:JYi Therefore, if I can b8 sure that I am clear on this, if we dBci~ed today that it was to
~
be done, it would be more than nine ~onths; is th3t 6
corr'.3 ct?
I
,'It?. COLLIJS:
That is a fair statement.
CO:,PHSSIO:-.IER KENNEUY~
-Nin1 months would be th3 Y
cas1 if, in fact, he was already committed to it.
IJ MR. DENTON t He has been aware for some ti me, many 11 months, that the st3ff has considered the question of 12 whether or !'"lot to require solidification of the EPICOR 13 material. T~e only application that we_have from him is the 14 ciesiqn of E?ICOR th:it doesn,.t include the S*:>lidification l_)
unit.
COMMISSirn\\JER AHEM?l~E~
There 1;1ould be no 1,
astonish~ent on his part?
Id COlvU!.ISSIDl*{EH GILHiS:<Y; l.Jasn't he asked to 19 evaluate this?
So, this isn't coming out like a bolt from 2:J the blue.
21 M,~. DENfOJ:
He did pre*para, a value impact 2~
assessment of solidifying these wastes, in which he 23 concluded it was unnecessary, ever, for the auxiliary 24 ouilding waste.
Gut I thin~ I would ex)ect that even the 2:J licensee will pro~ose solidification of waste from the
146D 02 I 2 26 cont:-dn:nent building 9 so he has been awaitinJ a Commission
~
decision on whether the wasts --
let-'s su;Jpose that we all --
he and we were faced with the S
possibility of there being no place to ship it unless it o
were solidified.
W~uld it still taka i year?
I MR. DEr,IfON:
Part of th8 pacinq item is us.
M~L COLLINS~
Yes, it is a engineerin(J lead time
)
on equip~9nt.
A solidification system isn't something you IJ go and buy off the shelf.
More often than not, they have to 1 i be Gustomized to fit the plant in which they are going to be l.2 inst3 lled.
J.J CHAIRMAN ~ENDRIE:
Is there going to be another 14 rouna of environ,11ental assessment, liti9ation, public jj 15 1 '
c: o m~n ~ n t s, r a v i e w s v e t al ?
COM,\\(ISSIONER GILI>!SKY:
Probably.
- CHAIRMAN HENORIEi If then3 is, I thin'-< I can Id saf~ly assure you that it will be at least a year.
IY COMMISSIONER GILir,/SKY; If,.,.,e started this some 2J time ago, the system would be ready now.
2]
CCEt'HSSICHER AHEAl?:'-IE:
Can we ask the general, 2i counsel's legal advice?
2.3 l.\\ i?.
13 IC j( ~'/I T :
I Ca n,. t s p 3 '3 !( f Or th P, 1 i t i q 3 n t s ' as 24 to w~eth~r ~n environmental ass8ss~9nt would be involved.
It is a ~atter th3t needs our research.
46~3 02 13 kap8\\-1H
.2
.3 i
.)
.)
27
- Ar
- 1.Ji r c k s
- C()M\\H~;s IOHEF? Bl?AD.=ORDi You have indicated that it is d9 finitely conte:np lated ti1a t the EP ICO!? system wi 11 proc1ss the water from the containment
- CHAI f-N,~AN HENDFH E ~
EP I CO:i-I I is contemplated at d
the time one is processing containment water through that oth8r system.
EPICOJ?-II is contemplated as a possible 10 polishing stage on the effluent fro~ the other prot~ssing l l syst8rn.
It could be used.
12 f3 14
)j DENTON:
~ith e defense in depth sort of outlook, I feel there are more potential ways to cle~n up any kinds of spills or leais.
I would like to see it 16 sitting there, re~dy to go
- Ii
. COMMISSIONER BFU\\D,..;ORD:
The solidification system 18 you are talking aoout for this other system has nothing to Jy do with EPICOR.
20 C~AIRMAN HENDRIE; I think it is too early, 21 oecause if y_ou kno~*, you are going to have to make a.
22 solidification system, solidify for that ~ontainment cleanup 23 syst1m, you might -- and also assum~ as you can get one in 20 plac~ for E?ICo~~-II, that mi*3ht influence your design of th~
liners, the bed S3t up for the containment proc~ssing
l-'168 02 I 4 kapBi'iH 28 syst~rn, so f')U coulJ have.a sinc;l0 solidifi.c-:i.tion unit that 3
- i you in f3ct go tr1rouqh E:PICCH *,-rhil0 the solidifye:r is b2in'.]
J built, and th8n the contain~ent watar goes through 3 6
diff3rent s1stem, that is not exactly clear ~hat exactly is I
goi~J to go tnrouqh the solidifyer.
]j I l 12 13 14
]j l i J,g
- 2) 21 23
468.03.1 29 Cr*fAI!-?/rfM,l HENDr?IE:~
My guess th.:it the solidifier
~
turns out to be sart of a sy,11bol for both systems.
3 CCFtHSSIONER KENNEOY: Is that 1,1hat is contemplated?
4 M,<. DENrOi,iE If it ls deciJeci they are to be
~
solidified as soon ~s practical, w~ would ask the licensee 6
for design and he would make those decisions ~bout wheth9r d
-J 10 I I I 2 13 14 f.)
Jj II 18 IY 20 21
- 22.
23 24 2:5 he wants to use it for both purposes or se~arate design.
It would oe up to him --
COMMIS::3IOrJER KENNEJY: He won"t reach that conclusion if he isn't instructed that it has to be for both.
- fiR. DENTON
- That's righL COMMISSIO>JER KENN.::DYr Or that there must oe something for eacho COMMISSICh~EF? GILI1~SKY: Is this so:nethinq that you hav~ thrown out as a suggestion to the licensee or something that you told the* licensee will be required for the clean-up of the cohtainment water because you believe that it is n~c9ssary for the protection of the public?
MR~ DENfON:
We have only one way of dealin9 formally:
That is orders and licensing conJitions.
lie ha.ve not formally communicated that requirement for solidification of the containment.
In all of the discussions that tne staff has had with their staff and planninJ their design, I think the staff has tried to indicate that if it didn't co~e in with solidification
1468.03.2 Gil 9sh 30 it probaDly woulJn't be approved.
2 Co;*.\\MISSICHEH GILVJS;<Yi The difference, you see, 3
bet~een the two cases is what -- the deqree of contamination 4
and the tim3 involved?
~
What leaJs you to take one position in one case and another
~
position in 8nother?
M,1. COLLL~S: In the case of the higher contaminat~d
,'3
- ,.rnt,er, there are two process methods that are b-9 ing on*
~
parallel efforts? that could probably be used to clean up 10 the reactor building water and the primary system water.
l l One is the demineralization system, *Nhich we planned to 12 be installeJ in one of the fuel pool~ submerged-in water as 13 aaditior1::ll shielding.
The other system v!Ould be an 14 evaporization syste~o l~
And on the evaporation system, we insist that th9 lG evaporator oottoms be solidified.
He has been told that l,
because the higher activity will go into the sludges in the 18 bott*'.)m of the evaporator.
We want those solidifiedo Vfa have 19 instructed him to put demins on higher activity waters that
- 20 should be factored into his design, his proposal to be 21 submitted to us.
22 COMMISSIONER AHEARNE: Is it correct to interpret 23 if you *,*,ant the evaporator route? he would have to have it 24 2j solidified?
If you want the deminer-:ilizer route --
Mi?. COLL Ii\\JS: Both.
1468003.3 l3i"I GI sh 31 COMMISSIOt*1ER GILINSi<Y: The difterenc-9 with the i
present case?
J
!-M?., COLLINS: Let m8 try to go oack, Commissioner, 4
and explain why it was never factored in.
'_)
fhis system was designed on an emerggncy ~odeo Shortly
~
aft9r the accident, we rec0Jniz3d that we would have a I
build-up of water in the containment building.
We knew the 3
activity levels in the auxiliary building over a period of J
time becaus9 of the leakage problem would build up.
10 There was not a system in that plant to handle the higher 11 activity.
fhe system was designed and started on construction 12
. shortly aftar the accident.
The solidification was not 13 designed into that system
- 14
. ~e expected to need that system in late April or late Jj May.
Unfortu0ately, due to othsr circumstances such as 16 litig~tions and environmental assessments, the operation has I,
been delayed.
1::3 C0,1.-HHSSIONER GILINSKY: t'lere they~ in fact, ready IJ to go?
If these legal questions hadn't come up -- yesterday, 2J you were mentioning that thsre was still need for training 21 and so on *.
MF?.
COLLIIS: I think the licensee could have oeen 23 ready to go by late May.
Had the system been necessary at 24 2J that time in the emergency mode, yes.
CCH,l),{ISSIOi,/ER KEl'lNEOY: If he was ready' in late May.
7468.03.4 BW 9sh 32 fhe 1uestion is:
Is he ready today'?
M,?. COLLL\\fS: If we had to operate that syste:n today 3
in 3 mode 9 3mer93ncy moda 9 we could operate that system 4
today.
COM:HSSio:,JER KENNEDY: E:ner-qency~
o M;-L COLL r:~s: Yes, on a normal o;Jer a-ting rn0de oy
/
the end of next week, he has committed that all of his items 8
necessary to run on normal operation will be completed,
~
including the training of oµerators.
10 COMMISSIONER Al-IEM<NE: Before we get. far afield from 11 the solidification, may I now get Mr. Dircks to comment?
He 12 should be well prepared at this stage.
13 14 MH. DIRCi<::3:
I am not as well prepared as I want to be.
But let me just say, ss you know, we have wanted IS solidification right from the beginning and we made that 16 known-back i~ June.
In vi~w of th3 urgency now, as I have been told, this 18 0rgency, Hacold and I have talked about it.
We have agreed 19 that we recommend with Harold that the resins could be 20 processed and shipped pending solidific::1tiono 21 However, I do think that we have a difference maybe in the 22 timing and the urgency in which the matter should be 23 approached.
~e had t6 have some.meetings with ~y staff and Harold's staff.
I sent the ;nemorandum to Harold yesterday where I thought we outlined the ba~is of an agreement.
We do
/468.03.5
/J;'*f gsh 33 hav~ some differences in timing.
It mi~ht oe worthwhile 2
C0M:-HSSI0>H:R KENN::DY:1 l1ihat is the nature of th3t
.3 diffe ren-:e?
4
- \\rn
- D I ~ C KS i O.-i th 3 t i mi n *J
- COl,!MISSIO:\\iER KENNC:DY~ i"ihat are we talkin'-J about --
~
years, weeks, months?
Mr?. DH?CKS:
- /e would like to see somethin-J placed d
in whate~er license mechanJsm is used in this case that would
)
prohibit th3 shipment of resins in unsolidified form in 9 say, IJ six months from now.
JI CO!liMISS I ONER KENNEJYg VJh:it I have heard right here, 12 that means six mo.nths from now, either EPICOR shuts down 13 or there is going to have to be some substantial interim 14 l:J 16 storage established because I u~dsrstood that they couldn't possibly be ready for a year.
M~. DIRCKS: ~ell, I guess that that is where we have I/
a differ~nc9.
I think it is a matter of how much urgencj you 18 dp~roach ths problem withe IJ M~. *DENTON: It seems that we have three choices --
- 20 is not solidify at all; the second was to --
21 COWHSSIONER KENNEDY: I didn't hear that from Bill *.
22 MR.
DENTO,: Theoretically -- there are lots of 23
~!ants giving resins today that are not bei~g s6lidified and 2+
it is larger than the emergency case here.
I don't want to single *out this unique situation when we are
146,3.03.6 34 lettinq oth.?r plant.s ship *unsolidifiGd resins today.
CO.',l.'HSS I ONER 13RADFORJ: Is the contamination of J
those resins comparable?
4 f.{R.
DENTOri: It could be, yeso
'.)
CO\\IMISSIOdER GILINSKYl And th2 qu3nti ties?
_:J
,'M?. DENTON:
We are making somethinq special out of som9thing that is not uniqu~.
~e could let this go without 8
solidification and require to hold it up until we solidify
':)
them all or the compromise position between us, that doesn't 10 meet either one but says in my view, let"s get on and require 11 solidification as soon as practical, and whether it is 12 six months or nine months 9 and then we solidify from there on 13 out.
14 I think it is a policy kind of decision that you need to I~
mak1 and tha staff can give you the pros and cons. ~e have 16 different interests.
I think our interest is protecting the I,
river and the public and the people in the plant from 18 possible spills and leaks in the water while it is there.
1~
Bill's interest is in protecting* the people from the 20 transportation on the waste and the ultimate storage.
And 21 there fore 22 23 2l-2j COMMISSIONER KENNEDY:
My interest is both.
,\\rn. DEi'ff01~ ~ And the public interest is oot h and you are weighing these two factors as fa where yciu want to i)roc eed.
146<3.03.i B,~
gsh 35 CO*\\C\\ISSIO:'*IER Ai*!EARNEi I think we have aln~sdy
- 2.
e stab l i shed t hat i f the EPIC O Fl sys t 8 m runs
.:1 n y w he re !1 e cff as 3
effi:iently as it is predicted to run~ that the water, exc~pt 4
for the in-lsakage 9 the water will ba completely cleaned up in c1 month :Jr two.
It will all have been cycled through.
5 fhen the question is, giv9n the cask availability, how long I
would it take to get those resins out?
- 3 J8hn?
--J MR. COLLI>!S: The turn-around time bebreen the site 10 and Richland has been running about 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> *. We figure a l l three-day 9 four-day turn-around time.
You could make about 12 two shipments a week if you had the casks.
13 CO\\-IMISSIO.\\/ER AHEA~?NEg Ho*11 long would it then take 14 to ship all of that resin out?
Jj 16 I '
MK. COLLI;~s: \\'le are anticipatin9 CCH!MISSICHER KENNEJY: T\\*to shipments a week?
M~. COLLINS: l'ie have been making a strip to Richland 18 in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
I'::>
COMMISSIONE:R KENNEDY: I don't see how you can make 20 two shipments a week.
21 Mt.'.l. COLLINS: All r.ight~
Your anticipated chan;:;e-out 22 would result in aoout 50 to 60 lin9rs.
23 CO.',PHSSio,,JER AHEA,?NE: S8 it would take about a year.
24 So the results woulJ b9 if 9verything o~erates as it is 2~
sup~osed to, about half of the material would have been shipped
1460.03.8 Bi'/
9sh 2_
3 4
36 in six months.
f'fr\\at Ls tho, maqic or the criteria for six months?
{~hy not three?
~hy not nine?
M~. DIRCKSg We are saying six months because it is
~
a tight sch3dule.
3ut we thought the need to get the thing 6
goin;i -- but at the sarn-:? time, now allow any room for laqging.
I Then we would like to see the six m~nths put in there so as 8
to allow'the solidification process to be installed
- COMMISSIOdER AHEAdNE: Is the six months based upon JO an estimate of how much of the unsolidif1ed you feel could.
ll be tolerated, or is it base.J upon an estimate of when the 12
. solidification facility ought to be able to be running?
I 3 14 15 W1
- D I RC KS : I t i s the l a t t e r
- I t i s our v i e w t hat we ~refer no unsolidified resins to be shipped.
COMMISSIONER AHEM?dE: I understanci that.
But your 15 point is that six months is oased upon -when you believe it I i could be running.
13 MR. DIRCKS~ Yes.
I:,,
COM!~HSSIOi"-rER AHEARNE: That disagrees fairly 20 substantially, then, with Harold.,s people's estimate of when 21 it could be running.
22 COMMISSIOi~ER GILINSKY~
y'Jhat is.the difficulty in 23 24 2j storing the resins until solidification is available?
rle went over that earlier, but I didn't fully understand it.
Suppose you operated EPICOR and then stored the products at
bY.l gsh 37 EPICOR and solidifL~d them when the facility was available for that?
3 JR. COLLINS~ The bi10,est µroblem is that the 4
facility, the design criteri8 that were approveJ by us had
~
a longevity of two years.
fhe additional _problem is the
,5 longer you :naintain snd hold those liners on-*site 9 there is
/
a p.'.)ssibility that you may have attRcl( on the meta.l just a
sitting there.
fhe best thing is to try to ship those resins off as quickly 10 as you can.
l I CHAIRMAN HENDRIE: Even at that, we are a whale of 12
. a lot better off _with the fission products locked up in the 13 resins in those lin9r tacks in storaJe pits on the site than 14 in the wate.r sitting in the pipes and tankQ*:;:ie in the auxiliary Jj building anJ around the plant.
16 I think it is two orders of magnitude difference in the 11 puolic risk.
lB COMMISSIC)iffR AHEARNE& I W3s tryin;i to get at that.
I~
We seem to have two segments of thA staff that have a factor 2J of two diffarence in how long it will take to build something.
21
\\u:?. DIRCKS: Two points.
One, we agree with Harold 22 that we don~t want to singl9 out this one plant.
We are wor~ini witn NRl to encourage solidification of all resins.
Second, I Juess six months is very stringent.
However, over 2j the past five months~ we haven't seen too much activity in
i468.03.l0
,2 3
-r
- )
5 38 this area.
fherefor3 9
we think that we wouldn't want to see it b9 put in a low priority item to move toward ~0lidification.
W9 have not se9n the attention oeing given to solidification that we would hav9 liked to have s,~en.
COM,\\HSSIOiH:R AHEldNE: But this is the auestion of an engineering design and then a construction.
6 So there ought to be, I would havq thouJht, some narrowing J
down -- I can recognize that there would be some uncertainty, 10 but a factor 2 difference seems to be very large.
11
\\-h?. DIRCKS~ It is a difference in view.
/-le think it 12 is ~robaoly Jo-able in 6 months if you give it the priority 13 attention that it deserves.
14 co;*,\\MISSICL-iER GILINS:(Y: Suppose the estirnat'e were l:3 off by a fe*.-1 months.
It would simply mean that you would 15 store*the resins for several months longer and process them I/
at that point.
1:3 COMMISS!Oi~ER AHEARNE: But the question comes, if 19 you have the storage capacity on-site for the resins anj 2:J you are com.:iitted -
you thin'.< it is really ess8ntial to 21 at some point to solidify, then the question co~es -~ Why not 22 just store it until solidification?
23 CO:'.hlISSIOi"i:::R GILINSKYg Go.'.)d point.
2-t 2::i CO',fHSSIO,H:R AHEAH,\\JE: If, for exa:nple, it is two years versus a year, then it probably is significant.
1468.03.11 otV gsh 39 Mt~.
DPJTOi~z I guess that is an option we* have 2
considered.
Ihe only thing mitigating against it is soma 3
feeling we are turning reactors into disposal sites.
4 fhere is an increasing lack of waste for low level,
~
intermediate~ and hiJh level spent fuel wajte.
COM\\llSSIOi*JER GILVJSKY: -It see:ns there is little incentiv9 for the licensee to g9t moving on this project r~
because if EPICOR is going to run, it runs 85 desgined -- that Y
~hase of it will oe over in a few months.
10 C0~,1:.-[ISSIONER KENNE:OY~ And come bacl< to th~ point 11 that we made earlier.
He hasn't been given any incentive 12..
to :nove on this project as far as the aux building 1-,rater in 13 the first place.
14 l:J So if we want him to do that, somehow or other h~ hss got to tY:i told ab::n,t it.
Up until now :-ie h3sn-'t9 and th-3.t isn't 16 his fault.
He hasn't been told to, nor have we suggested that 1,
he shoulci.
13 CO:,fr.HSSIONER BRADFORD:; Do we 1<now how long Richland IY is closed for?
2J MR. DIRCKS; No, we don't know.
I heard on the 21 radio that it was closed temporarily.
I think there is a good 22 deal of confusion aoout how long it may stay closed.
It was 23 clos3d over a liquid item 9 out was not related to resins.
24 2.)
.'.U. DE>JfON: Was the package that 19 d to the closing at ~ichland Class B?
.1468.03.12 40 i3t'i gsh CO-'..f.\\USS IO:-iER GIL L,!SKY:
I
':ta s inforr:ia.d it ';','oS not 2
anything th3t was rAgulated oy the ~qc.
3 COM:1iISSIO.H:R AHE/\\;:/l*JE: Proodbly tv10 of the pack:aqes wen~ not.
-:J COMMISSlOrH:R GILL"J:3'.\\Y: This~ a9ai:1, is just -
- 5 COMMISSI~Hf::R i(ENN~:OY: Can I shift to:., different I
suojact?
- 3 fhe assessment referred to processing to prR-determineJ
"-:l lev~ls -- tne only..Jif.ficulty with that is it didn.,t say what 10 the pre-determined level is.
A? h3ve we decided what the 11
- ire-determined level is?
B, if that is the case, will tnat 12 oe included in the technical specifications?
And then C, 13 will that be a matter, then, which has to be considered in 14 another assessment and another review and comment pariod?
I ::i
\\U. COLLINSg The :rnswer to your last question is 16 yes, it would be included.
It woulu be part of the I,
discussion in the second environmental assessment on the 18 distributio~ of the watar.
Yes 9 it would be includ1d in the 19 technical specifications.
2:J fhe language that appears here is the normal staff language 21 because that number, that pre-determined number, is set ~)ased 22 on his dilution and his out-form numbers and is set in the*
23 technical soecifications.
24 In esse*1c:~, wh3t h9 is going to :neet is the co,:imission-'s 2~
Appendix I regulations for aischarge from the plant.
/468.03.13 IY1i qsh J
4 41 COM.'HSS IO:ER r(E:,lN~Jyg That is the pre-dc'.!t~rmin~d TJ1e actual n umt:;er at ti1a t release poi~t cannot b8 set at this tim3 until ~e ~now the
- )
oth?-r-pararn*.:?ters.
It can b8 set as soon e.s
- ,e knot*/ th8
~
volLlme of flow out of the discharge pipa, the amount of I
service wat3r dilution flow.
That w-:-)uld be set at that ti,m.
It is part of his tech spec.
Ii 12 Every tech spec has it.
CO MM ISSI ONER Bi~.AD.:ORO: You set standards for the systems after it is operated a while.
1\\'iR. COLLINS: \\'ie don"t set the standards on the l'3 system.
Thare are no t9chnical specifj_cations that 1*equire lj
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20 21 23 25 3 p1rticular system to have a particular dscontAmin3tion.
r,:F?.
DENfcU: Th0 st~ndards are downstream dose. I think what John is saying, if this system is ap~rovad anJ then you know what volumes and flow rates are, his staff.would calculate the specific limits for concentrations at the point of discharg~ and put those in the tech specs.
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25 42 MR. COLLINS:
That is correct.
MR. DENTON:
If they were set prior to operation, and in fact I mentioned you could infer what they are now.
The Licensee has no doubt already done that calculation because we have specified in reg guides how we establish what the
- numbers are.
COMMISSIONER BRADFORD:
That is a phrase that appears in other places, the predetermined values.
It has troubled several of the commenters, the set points on particular instru-ments, what have you.
MR. DENTON:
The intent of this Staff is that we would appoint Appendix I as the base for holding the radiation standard.
I could see some controls below that point and sup-plementing our normal controls to be sure that no releases were made without maybe duplicate samples between the state, the city, and ourselves, or whatever it might take to assure every-one that what was being released met those types of standard.
Appendix I, plus additional conservatisms?
MR. DENTON:
Yes.
MR. VOLLMER:
It would depend on the ultimate disposition of the water.
CHAIRMAN HENDRIE:
Appendix I is a pretty conserva-tive standard.
If you apply, for instance, the Environmental Protection Agency Guidelines, you can go up a factor of 4 or 5.
MR. COLLINS:
For the real individual, that is an
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25 43 annual average for the uranium fuel cycle.
That is 25 millirem from all sources; where the Appendix I is specific to both --
CHAIRMAN HENDRIE:
You have to reserve a piece of that for other portions of the cycle or other operations.
MR. COLLINS:
That is correct.
CHAIRMAN HENDRIE:
I suppose you can make a good case that the federal regulations would allow release at levels of
-- up substantially from Appendix I.
I *think if we can get down inside Appendix I, that -- I think that is a desirable thing to do.
It puts this rather extraordinary recovery opera-tion back within the radioactive release limits for uncontamin-ated, normally operated plants, which I think is a very con-servative and very useful thing to do.
MR.. COLLINS:
It can be achieveo.
CHAIRMAN HENDRIE:
Now, are there questions at the moment?
COMMISSIONER AHEARNE:
No.
Onward.
CHAIRMAN*HENDRIE:
Let me propose the following to you.
The paper -- a couple of the papers came up -- one of them came yesterday.
My understanding is that you would be interested in having a chance to look at it.
COMMISSIONER AHEARNE:
And OGC.
CHAIRMAN HENDRIE:
I was going to go on to that.
There are some other questions that we ought to have a chance
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25 44 to understand.
I would like to have from the Counsel's Office an assessment of the various options for Commission action.
And inevitably, since we are under -- we are being sued in this matter anyway, there is litigation risk, greater or lesser, in each of these options.
And I would like an opportunity to know from the Counsel's Office how they assess all of this.
I think it might be useful for us to have that iP mind.
What I am getting around to proposing is that we ask the counsel for that -- to prepare an analysis of that set of options which he tells*me he doesn't have ready to go at the moment.
And we will meet again as soon as -- consider.those as soon as he can get them up, which I would expect would not be later than next week.
COMMISSIONER AHEARNE:
What I would particularly like General Counsel to address is the argument raised quite strongly, by at least the Susquehanna people, is can one separ-ate steps in.the overall decontamination treatment.
In other words, is it appropriate to look at EPICOR in isolation.
MR. DENTON:
I guess I do need some direction as to potential use of Unit 1 for storaqe; that if we progress down the number of available storage --
CHAIRMAN 3ENDPIE:
I expect to have the Commission decision before that becomes necessary.
The current estimate is end of October.
COMMISSIONER AHEARNE:
The decision*would have to be
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9 10 11 12 13 14 15 16 17 18 19 45 made sooner than that.
It is not just one little switch that you suddenly flip.
COMMISSIONER KENNEDY:
Meanwhile, those tanks are not being used for other purposes at this point.
MR. VOLLMER:
Unit 1 tanks.
MR. COLLINS:
Part of the -- one of three bleed tanks is being used for borated water.
Two others are available.
COMMISSIONER GILINSKY:
They have to be held avail-able in any case because li~htning could strike at the core, too, and the Unit 1 tanks are safety CHAIRMAN HENRIE:
Are part of it.
Ttere is apparent apparently other tankage around.
capacity What about the Unit 2; is it bleed tanks?
HR. COLLINS:
They are filled.
MR. VOLLMER:
The only other* available storage CH~IRMAN HENDRIE:
You pump those up.
MR. COLLINS:
The bleed tanks have been filled.
CHAIRMAN HENDRIE:
What is* the name at Unit - 2 of the 20 tank that you hang on when you run the ECCS, and it has got a 21 million gallons in it or something like that?
22 23 24 MR. VOLLMER:
_The borated water storage tank.
CHAIRMAN HENDRIE:
What is in the borated water storage tank for Unit 2?
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25 MR. COLLINS:
Borated water.
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25 MR. COLLINS:
Borated water.
I don't really know the exact capacity that is in there at the present time.
CHAIRMAN HENDRIE:
That is plain water, except for the boron.
MR. DENTON:
Right.
46 MR. ARNOLD:
I am Senior Vice President of Metropoli-tan Edison Company.
The borated water tank is essentially full, as is common with these tanks, because they reveive water back from the systems and are not only made up to with fresh'water; the tank is c9ntaminated such that it would have to be processed before it could be discharged.
Perhaps I could clarify one other point with regard
- to solidification.. The company has included in the design of the system for the cleanup of the containment building water the __ equipment and systems necessary for solidification.
The design approaches that appear to be feasible for that,purpose would not -- maybe not feasible, but most desirable, would not be able to be used in common with EPICO~-II resins.
EPICOR-II resins would require completely new types of facilities and would undoubtedly involve transfer of the resins and all of that, the implications of that, in order to solidify the present design of the EPICOR-II resin containers, was not set up on the basis that we would be solidifying within those containers.
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25 CHAIRMAN HENDRIE:
Thank you.
That was a helpful clarification.
I thought I had located 1 million gallons of storage there.
COMMISSIONER AHEARNE:
You did, but it is full.
CHAIRMAN HENDRIE:
Not free; too bad.
COMMISSION AHEARNE:
When do they have to know.
That's the point.
When do they really need a decision?
CHAIRMAN HENDRIE:
I would like to know what direction you are going now~
MR. VOLLMER:
The Licensee requested last week by letter that we consider an alternative interim decision, say 60,000-gallon authorization, October 15th.
As was indicated in the letter to --
CHAIRM..~N HENDRIE:
60,000 gallons to do what?
MR. *voLLMER:
To process through EPICOR up to 60,0.00 gallons.
Presumably that would be taking the lowest activity water to provide a little more --
COMMISSIONER AHEARNE:
Interim decision.
MR. VOLLMER:
We have not acted on that.
47 In response to Senator Hart's letter, I think we indicated the end of October was the most likely point of reaching the limit in the available storage which either then goes to the use of EPICOR or pr<;:>cessing by EPICOR or going to TMI-1 tankage.
Or another alternative which has been discussed is
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9 10 11 12 13 48 that of putting it back into the containment building.
I think we would like to look at that one in great detail, because there are some real substantial problems with doing that.
That was one option proposed or at least discussed in'*the I,icensee's letter.
We feel that we don't have the kind of margin we would want in the containment building.
We are close, in a manner of speaking, to some of the Valves that are critical for long-term assurance of safe operation and things of that nature.
So I would tend to discount that one almost out of hand.
As we.* touch the pipes, and I think we are very close to touching some of the lower portions, you affect the cool-14
- ability.
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25 water, so it would likely affect your natural circulation ability.
The other thing is in another 100,000 gallons or so, you are maybe running into some electrical components which control the decay heat valves.
CHAIRMAN HENDR!E:
What is the total input to the contaminated water volume?
MR~ VOLLMER:
About 500 gallons a day, and you have about 70,000 gallons a foot.
CHAIRMAN HENDRIE:
If one were looking for a few weeks, rather than a long-term choice of what to do, at this
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25 point one could certainly consider turning it back into the containment building.
49 MR. VOLLMER:
But I would hate to put it in without some assurance that it can be extracted again, because if you look in the long-term *.and you add up the 500 gallons a day, certainly that water level will rise until we come to grips with a way of getting that out.
CHAIRMAN HENDRIE:
We calculat,ed when we fill the containment?
MR. VOLLMER:. No, sir.
CHAIRMAN HENDRIE:
The answer with regard to Unit 1 tankage is, I think, anything which doesn't begin to fix the fission products into a medium in which those products are considerably less mobile than they are now in water, wherever it is stored, is a lousy solution compared to (inaudible).
MR. VOLLMER:
Totally agreed.
CHAIRMAN HENDRIE:
So I think it is clear where the health and the safety momentum drives us.
Now, the question:
Do we have to use some Unit 1 tankage? -- is a process of getting this decision machinery somehow cranked up and moving.
And all I can say is, if that is what it takes to keep the contaminated stuff out of the Susquehanna, that is what we'll have to happen~
Okay?
I think that is as good as guidance as I can provide.
J. 1 9
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50 COMMISSIONER BRADFORD:
Would it be possible to have 2
by the next meeting a response to the specific points made in 3
- the three or four letters that contain technical comments?
4 5
6 7
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. VOLLMER:
We could respond to them point by point.
COMMISSIONER BRADFORD:
We normally would, I take it.
MR. VOLLMER:
Some of them, as you probably know, go into areas *that are extremely detailed, *and in some cases even extremely hyp*othetical.
We try to do as we would normally do in the safety evaluation report or environmental assessment, looking a:t some of the bounding cases, and not get into very into details, aB was called for here.
I think to address in a responsive manner all of the questions that were *received, I see that is an effort that would re*quire well in excess of a month by a substantial num-ber* of people.
On the other hand, if can extract and provide generic responses, and try to hit some of the more succinct technical questions that were asked, I think we can -- we have iooked at them all very careful, and I think we. can try to come up with
-- I am not sure what Mr. Bickwit is anticipating for the next meeting, but we should try to come up with something in the very near future.
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COMMISSIONER BRADFORD:
In some cases they request no more than discussion of other radionuclides that will be 25
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MR. VOLLMER:
Those things we can certainly do.
In some cases. they are already provided; and where they aren't, we can certainly provide them; yes.
CHAIRMAN HENDRIE:
I would look for some coverag:e on
'that sort of basis sort of basis then.
MR. VOLLMER:
We have tried to provide a generic discussion of the comments, and that is.what was provided with this package.
We can go into another level.
COMMISSIONER*BRADFORD:
To the-extent that you can, I would like to make up specific answers with specific*comment comments.
MR. COLLINS:
Let me reiterate some of my concerns again about the transfer of any of this water over to Unit 1, I totally agreed with what you said about not moving that water fromUnit -- moving it from Unit 2 tG 1 creates a prob-lem.
It creates a number of problems.
It now takes radio-activity levels that are in the auxiliary building which are much higher than we have normally anticipated in an operating plant transferred to a plant that does not have those activity levels, contaminates piping systems, which is going to be very hard £or us as an agency to demonstrate --
CHAIRMAN HENDRIE:
I understand, John, it is like a case of poison ivy.
Every time you scratch it then run your back, you got a new patch.
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25 MR. COLLINS:
That is all the mor~ reason why we should proceed to make a decision on the --
52
.. CHAIRMAN HENDRIE:
You can hardly find. a guy in this room who is more anxious to make a decision than I, but I am also an expert in this machine here.
COMMISSIONER GILINSKY:
The question is:
Do we have the right system for decontaminating that water***and dealing with the products of that decontamination.
MR.. DENTON:
I see it somewhat like we discussed the other day on the radio-network from plants. *There may be a
\\
possibility if we started all over again; six ~onths ago we could have designed a better system, Certainly this system will. do the job.
Maybe_ there is, in retrospect, 10 percent improvements here or there if we had done it differently.
I am confi9-ent it will. do the job of gettin*g down to the Appendix I lev~ls.
I don't see a need to further refine the system.
I think striving for the last improvements just aren't wise.
COMMISSIONER GILINSKY:
I was trying-to say that we are not just dealing with legal niceti~s; we are trying to decide what the right way to deal with this water is and what the right way to deal with the products of the contaminated projects is.
MR. COLLINS:
I take it you have reservations as to*
the effectiveness of the demineralizer to remove radioactivity from water; is that your concern?
This is a well-proven
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25 53 procedure.
COMMISSIONER GILINSKY:
My question is on what to do with the resin that comes out of the process.
CHAIRMAN HENDRIE:
The main question before the house, aside from the fact that there are questions about~- on the legal side, do we set it up this way or that way or the other way?
And what the various risks?
Those are matters that the Commission ought to have a chance to chew on its legal possibilitiei of risks in private, I would think, but sort of the technical side iss~e that comes down -- the policy side issue,I guess would be better, that comes down is authorizing to go into storage and wait for the solidification system to be 1 I
put in place and then will be pulled back out of storage, then run through solidification, then shifted the solidified stock; or should you be able to ship at least --
MR. COLLINS:* But the water does not foreclose an option.
COMMISSIONER GILINSKY:
I would like to be clear on that.
MR. COLLINS:
Those resins can be solidified.
COMMISSION BRADFORD:
The point was raised in several comments that it isn't entirely clear in this situation that the Staff role is such that it permits them to impartially review the proposal before us.
In peformeing the environmental assessment, can you comment on the extent to which the Staff
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25 members were involved in the design of this facility?
Do we have a different r~lationship to EPICOR than we do to a reactor we license?
54 MR. DENTON:
It is a somewhat different relationship, because we embarked on this under the emergy conditions as_ they existed early_on.
I think our motivation is still unchanged; it is still to protect-the public health and. safety.
And we saw it with the treatment of the water.*
Now, other members who live downstream of the plant don't see that as their interest.
Perhaps to move -- they see it as a first step for ultimate release in the water.
I don't know whether our extent of involvement in meetings has been any different than.the.normal case.
It certainly was, early o,n, in those.first months when we were urging them to build this thing.back during the summer.
MR. VOLLMER:
I-n a lot of respects it has been much closer, more detailed involvement than we would normally see.
As Harold said, in the early stages of the acciderit, we were foreeeeing_the running out of any space for storage of water.:
in a very short time.
Fortunately, most of those sources were MR. GOSSICK:
The Staff wasn't really involved in the design as such.
This is an off-the-shelf system.
MR. COLLINS:
No, it was designed specifically the process is off this
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25 55 MR. VOLLMER:
The shielding and those things were
- designed,
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25 56 MR. DENTON:
If the licensee doesn't propose anything get on I
we don't license, *Here I think we have urged them to with some design that would accomplish this function.
serise, it has been different than our normal approach.
In that MR. COLLINS:
It was designed in accordance with the staff guidance contained in this reg guide.
During the early period, I participated personally-in those design review meetings, as if it were any license.
They would have to meet our design requirements*.
That was done.
COMMISSIONER AHEARNE:
Part of the nagging concern I. have is --- i.and. it. is a little different from Vic Is, al though it might be the same..
I am not using the words "what is the right thing to do," but rather, what is sufficient and adequate.
"Right" might carry some sense of the absolute best.
I am not sure whether that is what I am trying to strive for.
What I am a little concerned about is any flavor that says, now we must immediately make a decision, in the sense that back in April we really had to quickly make a decision on what system ought to be designed.
All of us share the responsibility.
It is not equally distributed, perhaps, but all of us participated in the fact that it has now taken until October to get to this stage.
But somewhat the concept that, had we known earlier, that we would have done it in a more complete fashion, makes
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25 me just hesitate a little bit to think, maybe if the urgency isn't still -- and' that is one of my reasons why I want to
~hink a iittle bit.
MR. COLLINS:
Could I address that?
When we met with the licensee and discussed in the early stages the alternative methods for treating that waste, it was not done in haste.
There was thoughtful consideration, both on his par~ and o~r part, as to the type of sy~tem to be used.
Evaporation was the other alternative system.
Now, you concentrate these materials and you are dealing with much higher acitivity.
57 COMMISSIONER AHEARNE:
I am addressing the solidifi-cation issue.
- MR. DENTON:
It has been taking on increasing priority within the. Commission all summer long, and that is the.right one to decide for that 1s -- maybe you would like a briefing by NMSS on the solidification system as a separate matter.
It wasn't a big priority in my book six months ago.
MR. COLLINS:
But even in the early discussions on the selection of the process system, solification was discussed.
It was at that time my*guidance particularly, because it was my responsibility, that using vacuum dewatering, putting in thick steel liners with Type B casks, was more than adequate.
And that was the guidance that was given to
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25 58 the utility.
MR. DENTON:
But getting back to the general urgency,1*
there is a feeling in NRC employees at the site that it is increasingly difficult for them to provide the kind of oversigh and assurance in this area, in view of the mounting problems with the accumulation of water.
I think John has reflected some of this.
I think it is shared, John, bi the other people I have talked to at the site. It is not a unique situation.
It is really hol~ing us up from reducing the activity levels, providing* an environment in the auxiliary building, the fuel-h~ndling building, that we don't have to in the mode we are right now.
It is a veri cautious step by step.
We are not able ~o gei into many of the areas1that we wotild like to get into, even since the ~ccident, because 6f the reactivity levels.
We are not going to be able to continue decontamina-tion in those areas until we clean up the water.
We have to remove the water.
MR. DENTON:
It would provide access in terms of tomorrow' problem if we had a little bit of access --
COMMISSIONER BRADFORD:
If the -- if Met Ed is operating EPICOR in the principle of the lowest activity first, that isn't entirely consistent with getting your buildings cleaned.
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25 MR. COLLINS:
Eventually.
COMMISSIONER BRADFORD:
But it would be months off, then, before the higher activity water would be treated.
It isn't as though beginning now is gping to solve that problem within the next couple of weeks.
MR. *COLLINS:
No, but on the next couple of months it certainly will, and the longer you sit there the greater pot~ntial ~ou have.
COMMISSIONER BRADFORD:
That depends on how well EPICOR runs, I understand.
But there iin't A complete mesh between starting to deal with the water and immediately being able to go into other parts df the building.
MR. COLLINS:
I have all ihe confidence in the world that EPICOR will do the job it is designed to do.
It is one system that we know quite a bit about.
COMMISSIONER BRADFORD:
Haven't the estimates varied frdm three to ten gallons a minute?
MR. CbLLINS:
Ten gallons per minute is if I start out today I can process ten gallons per minute input ~hrough that thing.
I have to stop some period of time, because I know I have to take out the resins.
So the average through-put considering down time to replace the resins over a long period of time, would be an input and.a through-put of three gallons a minute.
The through-put still remains the same.
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25 COMMISSIONER GILINSKY:
Let me ask you one point:
Do the resins are they replaced at a fixed level of conta-rnination or does the contamination of the resins reflect the contamination of water?
MR. COLLINS:
The resins will be exhausted on radiation.
TSat number has been fixed to coincide with the shielding requirements on the tasks, the transfer belt.
On normal operating plants, more often than not somebody decides that maybe once a month or every six months is a good time to change them.
That is bhe normal process.
This plant has a specification that says when it.
reaches that activity level that is when you dispose of that resin.
COMMISSIONER GILINSKY:
So all of the resin will have the same activity level?
MR. COLLINS:
Will have no more than that.
CHAIRMAN HENDRIE:
Len, will you crank your people up, please, to look into this matter, and have that ready as soon as you reasonably can?
And we can examine it with the Secretary and see how soon we can schedule it. It will be next week.
All right.
Thank you very much.
(Whereupon, at 11:10 a.m., the meeting was adjourned.