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 RADIOACTIVEL Y CONTAMI NATED WATER AT TMI & RELATED SUBJECTS (EPICOR II )
Place - Washington, D. C.
Date - Thursday, 4 October 1979 Pages 1-60 Telephone:
(202 ) 347-3700 ACE - FEDERAL REPORTERS, INC.
Official Reporten 444 North Capitol Street Washington, D.C.20001 NAT10NW1DE COVERAGE* DAILY
1 CR746 8 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.
I I
2 CR746 8 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
PUBLIC MEETING 4
DISCUSSION OF RADIOACTIVELY CONTAMINATED WATER 5
AT TMI & RELATED SUBJECTS (EPICOR II) 6 7 Room 1130 1717 H Street, N. W.
a Washington, D. C.
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.
20 21 22 23 24 Ace-Federal Reporters, Inc, 25
CR 7468 3 WHITLOCK t-1 mte 1 P R O C E E D I N G S 2 CHAIRMAN HENDRIE: Let's get started.
3 The Commission meets this morning for a discussion 4 with the staff on contaminated water matters at Three Mile 5 Island and related subjects, the EPICOR-II system and so on.
6 The first item of business that we ought to bring up is for 7 me to ask my colleagues to join me in voting to hold a meeting 8 on less than* one week's notice on this subject this morning.
9 Those in favor?
10 (A chorus of'ayes.)
11 CHAIRMAN HENDRIE: So ordered.
12 I guess the best introduction could be provided by 13 those across the table. Please go ahead.
14 MR. GOSSICK: Mr. Denton~ill introduce the subject.
15 MR. DENTON: I sat down late last night with the 16 Commission paper on the use of EPICOR-II for processing the 17 water. Dick .Vollmer has a detailed presentation. I think 18 the best way to proceed is to let him discuss the issues that 19 need resolution.
20 We have concluded that the use of EPICOR does not 21 require preparation of an environmental impact statement. It 22 deals only with the use of EPICOR. We are preparing an 23 environmental assessment on the disposition of the water that 24 would be produced by EPICOR. Therefore, in our conclusions Ace-Federal Reporters, Inc.
25 regarding the lack of need for a formal environmental statement
mte 2 4 on EPICOR itself, we are recommending that the use of EPICOR-II 2 be authorized by the Commission.
3 Dick, why don't you discuss this specifically?
4 MR. VOLLMER: Okay. There appear to be ~hree major 5 issues revolving around the use of EPICOR-I. On the first 6 slide these are indicated.
7 The first is to the adequacy of the environmental 8 assessment.
9 (Slide.)
10 The environmental assessment, as you know, was 11 prepared in response to the Commission's May 25th statement, 12 and was put out for public comment on August 20th of this
- 13 14 15 year. And a number of comments were received, both technical and otherwise, in response to that environmental assessment.
I will discuss that one.
16 But, for completeness, I recall, I want to point 17 out to you that the fact that there still is a need for 18 consideration, as brought up prior to this, whether or not a 19 construction permit is needed for the -- as it turns out, 20 already completed EPICOR-II facility.
21 And, thirdly, as to whether or not an amendment is
- 22 23 24 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 Ace-Federal Reporters, Inc.
25 are normally part of technical specifications* and are
mte 3 5 normally identified in the technical specifications. So, 2 since the EPICOR facility does have such an effluent monitor, 3 it would likely need to be part of the technical specifications 4 although the facility itself and the operation itself would 5 not normally be part of the technical specifications.
6 As far as the adequacy of the environmental assess-7 ment and the response of the public to the August 20th 8 Federal Register notice, we received about 40 comments. 36 9 of these I characterized as es:pressions of opinion. Many of 10 these were expressions that they did not want any water dis-ll charged, did not want any krypton gas released, which were 12 really not part of the scope of the environmental assessment.
- 13 14 15 But many of these, inherently or explicitly didn't say they wanted EPICOR operated.
35 of these were expressions against the use of 16 EPICOR. One of these was an expression for the use of EPICOR.
17 There were four other commenters that provided more substan-18 tive comment.
19 COMMISSIONER GILINSKY: Could I stop you for a 20 moment. Did those who objected to the use of EPICOR suggest 21 alternatives?
- 22 23 24 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 Ace-Federal Reporters, Inc.
25 of detail.
mte 4 6 CO.MMISSIONER AHEARNE: From the standpoint of 2 arguing that we should have evaluated the alternative to a 3 greater extent, as opposed to saying evaluate --
4 MR. VOLLMER: The more substantive commenters, three 5 were received that were opposed to the use of EPICOR: the 6 City of Lancaster, Susquehanna Valley Alliance, and two 7 profess~rs from Franklin and Marshall College. One of the 8 cornmenters, the Commonwealth of Pennsylvania, had some technica 9 comments and was in favor of the use of EPICOR for processing 10 of this water.
11 COMMISSIONER AHEARNE: Did Met Ed respond?
12 MR. VOLLMER: No, we did not get a response from
- 13 14 15 Met Ed.
Other agencies -- I understand that in the last couple of days we got a response from HEW that had some 16 technical comments. But I guess we characterize this as in 17 favor of the use. EPA was given copies, CEQ, and they did 18 not*respond.
19 Next I would like to briefly run through the system, 20 and then I would like to describe what the major issues were 21 raised by the comments, both from the issue point and from
- 22 23 24 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 Ace-Federal Reporters, Inc.
25 with respect to the EPICOR building that was part of the
mte 5 7 original cdnstruction of the plant.
2 (Slide.)
3 And in relation to the auxiliary building, the 4 reactor building, and the fuel-handling building. The 5 fuel-handling building, of course, contains the temporary 6 storage tanks that were constructed and placed in the fuel 7 rool for Unit 2 to provide additional stcrage capacity.
8 COMMISSIONER GILINSKY: Are you going to go through 9 the slides at some point?
10 MR. COLLINS~ Yes.
11 The next slide very briefly shows you the concentra-12 tions expected to be processed through the EPICOR system.
- 13 14 These are probably the maximums that are contained principally in the react6r coolant bleed tanks. Many of the.other tanks 15 have lower concentrations than that. But just to give you an 16 idea of the type of activity levels that we are talking about, 17 with their expected half-lives.
18 COMMISSIONER AHEARNE: You have assumed levels.
19 MR. COLLINS: These numbers have fluctuat~d, because 20 many of the tanks have been topped off with other water that 21 has diluted them down. We have not made it a requirement on
- 22 23 24 Met Ed that they continually measure the concentration in those tanks, because ~f the problem of increased exposure to the operators.
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25 Of course, prior to processing any of the water,
mte 6 8 each one of those tanks will be sampled for its radioactivity 2 and its chemical content, prior to the prcessing, so that we 3 know for sure what those concentrations will be.
4 These are the principal isotopes that we will be 5 dealing with, in that order of magnitude.
6 MR. SNYDER: Are there any of these tanks in which 7 the water is of significantly lower activity than some? Has 8 there been an attempt to segregate on that basis?
9 MR. COLLINS: I think I indicated that there are 10 tanks with lower activity levels in them. What I tried to 11 depict in this slide is that this is the activity one would 12 expect to see in the bleed tank, which contains the highest
- 13 14 15 activity.
MR. SNYDER: The worst case?
MR. COLLINS: Yes. Many tanks would have activity 16 lower, but still above what one would expect to see in a 17 normal operating reactor.
18 MR. SNYDER: There is the possibility, if_ the system 19 were operate~ to run the lower activity through first.
20 MR. COLLINS: That would be the proposed plan, as 21 Met Ed has described it to us, that they would handle lower
- 22 23 24 activity tanks-first, processing that water, and then get on with the higher activity.
I think the next slide is probably the most signifi-Ace-Federal Reporters, Inc.
25 cant slide.
mte 7 9 (Slide .1).
2 It is a block diagram of what the EPICOR process 3 consists of. And you can see on the left-hand side it shows 4 the auxiliary building tanks,.the contaminated storage tanks 5 and temporary storage tanks, and they feed into a series of 6 piping systems into the first stage of the EPICOR, which is 7 a pre-filter, which iri this case is a demineralizer . . It 8 then is processed through a second demineralized bed, another 9 catalyst to remove principally the cesiu~, and then the third 10 bed, the second demineralizer, is a mixed-bed demineralizer.
11
-The water is then taken back to the clean water 12 receiving tank, where it is then sampled. If it meets the 13 requirements for either reuse or discharge, it could then be 14 pump~d over to their concentrated or their waste evaporator 15 condensate test tanks, where it would be sampled prior to 16 release or recycle back into the plant.
17 If the water do~s not meet discharge or reuse 18 requirements, then it would be pumped back to the-~ referred 19 to as the off-spec batch tank, and then recycled through the 20 EPICOR system.
21 COMMISSIONER BRADFORD: "Off-spec" means contami-22 nated?
23 MR. COLLINS: That it is higher than the requirements 24 placed on the water for either discharge to the Susquehanna Ace-Federal Reporters, Inc.
25 or for reuse in the plant, both chemically and radioactivity.
mte 8 10 COMMISSIONER AHEARNE: Let me make sure I understand 2
what you just said. It seems to me you had three alternatives 3
for that water after it left the receiving tank: One was, if 4 it was -- it would go back for reprocessing ifi it was off-spec.
5 The other was .for reuse in the plant. You mean going back 6 into the cooling system for makeup?
7 MR. COLLINS: I would like to refer to that. At the 8 present time, there is we are prohibited from discharging, 9
so that.the alternatives to discharge at the present time 10 would be either to store that water --
11 COMMISSIONER AHEARNE: That is what I was trying to 12 get to. Storage doesn't seem to be one of the ones you were
- 13 14 15 t*alking about.
MR.* COLLINS: Storage, of course, would be one of the alternatives. Another one would be to reuse it in the 16 plant.
17 COMMISSIONER AHEARNE: At the moment, at least, and 18 maybe longer than that, discharge is not an alternative, right?
19 MR .. COLLINS: At the present time, discharge is not 20 an alternative. But the water coming through here would be 21 sampled.* If discharge were permitted, at that point a deter-22 mination would be made.
23 COMMISSIONER AHEARNE:* As far as use at the present 24 time that you are proposing, discharge is not one of the Ace-Federal Reporters, Inc.
25 proposed --
mte 9 11 MR. COLLINS: That is correct. Storage -- after 2 processing of the EPICOR at the present time, it would be 3 storage.
4 COMMISSIONER GILINSKY: Where would the water be 5 stored?
6 MR. COLLINS: It could be in two places. Of course, 7 you do have the capability to store water in that receiving
-- 8 tank, because you have 130,000 gallons capacity, and you are 9 processing through at a nominal processing rate of 10 gallons 10 per minute, or you can*process water and*store it in that 11 tank.
12 The other thing that could be done with the water
- 13 14 15 would be to take the water back to its original tank, if that tank were empty.
contaminated.
Because those tanks are pretty heavily They will have to be flushed out, anyway~ So 16 you could use that water as a flushing mechanism.
17 CHAIRM..Z\.N HE:NDRIE: The reactor water storage tank?
18 MR. COLLINS: The miscellaneous waste holdup, the 19 various tanks in the auxiliary building.
20 COMMISSIONER KENNEDY: You would use this clean 21 water as part of your --
- 22 23 24 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?
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25 MR. COLLINS: All of the tanks in the auxiliary
mte 10 12 building fur Unit 2 contain contaminated water.
2 CHAIRMAN HENDRIE: Of one kind or another.
3 MR. COLLINS: Yes.
4 MR. VOLLMER: Including the tank farm. We are using 5 that now.
6 MR. DENTON: But just recycling it within the plant 7 doesn't solve the problem, because there is an in-leakage of 8 1,000 gallons a day. So eventually, you have to store it 9 some~lace that it is not stored today. It might be over in 10 Unit 1 or in railroad cars or inflatable bladders brought on 11 site. But there is a need eventually to create additional 12 storage other than that presently available.
- 13 14 15 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 16 not contain the shielding that would be required.
17 COMMISSIONER GILINSKY: After the cleanup, these 18 tanks are set up and ready to be used?
19 MR. *coLLINS: Yes~
20 CHAIRMAN HENDRIE: At this stage, what do they call 21 the reactor water storage tank?
- 22 23 24 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.
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25 The borated water storage, the reserve water. Basically, that
mte 11 13 is the borated water storage tank, which is 300,000 galons, 2 between 300 and 400,000 gallons.
3 COMMISSIONER GILINSKY: Isn't that outside?
- 4. MR. VOLLMER: Yes.
5 CHAIRMAN HENDRIE: That ought to be pretty well 6 empty now.
7 MR. VOLLMER: There is still a fair amount of margin 8 of water there. And in Unit 1, Unit.l needs further tech 9 specs, a certain amount of additional capacity, because that 10 water goes irtto the coolant system in the event of a pipe 11 break. It is also used in the makeup, for the fuel pool and 12 so on. It is the main supply of borated water.
- 13 14 15 COMMISSIONER GILINSKY: The tanks for Unit 2 are needed for Unit 1, even in its present condition?
MR. COLLINS: No.
16 MR. VOLLMER: A borated water tank for each facility.
17 I was speaking generically. They need to contain a margin of 18 water available for contingencies, in case you get_some sort 19 of a pipe break or leak or something like that.
20 COMMISSIONER GILINSKY: Why can't this be some of 21 the water? Can't you borate this water?
- 22 23 24 it back MR. VOLLMER: I think John was referring to putting into the system, both as flushing material or probably, if it is chemically adequate to be put in there.
Ace-Federal Reporters, Inc.
25 MR. COLLINS: Chemically, it would have to be very
rntel2 14 adequate, because at that point you are keeping your low 2 concentrations of chlorine and other chemicals that you don't 3
want in your primary system. So if it could meet it chemically 4 it could be used as that source. I think the most likely thing 5 would be to use it as a flushing mechanism for reducing the 6 activity levels in the various piping,!systerns and the tanks 7 ~rom which it came from.
8 COMMISSIONER GILINSKY: How do you decontaminate 9
these pipes and tanks? Do you flush out? Or is there any 10 e-1 more --
11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-Federal Reporters, Inc.
25
- 468 02 01 15 kap EW/d Mr~. COLLIUS: rl"u:3hinq of wat,3r is the principal 2 mecn.anis11.
3 COW1(lSSIOr4ER Ai-lEAr?NEt Th::ire com"'!s a point \'/hen 4 you are taking the water in the aux tanks, running it
- ) 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.
Y !,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
468 02 02 16 lcapBWH wat9r in th3re matter as ~uch in this plant as it would in 2 an operatin9 reactor?
3 J,,m. COLLINS~ \lie l'loulJ not want to put in high 4 concentrations of chlorides into the primary system. You
~ 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 shield. And then transferred to the staging area. And 22 then, on to th~ licensed burial ground.
23 CO!*MHSSIONE!? AHEMWEg The staging area is what?
2-} ,\m. COLLii~s: There are two staging areas. On'3 is 25 refsrred to as an interim staging facility that*was ouilt to
,468 02 03 17 kapBr'1H handle a certain number of 28 liners, until a more long-ter~
2 concrete structure could be ouilt 9 which we would ho~e would 3 have no mora longevity than of about two years.
4 This would provide adequate on-site holding
~ 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 because of tha rains we have had these past several w~eks.
15 It has hampared the Met Ed from pouring concrete. So, it 16 has now slipped that schedule back about a month.
I' 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
18 468 02 04 k apBrl/i--! 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
+ 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 i t would look, whether i t 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 le 14 at.
l:S 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
19 1468 02 05 k apBi'IH facility could be hooked on to th9 processing building tnat 2 is hare 9 so the material doJsn't go through a dewatered 3 staga and tnen into storage and has to come back out, or 4 whether you can get the solidification facility into this
- ) area or next to it 9 in any re3sonable wayo 6 And you are indeed going to have to go to I staging ..
-3 COMMISSI01~ER KENN:::DYg Are l*te ~10ing to discuss y that solidification proposition?
10 MR. DENTONx We can do it now 9 if y0u like. We lI have our technical staffs that talk bac~ and forth about 11- it. Bill 0ircks and I have reached an agreement that we 13 should use the EPICDR the way it is designed until such time
- 14 15 16 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 I I they come out of this one.
I c3 I would treat.the resins that have ~!ready been 19 exhausted -- but once the solidification unit -- we move 20 over to using the solidification unit.
21 CHAIRMAN HENDRIE: . Can they g~t one hooked on 2.2 here?
23 lvH?. DENTO:~i Let me ask John to respond.
24 1,{.-,. COLLI:--!S: No thought has been given to it. I 2j would agree with you, though. I think it would be tight
20
/468 02 06 kapl3Wrl puttin-;J it ine
- 2. 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
~ 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 that it could be possible to do in-lining s0lidification.
23 In any event, I think any modification wouLJ be in the order 24 of nine years to a year -- nine months to a year.
25 (Laughter.)
21 t468 02 o7 kap3Wi-1 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
22 46f3 02 08 lcapBWH 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 0'1 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 --
23 468 02 09 kap!JWH COi',H*,IISSIOi i::R GIL-It'6KY: This facility could handla L IO, OJO qal10ns a day?
,.;, :-,*[~. COLLL-JS: 10,DOO a minute would be your 4 optimum through-put, it would b9 more like three gallons a
'.:) minute oecause you have change-outs.
V COMi,1ISSID>lcF? GILL'lSKY: As a .:Jractical matter 9 it I would not apply to the decontamination of the water in the 8 auxiliary building?
y Mf?. DENTON: Six months ago --
10 (Laughter.)
11 MH. DENTON: I might have thought we would have 12 been much further along.
L3 CO~f.~USSIONER GILINSKYg Things may not move as
- 14 b
16 fast as we think they will.
!,Ft. DEi{fO,>l:
contaminated water up there that It s*eems like we have got so much Ii CO MMI SS I ONcF? AHEARNE: If it does perform at the 18 rste at which it is piedicted --
1:-) MR. DENTON: It seems to me that it wouldn-'t b3 a 20 total waste of resources to have a solidification ~nit at 21 least under _desi9n 9 and maybe by the time it is designed and 22 the staff has reviewed it, we can reassess.
2 *").J CO.'/i.\HSSIONEf~ GILINSKY: ,11:i have g,::it all the water 2,.i in t~e cont3inment 9 which is highly contaminated, and there 2::S is a lot more of it.
24 468 02 10
- '.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 design into his system solidification processes?
15 !: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 solidification'?
2:S MK
- CO LL L~ S i No ~
25 46.J 0.2 11 CO,WHSSIOiH:f~ iCENNE:L.JY: He has noL
!'IU" COLL I i*JS: No.
3 COMMISSIONER KENNC:JYi Therefore, if I can b8 sure 4 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
26 46D 02 I 2 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 1i 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 c: o m~n ~ n t s , r a v i e ws v et al ?
15 COM,\(ISSIONER GILI>!SKY: Probably.
1' - 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.
27 46~3 02 13 kap8\-1H
.2 :Ar
- 1.Ji r c k s *
.3 C()M\H~;s IOHEF? Bl?AD.=ORDi You have indicated that it i 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 DENTON: ~ith e defense in depth sort of 14 outlook, I feel there are more potential ways to cle~n up
)j 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 plac~ for E?ICo~~-II, that mi*3 ht influence your design of th~
20 liners, the bed S3t up for the containment proc~ssing
28
-'168 02 I 4 kapBi'iH 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 Il 12 13 14
]j l i J,g 2) 21 23
68.03.1 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 he wants to use it for both purposes or se~arate design.
d It would oe up to him --
-J COMMIS::3IOrJER KENNEJY: He won"t reach that conclusion 10 if he isn't instructed that it has to be for both.
II ;fiR. DENTON: That's righL I2 COMMISSIO>JER KENN.::DYr Or that there must oe 13 something for eacho
- 14 f.)
Jj 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 II of the cohtainment water because you believe that it is 18 n~c9ssary for the protection of the public?
IY MR~ DENfON: We have only one way of dealin9 20 formally: That is orders and licensing conJitions. lie ha.ve 21 not formally communicated that requirement for solidification
- 22. of the containment.
23 In all of the discussions that tne staff has had with their 24 staff and planninJ their design, I think the staff has tried 2:5 to indicate that if it didn't co~e in with solidification
1468.03.2 30 Gil 9sh 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.
ll 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 solidified? If you want the deminer-:ilizer route --
2j Mi?. COLL Ii\JS: Both.
1468003.3 31 l3i"I GI sh 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?. COLLII S: I think the licensee could have oeen 23 ready to go by late May. Had the system been necessary at 24 that time in the emergency mode, yes.
2J CCH,l),{ISSIOi,/ER KEl'lNEOY: If he was ready' in late May.
7468.03.4 32 BW 9sh 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 MH. DIRCi<::3: I am not as well prepared as I want to 14 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 33
/J;'*f gsh 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 ~ CKS 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 storage established because I u~dsrstood that they couldn't l:J possibly be ready for a year.
16 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 i t 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 COMMISSIONER KENNEDY: My interest is both.
23 ,\rn. DEi'ff01~ ~ And the public interest is oot h and you 2l- are weighing these two factors as fa where yciu want to 2j i)roc eed.
146<3.03.i 35 B,~ gsh CO*\C\ISSIO:'*IER Ai*!EARNEi I think we have aln~sdy
- 2. e stab l i shed t hat i f the EPIC OFl sys t 8 m runs .:1 n y whe 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 MK. COLLI;~s: \'le are anticipatin9 16 CCH!MISSICHER KENNEJY: T\*to shipments a week?
I' 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 36 Bi'/ 9sh in six months.
2_ f'fr\at Ls tho, maqic or the criteria for six months? {~hy not 3 three? ~hy not nine?
4 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?
I3 W1
- DI RC KS : I t i s the l a t t e r
- I t i s our v i e w t hat 14 we ~refer no unsolidified resins to be shipped.
15 COMMISSIONER AHEM?dE: I understanci that. But your 15 point is that six months is oased upon -when you believe it Ii 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 storing the resins until solidification is available? rle went 24 over that earlier, but I didn't fully understand it.
2j Suppose you operated EPICOR and then stored the products at
37 bY.l gsh 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.
lI 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 38 this area.
,2 fherefor3 9 we think that we wouldn't want to see it b9 put 3 in a low priority item to move toward ~0lidification. W9
-r have not se9n the attention oeing given to solidification
- ) that we would hav9 liked to have s,~en.
5 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 CO',fHSSIO,H:R AHEAH,\JE: If, for exa:nple, it is two 2::i years versus a year, then it probably is significant.
1468.03.11 39 otV gsh 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, i t 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 So if we want him to do that, somehow or other h~ hss got l:J 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 .'.U. DE>JfON: Was the package that 19 d to the closing 2.) 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 41 IY i 1
qsh COM.'HSS IO:ER r(E:,lN~Jyg That is the pre-dc'.!t~rmin~d J TJ1e actual n umt:;er at ti1a t 4 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.
Every tech spec has it.
CO MM ISSI ONER Bi~.AD.:ORO: You set standards for the Ii systems after it is operated a while.
12 1\'iR. COLLINS: \'ie don"t set the standards on the l'3 system. Thare are no t9chnical specifj_cations that 1*equire 3 p1rticular system to have a particular dscontAmin3tion.
lj r,:F?. DENfcU: Th0 st~ndards are downstream dose. I
!.'.J think what John is saying, if this system is ap~rovad anJ II then you know what volumes and flow rates are, his staff.would lo *_) calculate the specific limits for concentrations at the point of discharg~ and put those in the tech specs.
20 21 23 25
CR7468 42 BWH t.4 jl 1 MR. COLLINS: That is correct.
2 MR. DENTON: If they were set prior to operation, and 3 in fact I mentioned you could infer what they are now. The 4 Licensee has no doubt already done that calculation because 5 we have specified in reg guides how we establish what the 6 *numbers are.
7 COMMISSIONER BRADFORD: That is a phrase that appears 8 in other places, the predetermined values. It has troubled 9 several of the commenters, the set points on particular instru-10 ments, what have you.
11 MR. DENTON: The intent of this Staff is that we 12 would appoint Appendix I as the base for holding the radiation
- 13 14 15 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 16 city, and ourselves, or whatever it might take to assure every-17 one that what was being released met those types of standard.
18 Appendix I, plus additional conservatisms?
19 MR. DENTON: Yes.
20 MR. VOLLMER: It would depend on the ultimate 21 disposition of the water.
- 22 23 24 CHAIRMAN HENDRIE:
tive standard.
Appendix I is a pretty conserva-If you apply, for instance, the Environmental Protection Agency Guidelines, you can go up a factor of 4 or 5.
Ace-Federal Reporters, Inc.
25 MR. COLLINS: For the real individual, that is an
j1 2 43 annual average for the uranium fuel cycle. That is 25 millirem 2 from all sources; where the Appendix I is specific to both --
3 CHAIRMAN HENDRIE: You have to reserve a piece of 4 that for other portions of the cycle or other operations.
5 MR. COLLINS: That is correct.
6 CHAIRMAN HENDRIE: I suppose you can make a good case 7 that the federal regulations would allow release at levels of 8 -- up substantially from Appendix I. I *think if we can get 9 down inside Appendix I, that -- I think that is a desirable 10 thing to do. It puts this rather extraordinary recovery opera-11 tion back within the radioactive release limits for uncontamin-12 ated, normally operated plants, which I think is a very con-
- 13 14 15 servative and very useful thing to do.
MR .. COLLINS:
CHAIRMAN HENDRIE:
It can be achieveo.
Now, are there questions at the 16 moment?
17 COMMISSIONER AHEARNE: No.
18 Onward.
19 CHAIRMAN*HENDRIE: Let me propose the following to 20 you. The paper -- a couple of the papers came up -- one of 21 them came yesterday. My understanding is that you would be
- 22 23 24 interested in having a chance to look at it.
COMMISSIONER AHEARNE:
CHAIRMAN HENDRIE:
And OGC.
I was going to go on to that.
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25 There are some other questions that we ought to have a chance
j1 3 44 to understand. I would like to have from the Counsel's Office 2 an assessment of the various options for Commission action.
3 And inevitably, since we are under -- we are being sued in this 4 matter anyway, there is litigation risk, greater or lesser, in 5 each of these options. And I would like an opportunity to know 6 from the Counsel's Office how they assess all of this. I think 7 it might be useful for us to have that iP mind.
8 What I am getting around to proposing is that we ask 9 the counsel for that -- to prepare an analysis of that set of 10 options which he tells*me he doesn't have ready to go at the 11 moment. And we will meet again as soon as -- consider.those 12 as soon as he can get them up, which I would expect would not
- 13 14 15 be later than next week.
COMMISSIONER AHEARNE: What I would particularly like General Counsel to address is the argument raised quite 16 strongly, by at least the Susquehanna people, is can one separ-17 ate steps in.the overall decontamination treatment. In other 18 words, is it appropriate to look at EPICOR in isolation.
f9 MR. DENTON: I guess I do need some direction as to 20 potential use of Unit 1 for storaqe; that if we progress down 21 the number of available storage --
- 22 23 24 CHAIRMAN 3ENDPIE: I expect to have the Commission decision before that becomes necessary.
is end of October.
The current estimate Ace-Federal Reporters, Inc.
25 COMMISSIONER AHEARNE: The decision*would have to be
j1 4 45 made sooner than that. It is not just one little switch that 2 you suddenly flip.
3 COMMISSIONER KENNEDY: Meanwhile, those tanks are not 4 being used for other purposes at this point.
5 MR. VOLLMER: Unit 1 tanks.
6 MR. COLLINS: Part of the -- one of three bleed tanks 7 is being used for borated water. Two others are available.
8 COMMISSIONER GILINSKY: They have to be held avail-9 able in any case because li~htning could strike at the core, 10 too, and the Unit 1 tanks are safety 11 CHAIRMAN HENRIE: Are part of it. Ttere is apparent 12 apparently other tankage around.
- 13 14 15 What about the Unit 2; is it bleed tanks?
HR. COLLINS:
MR. VOLLMER:
They are filled.
The only other* available storage 16 capacity 17 CH~IRMAN HENDRIE: You pump those up.
18 MR. COLLINS: The bleed tanks have been filled.
19 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 MR. VOLLMER: _The borated water storage tank.
23 CHAIRMAN HENDRIE: What is in the borated water 24 storage tank for Unit 2?
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25 MR. COLLINS: Borated water.
j1 5 46 MR. COLLINS: Borated water. I don't really know 2 the exact capacity that is in there at the present time.
3 CHAIRMAN HENDRIE: That is plain water, except for
- 4 5
the boron.
MR. DENTON: Right.
6 MR. ARNOLD: I am Senior Vice President of Metropoli-7 tan Edison Company.
8 The borated water tank is essentially full, as is 9 common with these tanks, because they reveive water back from 10 the systems and are not only made up to with fresh'water; the 11 tank is c9ntaminated such that it would have to be processed 12 before it could be discharged.
- 13 14 15 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 16 the __ equipment and systems necessary for solidification. The 17 design approaches that appear to be feasible for that,purpose 18 would not -- maybe not feasible, but most desirable, would not 19 be able to be used in common with EPICO~-II resins. EPICOR-II 20 resins would require completely new types of facilities and 21 would undoubtedly involve transfer of the resins and all of
- 22 23 24 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 Ace-Federal Reporters, Inc.
25 containers.
jl 6 47 CHAIRMAN HENDRIE: Thank you. That was a helpful 2 clarification. I thought I had located 1 million gallons of 3 storage there.
- 4 5
COMMISSIONER AHEARNE:
CHAIRMAN HENDRIE:
You did, but it is full.
Not free; too bad.
6 COMMISSION AHEARNE: When do they have to know.
7 That's the point. When do they really need a decision?
8 CHAIRMAN HENDRIE: I would like to know what 9 direction you are going now~
10 MR. VOLLMER: The Licensee requested last week by 11 letter that we consider an alternative interim decision, say 12 60,000-gallon authorization, October 15th. As was indicated
- 13 14 15 in the letter to --
CHAIRM..~N HENDRIE:
MR. *voLLMER:
60,000 gallons to do what?
To process through EPICOR up to 16 60,0.00 gallons. Presumably that would be taking the lowest 17 activity water to provide a little more --
18 COMMISSIONER AHEARNE: Interim decision.
19 MR. VOLLMER: We have not acted on that.
20 In response to Senator Hart's letter, I think we 21 indicated the end of October was the most likely point of
- 22 23 24 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.
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25 Or another alternative which has been discussed is
jl 7 48 that of putting it back into the containment building. I think 2 we would like to look at that one in great detail, because 3 there are some real substantial problems with doing that. That 4 was one option proposed or at least discussed in'*the I,icensee's 5 letter.
6 We feel that we don't have the kind of margin we 7 would want in the containment building. We are close, in a 8 manner of speaking, to some of the Valves that are critical 9 for long-term assurance of safe operation and things of that 10 nature. So I would tend to discount that one almost out of 11 hand.
12 As we.* touch the pipes, and I think we are very close
- 13 14 15 to touching some of the lower portions, you affect the cool-
- ability. You take*heat away from there by heating up the base water, so it would likely affect your natural circulation 16 ability.
17 The other thing is in another 100,000 gallons or so, 18 you are maybe running into some electrical components which 19 control the decay heat valves.
20 CHAIRMAN HENDR!E: What is the total input to the 21 contaminated water volume?
22 MR~ VOLLMER: About 500 gallons a day, and you have 23 about 70,000 gallons a foot.
24 CHAIRMAN HENDRIE: If one were looking for a few Ace-Federal Reporters, Inc.
25 weeks, rather than a long-term choice of what to do, at this
j1 8 49 point one could certainly consider turning it back into the 2 containment building.
3 MR. VOLLMER: But I would hate to put it in without
- 4 5
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 6
7 with a way of getting that out.
8 CHAIRMAN HENDRIE: We calculat,ed when we fill the 9 containment?
10 MR. VOLLMER:. No, sir.
11 CHAIRMAN HENDRIE: The answer with regard to Unit 1 12 tankage is, I think, anything which doesn't begin to fix the
- 13 14 15 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).
16 MR. VOLLMER: Totally agreed.
17 CHAIRMAN HENDRIE: So I think it is clear where the 18 health and the safety momentum drives us.
19 Now, the question: Do we have to use some Unit 1 20 tankage? -- is a process of getting this decision machinery 21 somehow cranked up and moving. And all I can say is, if that
- 22 23 24 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 Ace-Federal Reporters, Inc.
25 provide.
J. 1 9 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 MR. VOLLMER: We could respond to them point by 5 point.
6 COMMISSIONER BRADFORD: We normally would, I take it.
7 MR. VOLLMER: Some of them, as you probably know, go 8 into areas *that are extremely detailed, *and in some cases even 9 extremely hyp*othetical. We try to do as we would normally do 10 in the safety evaluation report or environmental assessment,
\ 11 looking a:t some of the bounding cases, and not get into very 12 into details, aB was called for here.
-- 13 14 I think to address in a responsive manner all of the questions that were *received, I see that is an effort that 15 would re*quire well in excess of a month by a substantial num-16 ber* of people.
17 On the other hand, if can extract and provide generic 18 responses, and try to hit some of the more succinct technical 19 questions that were asked, I think we can -- we have iooked at 20 them all very careful, and I think we. can try to come up with 21 -- I am not sure what Mr. Bickwit is anticipating for the next
- 22 23 24 meeting, but we should try to come up with something in the very near future.
COMMISSIONER BRADFORD: In some cases they request Ace-Federal Reporters, Inc.
25 no more than discussion of other radionuclides that will be
jl 10 51 present.
2 MR. VOLLMER: Those things we can certainly do. In 3 some cases. they are already provided; and where they aren't,
- 4 5
we can certainly provide them; yes.
CHAIRMAN HENDRIE: I would look for some coverag:e on 6 'that sort of basis sort of basis then.
7 MR. VOLLMER: We have tried to provide a generic 8 discussion of the comments, and that is.what was provided with 9 this package. We can go into another level.
10 COMMISSIONER*BRADFORD: To the-extent that you can, 11 I would like to make up specific answers with specific*comment 12 comments.
- 13 14 15 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 16 water fromUnit -- moving it from Unit 2 tG 1 creates a prob-17 lem. It creates a number of problems. It now takes radio-18 activity levels that are in the auxiliary building which are 19 much higher than we have normally anticipated in an operating 20 plant transferred to a plant that does not have those activity 21 levels, contaminates piping systems, which is going to be
- 22 23 24 very hard £or us as an agency to demonstrate --
CHAIRMAN HENDRIE:
case of poison ivy.
I understand, John, it is like a Every time you scratch it then run your Ace-Federal Reporters, Inc, 25 back, you got a new patch.
j 1 11 52 MR. COLLINS: That is all the mor~ reason why we 2 should proceed to make a decision on the --
3 .. CHAIRMAN HENDRIE: You can hardly find. a guy in this 4 room who is more anxious to make a decision than I, but I am 5 also an expert in this machine here.
6 COMMISSIONER GILINSKY: The question is: Do we have 7 the right system for decontaminating that water***and dealing 8 with the products of that decontamination.
9 MR .. DENTON: I see it somewhat like we discussed the 10 other day on the radio-network from plants. *There may be a
\
11 possibility if we started all over again; six ~onths ago we 12 could have designed a better system, Certainly this system
- 13 14 15 will . do the job. Maybe_ there is, in retrospect, 10 percent improvements here or there if we had done it differently.
confi9-ent it will. do the job of gettin*g down to the Appendix I I am 16 lev~ls. I don't see a need to further refine the system. I 17 think striving for the last improvements just aren't wise.
18 COMMISSIONER GILINSKY: I was trying-to say that we 19 are not just dealing with legal niceti~s; we are trying to 20 decide what the right way to deal with this water is and what 21 the right way to deal with the products of the contaminated
- 22 23 24 projects is.
MR. COLLINS: I take it you have reservations as to*
the effectiveness of the demineralizer to remove radioactivity Ace-Federal Reporters, Inc.
25 from water; is that your concern? This is a well-proven
jl 12 53 procedure.
2 COMMISSIONER GILINSKY: My question is on what to do 3 with the resin that comes out of the process.
4 CHAIRMAN HENDRIE: The main question before the 5 house, aside from the fact that there are questions about~- on 6 the legal side, do we set it up this way or that way or the 7 other way? And what the various risks? Those are matters that 8 the Commission ought to have a chance to chew on its legal 9 possibilitiei of risks in private, I would think, but sort of 10 the technical side iss~e that comes down -- the policy side 11 issue,I guess would be better, that comes down is authorizing 12 to go into storage and wait for the solidification system to be 1
-- 13 14 put in place and then will be pulled back out of storage, then run through solidification, then shifted the solidified stock; I
15 or should you be able to ship at least --
16 MR. COLLINS:* But the water does not foreclose an 17 option.
18 COMMISSIONER GILINSKY: I would like to be clear on 19 that.
20 MR. COLLINS: Those resins can be solidified.
21 COMMISSION BRADFORD: The point was raised in several 22 comments that it isn't entirely clear in this situation that 23 the Staff role is such that it permits them to impartially 24 review the proposal before us. In peformeing the environmental Ace-Federal Reporters, Inc.
25 assessment, can you comment on the extent to which the Staff
jl 13 54 members were involved in the design of this facility? Do we 2 have a different r~lationship to EPICOR than we do to a 3 reactor we license?
4 MR. DENTON: It is a somewhat different relationship, 5 because we embarked on this under the emergy conditions as_ they 6 existed early_on. I think our motivation is still unchanged; 7 i t is still to protect- the public health and. safety. And we 8 saw it with the treatment of the water.*
9 Now, other members who live downstream of the plant 10 don't see that as their interest. Perhaps to move -- they see 11 i t as a first step for ultimate release in the water. I don't 12 know whether our extent of involvement in meetings has been
- 13 14 15 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.
16 MR. VOLLMER: I-n a lot of respects it has been much 17 closer, more detailed involvement than we would normally see.
18 As Harold said, in the early stages of the acciderit, we were 19 foreeeeing_the running out of any space for storage of water.:
20 in a very short time. Fortunately, most of those sources 21 were
- 22 23 24 MR. GOSSICK:
the design as such.
MR. COLLINS:
The Staff wasn't really involved in This is an off-the-shelf system.
No, it was designed specifically Ace-Federal Reporters, Inc.
25 the process is off this
jl 14 55 MR. VOLLMER: The shielding and those things were end t4 2 designed, 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace-Federal Reporters, Inc.
25
CR 7468 56 WHITLOCK t-5 mte 1 MR. DENTON: If the licensee doesn't propose anything 2 we don't license, *Here I think we have urged them to get on I 3 with some design that would accomplish this function. In that 4 serise, it has been different than our normal approach .
.5 MR. COLLINS: It was designed in accordance with the 6 staff guidance contained in this reg guide. During the early 7 period, I participated personally-in those design review 8 meetings, as if it were any license. They would have to meet 9 our design requirements*. That was done.
10 COMMISSIONER AHEARNE: Part of the nagging concern 11 I. have is --- i.and. it. is a little different from Vic Is, al though 12 it might be the same.. I am not using the words "what is the
- 13 14 15 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 16 for.
17 What I am a little concerned about is any flavor 18 that says, now we must immediately make a decision, in the 19 sense that back in April we really had to quickly make a 20 decision on what system ought to be designed. All of us 21 share the responsibility. It is not equally distributed,
- 22 23 24 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, Ace-Federal Reporters, Inc.
25 that we would have done it in a more complete fashion, makes
mte 2 57 me just hesitate a little bit to think, maybe if the urgency 2 isn't still -- and' that is one of my reasons why I want to 3 ~hink a iittle bit.
4 MR. COLLINS: Could I address that? When we met 5 with the licensee and discussed in the early stages the 6 alternative methods for treating that waste, it was not done 7 in haste. There was thoughtful consideration, both on his 8 par~ and o~r part, as to the type of sy~tem to be used.
9 Evaporation was the other alternative system. Now, you 10 concentrate these materials and you are dealing with much 11 higher acitivity.
12 COMMISSIONER AHEARNE: I am addressing the solidifi-
- 13 14 15 cation issue.
- MR. DENTON: It has been taking on increasing priority within the. Commission all summer long, and that is 16 the.right one to decide for that 1s -- maybe you would 17 like a briefing by NMSS on the solidification system as a 18 separate matter. It wasn't a big priority in my book six 19 months ago.
20 MR. COLLINS: But even in the early discussions 21 on the selection of the process system, solification was
- 22 23 24 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 Ace-Federal Reporters, Inc.
25 than adequate. And that was the guidance that was given to
mte 3 58 the utility.
2 MR. DENTON: But getting back to the general urgency,1*
3 there is a feeling in NRC employees at the site that it is 4 increasingly difficult for them to provide the kind of oversigh 5 and assurance in this area, in view of the mounting problems 6 with the accumulation of water. I think John has reflected 7 some of this.
8 I think it is shared, John, bi the other people I 9 have talked to at the site. It is not a unique situation.
10 It is really hol~ing us up from reducing the activity levels, 11 providing* an environment in the auxiliary building, the fuel-12 h~ndling building, that we don't have to in the mode we are
-- 13 14 15 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 16 levels.
17 We are not going to be able to continue decontamina-18 tion in those areas until we clean up the water. We have to 19 remove the water.
20 MR. DENTON: It would provide access in terms of 21 tomorrow' problem if we had a little bit of access --
22 COMMISSIONER BRADFORD: If the -- if Met Ed is 23 operating EPICOR in the principle of the lowest activity 24 first, that isn't entirely consistent with getting your Ace-Federal Reporters, Inc.
25 buildings cleaned.
mte 4 59 MR. COLLINS: Eventually.
2 COMMISSIONER BRADFORD: But it would be months off, 3
then, before the higher activity water would be treated. It 4 isn't as though beginning now is gping to solve that problem 5 within the next couple of weeks.
6 MR. *COLLINS: No, but on the next couple of months 7 it certainly will, and the longer you sit there the greater 8 pot~ntial ~ou have.
9 COMMISSIONER BRADFORD: That depends on how well 10 EPICOR runs, I understand. But there iin't A complete mesh 11 between starting to deal with the water and immediately 12 being able to go into other parts df the building .
- 13 14 15 MR. COLLINS: I have all ihe confidence in the world that EPICOR will do the job it is designed to do.
system that we know quite a bit about.
It is one 16 COMMISSIONER BRADFORD: Haven't the estimates varied 17 frdm three to ten gallons a minute?
18 MR. CbLLINS: Ten gallons per minute is if I start 19 out today I can process ten gallons per minute input ~hrough 20 that thing. I have to stop some period of time, because I 21 know I have to take out the resins. So the average through-put
- 22 23 24 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.
Ace-Federal Reporters, Inc.
25 The through-put still remains the same.
1 rnte 5 60 COMMISSIONER GILINSKY: Let me ask you one point:
2 Do the resins are they replaced at a fixed level of conta-3 rnination or does the contamination of the resins reflect the 4 contamination of water?
5 MR. COLLINS: The resins will be exhausted on 6 radiation. TSat number has been fixed to coincide with the 7 shielding requirements on the tasks, the transfer belt. On 8 normal operating plants, more often than not somebody decides 9 that maybe once a month or every six months is a good time to 10 change them. That is bhe normal process.
11 This plant has a specification that says when it.
12 reaches that activity level that is when you dispose of that
- 13 14 15 resin.
COMMISSIONER GILINSKY:
have the same activity level?
So all of the resin will 16 MR. COLLINS: Will have no more than that.
17 CHAIRMAN HENDRIE: Len, will you crank your people 18 up, please, to look into this matter, and have that ready as 19 soon as you reasonably can? And we can examine it with the 20 Secretary and see how soon we can schedule it. It will be 21 next week.
22 All right. Thank you very much.
e-5 23 (Whereupon, at 11:10 a.m., the meeting was adjourned.
24 Ace-Federal Reporters, Inc.
25