ML22230A108
| ML22230A108 | |
| Person / Time | |
|---|---|
| Issue date: | 10/10/1979 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M791010 | |
| Download: ML22230A108 (63) | |
Text
RETURN TO SECRETARIAT RECORDS NUCLEAR REGULATORY COMMISSION IN THE.~ATiER OF:
PUBLIC MEETING DISCUSSION OF RADIOACTIVELY CONTAMINATED WATER AT TMI AND' RELATED SUBJECTS (EPICOR II)
Place -
Washington, D. c.
Date _
Wednesday, 10 October 1979 ACE - FEDERAL REPORTERS, INC.
Official Reporten 444 North Capitol Street Washington, D.C. 20001 NATIONWIDE COVERAGE.* OAJLY Pages 1 -
60 0
Telephone:
(202 ) 3.47-3700
a DISCLAI:V.!ER This is an unofficial transcript of a meeting of.the United States Nuclear Regulatory Commission held on Wednesday, 10 October J 979 in t..'le Cornmissions's offices at 1717 H Street, N. W., Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has no-:: bee.!1 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 O?inion 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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BEFORE:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PUBLIC MEE'l'Il-JG.
DISCUSSION OF RADIOACTIVELY*CONTAMINATED WATER AT. TMI AND RELATED. SUBJECTS (EPICOR. II)
- Room 1130, 1
1717 H Street, N.W.,
Washington, D.C.
Wednesday, 10 October 1979 The Commission met, pursuant to notice, at
.DR. JOSEPH M. HENDRIE, Chairman VICTOR GILINSKY, Commissioner RICHARDT. KENNEDY, Commissioner PETER A. BRADFORD, Commissioner JOHN F. AHEARNE, Commissioner ALSO PRESENT:
Leonard Bickwit, Jr., Esq.
Steven Eilperin, Esq._
Martin Malsch, Esq.
Bernard Snyder, Esq.
Lee Gossick Edson Case Richard Vollmer John Collins Howard Shapar, Esq.
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CHAIRMAN aENDRIE:
If we can come to order?
Mr. Kennedy will join us directly.
In the meantime we should go. ahead.
The Commission meets this afternoon for a continua-tion of its discussion of what to do with the contaminated water at Three Mile Island and related subjects, the proposed use of the EPICOR II system, and so on, The first thing I would note is that we will hear from the Staff this.afternoon, who have be~n asked to prepare some further material in response to comments on the environ-mental assessment of the EPICOR II system and its proposed limited use.
Later on the Commission will want to discuss certain legal aspects of possible Commission actions in *connection with this matter, and we will do that at a second meeting this afternoon which will be closed since we will want to discuss with the Commission's lawyers various matters connected with possible litigation.
I welcome the Staff.
Lee, I see you have brought Ed Case, Mr. Vollmer and John Collins.
I think we ought to turn to the papers they have prepared, responding to some of the 1
comments on the environmental assessment and associated matters.I Why don't you go ahead?
MR. GOSSICK:
Why don't you go ahead, Mr. Chairman?
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THe paper we sent down I'm sure you've hardly had a chance*
to read, but Mr. Vollmer is prepared to go through and brief.
you one~.the comments that the Staff has.
Dick, do you want to go ahead?
CHAIRMAN HENDRIE:
I think we ought to* do that in any case, and I will just note that fortunately.my colleagues and I are fast readers and quick absorbers of information, fortunately.
Why don't you go ahead?
MR. VOLLMER:
Okay.
Thank you.
What I would like to do if. I may to start out with is basically summarize the options. that were discussed at the last meeting.
And rather than going through the point by point comments that we have provided you in the October 9th memorandum, I'd like to use if I may the opportunity presented with Mr. Snyder's memo which does I think pretty well highlight some of the important issues and the technical comments, and go down those and discuss those with the Commission.
And if there are residual comments then we can take them as they come up, CHAIRMAN HENDRIE:
I'm sure the Commissioners will have assorted questions with respect to these papers.
MR. VOLLMER:
As we talked about last time; we* see three major options for processing or storage or interim treatment of the contaminated water that is now housed in tanks
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in the auxiliary building and the fuel handl.;i.ng building.
One of these options was the use of available tanks in Unit l,to transfer the water over to the auxiliary building tanks in Unit 1, -and thereby provide -- a -ce_rtain amount -of free board that would give us more operational flexibility in Unit 2 to proceed with the needed.operations and the leakage that accrues from maintaining the Unit 2-system in the safe shut-down configuration.
As we discussed before, there are several problems with the transfer to Unit 1, I think generally.characterizing it as spreading out the contamination problem and not provid-ing for a fix which would immobilize the contained radio-activity in the water, whic~-was the basis reason-that the Staff felt that that option was not desirable.
Another*option we discussed briefly was the transfer of water to the reactor building.
At *this point in time we are roughly 150-or 200 thousand gallons away from reaching the decay heat removal valves, the decay heat removal system valves in the reactor building.
We feel these valves are fairly critical to have them in working order during the operation, so we don't feel it would be 'really a good solu-tion to put additional water into the reactor building.
There are other problems with that.
This water would contact various parts of the primary system, cutting down -- providing a heat transfer medium which would tend to
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counteract'the natural circulation that is currently going on in the system.
The third thing that was considered of* course was the thing we've been discussing for some time and that's the use of EPICOR II for processing the water.
And I think to summarize the Staff's-position on this, it is that we feel that the public. interest can best be served by immobilizing.the activity in the contained radioactive water by putting.-them on -- fixing them.on resins, and we feel that this also would provide needed relief in the auxiliary building to try-to clean up areas in there and to over-all reduce the occupa-tional,exposure~
Activities are still_ going on in the auxiliary 14 building and will need to be for the foreseeable future,. in-15 cl uding the proposed installation of a separate decay heat 16 removal system that would be more nearly matched to the heat 17 load that we currently have 'in the core and would provide a 18 fairly low flow so that we would not have to get into a situa-19 tion where turning on larger pumps might disturb the core.
20 Since we don't know the configuration there we would rather 21 not have to apply any high flows to. the core.
22 With _those in mind as the options, I would like to 23 go to the discussions in the OPE memo* and discuss briefly 24
- Items 1 and 2, "Adequacy of the EPICOR II System" and "The
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25 Solidification of the Resins, 11 and then go on to the 12 or 15
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or so technical comments that they had *.
- I th:di.hk they fairly 2
reflect some of the comments that were* provided as the public 3
comments, and also some of the nagging.issues that you and.
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- others have raised,that perhaps *were
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As far.as Item 1, the adequacy of the EPICOR II system, I think that we have.in the environmental assessment perhaps. not provided an. extremely direct analysis of how, isotope by isotope, the system itself will be capable of de-contaminating the water.
We have used,.rather than that, basically a criteria approac,h.
The criteria was basically that the system should operate.such that.the effluent water from the system would be capable of many disposal alternatives.
And one of these disposal alternatives that would need to be considered in a separate assessment would be the alternative of discharge to a river, as well as the others would be tanking offsite, evaporation or solidification or others.
So what the Staff did was basically assure them-selves that the technology we see with the use of a system like EPICOR, which we feel will give decontamination factors in the order of 105 or so; would be certainly: adequate to cle.an the water up to a point where it could be below 10 CFR Part 20 disposal standards and could be below* the standards Ace-Federal Reporters, Inc:
25 set by Appendix I if the river '1.-iere used* as a discharge
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- criteria:. *.
A'ede~al Reporters,
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There was no* intent*here,*to/in'. advance/,.pick'.~
d:Lscharge.aiterriative but/ rath~r, -it *was' the. selection. of a*
criteria and' a goal* by which* the :system qould** be. performance-_****
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25 Work-is* going *on currently, and,we.don't have, the,:*
results from those to try to:assess/what* type of decontamina-,
tion factors would be achieved.by the system.
If you wish to go into that further I'm sure-John.can comment,on it.* I don't
- know when-we might expect the results.*
MR. 'COLLINS:.. We_ *can expect those' do'cumented re-sults in.about a.:week 'or' ten days from now.. Most *of 'the 'studie have :.been :CO~pleted r ' It Is.. a matter'. of. maktn_g 'the final' evalua-tion of the data.
MR. VOLLMER:
But in any* event*,.. as we. discussed in
. the* environmental *.assessment, the water from-EPICOR would be Put.into a holding tank and if the *de~ontamination factors that we expect or the resultant water. did not achieve*. the. goals **
that we're-lookingfor, it could be*put back through the.system or other decbntarnina tion activities could.be *unde.rtaken if
. necessary* *.
COMMISSIONER AHEARNE:
. Such *as --.?
'MR.. VOLLMER:
Well,' if.necessary, LE the system.
'its elf. didn It. work' we could:_.go.back into. puttipg it' back into holding. tan:ks and. a dif:fe*rent., type of resin mix could.be I.
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used.
I guess if necessary it could be put through an evapora-tor or something like that, which would make it less of a con-centration problem.
But I think the resin would be the first solution.
Isn't that right, John?
MR. COLLINS:
Yes.
MR. VOLLMER:
So I think it 1 s a technology that we're talking about, and we would expect, based on a great deal of experience with operating plants, with military applications, that it's the Staff 1 s best judgment that this facility will provide us with the decontamination factors that we have been alluding to in* our environmental assessment*.
CHAIRMAN HENDRIE:
Hold ii;: just a second:
Let me ask the people back in the back row, first of all can you hear me when I talk about like this?
And the second question is can you hear these folks when they talk about like they've been-talking?
VOICE:FROM THE AUDIENCE:
No.
. CHAIRMAN HENDRIE:
I hear some heads shaking, so I will ask you to hold your mikes* up. a little bit and boom out so the people in the back can hear.
You. know, if we charged less for the back seats why then I suppose it would be fair that the people back there.not hear as well as the people up front, but since it is sort of one-price seating, why
- everybody is entitled to the same receipt of information.
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Pleas,e* go ahead. ' '
2 MR. VOLLMER:_. Ok~y ~
.3 One item that was brought.up.,in :this.discussion,. the 4
,OPE discussion of the adequacy_, of' the. EPICOR._systerri* was the
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- clean_ water would-be condµcted* after deminE!ralizing. unit re-:-
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-placement.
8 As* you know,. the system itself was tested to. 125
. 9 pounds prior to operation, performance, tested.. And operation 10
.. of the system will be* at just a few pounds over p_ressure*~
And 11 12 13 14 15 16 17 18
)9 also the Staff felt that opeiations*really*provide you with a continual* testing of the* system by virtue of. the fact you. do.*
-have. leak -detection systems. and so on..
However, the licensee ha*s informed us that they-.
would indeed.plan.ondoing-a performance test, a leak.perform:...
anc;::e *test.after replacement of the resins each time with clean water, so I think that' particular. issue',! as: far as. demonstra-tion. each time a process is initi*ated aff.er a changecout, disconnect and con.necting the hos*es, w.ill be -taken care of.
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- That certainly is not reflected in our current *environmental 21
_ asses.sment since the, information is ielative*ly recent-.
- 22 I would_-like to go,.on now.to th~* s61dfdiification. of 23 the resins.which were* discussed: *i11 consiperable detail in. the last meeting.. *
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25 In a letter f-rom Bill Dirks* to >Harold Dentow dated
eb9 10 0ctober.. 3rd it discussed :th~ iproce!=>.sing-of. TMI~2 waste and:..
2 sort of. a. Staff con;;ensus that;,the *waste*.would be solidified 3
at *a time wheI1° -:- we111;. this-particular*,*lettei" s_aid.six months.
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-consensus that, on *a.best-effqrts basis, we would._ g_o fro_:m :the v~cutim; _ dewai:ered resins. into'* a:.solidified matrix resin for shipm~nt, :but that this should not. preclude* the* application* of EPICOR,. rather, that we. should proceed with* the oper~ti'on
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- soon as the system could.. be put into place,. there would.
.be, from that time forward, solidification -of resins for ship-ment.
- Ed, so :f:a'.r as L know ;.i there was no. real reservation on the* actuai timing,> and: the St:aff.has disc:'ussed : _ _.:.
CHAIRMAN HENDRIE:. W~*ll~IHarold. Denton and Bill Dirks *had talked about s1x months as a possible changeover*
time,. to a point.whe:re. :only -so*lidified re~i11s.might be. shipped.
. I don't. think, talking to both. of them, it was clear to me*
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- that.the s:Lx months was* not *-contempl~ted-as some in:violable 19 limit or date* from above_ but, rather~ a. time which was probably 20 on the short.side* but wa_s.aimed also *at* encouraging vigorous 21 action.".te>. design to *get a* solidification system.into operation.
. Md I think one of. the.things that people have...
23 suggested in: resolving the question about solidification of A
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the. spent resins,,.assuming, that *.the system -- if -the* system Ace-Federal Reporters, Inc.
25 is to be operated, would be to try to.establish that target
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25 11 time as part of the initial.understanding on the matter so that it simply does not drift-and keep getting pushed out as time goes on.
And in that context--
Let's see.
In fact you represent one side of that issue but: I. see others who can represent* the other* side if necessary.*
How good or bad is six months as a target?
MR. COLLINS:
Let me address that, Mr. Chairman.
Following our last meeting with you, I met with the licensee and I think it was pretty clear to_ the licensee the direction in which the*staff and the Commissioners were heading as far as solidification>
The licensee has undertaken a study to identify the best method available for solidification.
There are many -
alternatives and he has*undertaken*a study to identify the CHAIRMAN HENDRIE:
ANd some of those I notice have already resulted in the arrival at burial grounds of containers with free water in them, or at least free liquid.
MR. COLLINS:
But not from TMI though.
COMMISSIONER GILINSKY:
I thought no reactors had implemented this requirement yet.
COM.1'1ISSIONER AHEARNE:
There are abo.ut nine *or some-thing.
MR. SNYDER:
They do it on their own option I be-lieve.
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25 12 CHAIRMAN HENDRIE:
There are a... number that have tried one or another solidification process; and I made the comment only to note that one does not, by saying the word "solidification" one does*not move from a difficult and un-
.certain area into the golden promised land.
There's. a good deal to it arid one.* has to be careful in choosing the process and working* out_ the details.
MR. COLLINS:
That's what the licensee is attempt-ing to do at the present time.
COMMISSIONER GILLINSKY:
Let me just raise this point.
There are reactors now --
MR. COLLINS:
-- who have the capability to solidify COMMISSIONER GILLINS~Y:
They do that now as a matter of course, --
MR. COLLINS:
- Yes, COMMISSIONER GILLINSKY:
-- and ship.their waste in that form.
MR. COLLINS:
Some of them would ship the resins in solidified form in 55-gallon drums.
CHAIRMAN HENDRIE:
You may remember that some of those drums containing solidified resins in fact leaked*at the Nevada site not so long ago and caused a certain amount of discussion between ourselves and Governor List.
COMMISSIONER GILLINSKY:
Did they employ one of these solidification schemes?
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Yes.
COMMISSTONER GILLINSKY:
The Palisade*s reactor?
CHAIRMAN HENDRIE:
Yes.
13 MR. COLLINS:
They were using urea formaldehyde.
So I guess, to sum it up, they are prepartng --*they are going. through this study and will prepare a* report to us identifying the present method.to handle the solidification of the*EPICOR II resins.
I would hope that the Staff would see that report in the very near future.
I don't have a permanent date as to when they will submit it to us.* I would certainly expect it would be within the next co~ple of weeks though.
But that study is underway.
CHAIRMAN HENDRIE:
But try to set a target time after which one would not ship spent resins unless solidified.
The six-months number sounds to you short?
MR. COLLINS:
I think six months is entirely too short.
COMMISSIONER GILINSKY:
Why do you need to ship resins at all during the six months?
Why can't EPICOR operate and the resins* then be stored and solidified when that process
- is available?
MR. COLLINS:
The resins can be stored and that was the purpose of constructing an:;onsite interim staging area, because of the availability of shipping casks to make those
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- COMMISSIONER*' GILINSKY: *.
But.this *wpuld*.* get away_ from.
this six-month limit, Mr. chairman? -.
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- MlL : COLLINS:
T thirtk* the. six mon th.s is not. very
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- realistic at all.*.*I. think.:it**is-very '-unrealistic,. six months*'
to do that..
MR. VOLLMER:
What you say _is-certainly: true *.
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facilities were constructed to.accommodate long_.:t:,erm, storage~.
- And I th.i..nk we talked about before* that the generation of re.sin would be a lot faster. if the* system.is.. used as expected.than-.
the shipment ~nyway.
- But the, _feeling was that rather. than -sort* of. getting.
. into,: the mode -of pi:li~g up wastes that' we felt. it.would.'be' more appropriate to. get it,out... But that certainly is another option.
CO.MMISSIONER GILINSKY:
As the Chairman s.aid*,. you '_re already off hy a factor of* 100,.
Arn I.recalling* you* correctly?.. -
CHAIRMAN HENDRIE:
Get*the stuff out of the water is my aim.
COMMI_SSIONER AHEARNE :.
on* the question of no free....
. standing water criteria,. do. you intend to.comment on that?
MR. COLLINS.;. I believe.that' they go on to say that. the licensee has undertaken tests* to derrion~trate *no_
- free-standing water:/ and; those* tests have*_ been on-going.
I tve seen some prel:Lminary_'. resul:ts*_: from-: t:.ha t: and
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25 15 again I have asked the.licensee-to submit to us the documen-tation of the results of their tests to *show us no free-standing water in those resins:.
COMMISSIONER AHEARNE:
That would be a criterion that you would MR. COLLINS:
Absolutely, no free~standing water; no question about it.
CHAIRMAN" HENDRIE:
Go ahead, please.
MR, VOLLMER:
This is probably a good time to pick up the.comment that has*been made several places and that is what about the environmental assessment or inclusion of the transportation and burial.in the environmental.assessment.
In particular, I_guess the comment -- the_question came up as to whether or not the environmental risks associated with either the dewatered resin shipment or the solidified resin shipments would.be much different, and I think we believe that the risks associated with the -transportation of the. de-watered resins or the solidified resins are roughly equivalent.
_Both of these would have to comply with the same federal limits for contact dose rate and dose rate at the site of the trailer.
So each package, be it solidified or not, would have to be shielded as necessary.
Also, the NRC and DOT package requirements would have to be satisfied so that the radioactive content.would be in-
-an overpack capable of with.standing a 30-foot drop test, the I
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25 16 fire at 1475, and water immersion.*
Things are somewhat equivalent from an environmental assessment point of view.
The only major difference that we can see on the solidification side -- and*I would like to re-characterize it as not a major difference.
If the resins are truly dewatered as we would require them before shipment, we don't see a major transportation and/or burial problem.
On the side against solidification, we believe that it will involve more operator exposure to go the solidification route, but I think a careful_ assessment and preplanning of the system that is used for solidification will certainly mini-mize that.
And that would be one of -the criterion that we would look very carefully at in assessing that system.
So I guess on balance we would conclude that there is no major environmental difference between the shipment of the dewatered resiris or the shipment of the solidified resins.
I think, in my view anyway, it would be more of a policy question of how quickly you feel it is necessary to get the resins off.site as opposed to waiting on_ an interim storage basis for a solidification*process to be put into effect.
But I don't think on balance it would affect signi-*
ficantly the transportation issue.
COMMISSIONER AHEARNE:
Since you have raised the transportation question, could you comment on EPA's question-ing about the perhaps need for special packaging since they
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25 17 conclude that the.resins are so different-than the.normal resins?
MR. VOLLMER: - I think the packaging issue really gets to -the integrity of the package and __ the dos.e rates, the surface dose rates and the dose 'rates* to the trailer, and whatever the-isotope involved" we would require that these basic criteria be_ met.
This just got stuck in front of 'my nose-and John hasn' t seen -it. _
MR. COLLINS:
Can we come back to this?
COMMISSIONER AHEARNE:
Yes~
I just received it, too.
It's easier *to ask a question than to answer it.
MR. VOLLMER:.
Okay. *.On page 4 of the OBE memo, Item 3 lists a number of suggested question for the Staff, and I would like to briefly respond to these, _ and again I think we do characterize a lot of the major issues that have been brought up.
The first one deals with the*issue of--
The EPICOR system has a pipe fo.1r transfer of contaminated liquids between the-auxiliary building and the EPICOR II building, and the question*would be how would such leakage in that particular transfer system *be detected?
As we indicated before, both the pipe that is used to transfer the liquid.and the guard_pipe which surrounds it and that in turn is surrounded by concrete which you can't
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25 18 really -give a great deal of leak integrity credit for anyway, but the first two, the main pipe and the guard pipe, are both seal-welded and tested.
And the guard pipe itself does.drain by gravity flow into the EPICOR II building sump where any accumulation of leakage would indeed be detected.
So we feel that _if a leak did occur on the system which was somewhere between. a leak that would be not detected because you're.missing some -of. the water that you think is going into. the building but still it is a measurable leak rate, it would go in to the sump and be not only held up that.way but also detected.
If it's a very small leak of course it would take longer to detect, but we think it's an adequate *cure for that.
Item 2 on the system testing.
I think we mentioned that a few minutes ago.
I also would like to mention that during process of the water itself there is monitoring of the potential leak rate both by the sump levels--
Perhaps you can see it in the airborne. contamination.
If it was a mist it could be carried along.
And you.also have TV monitoring the system.
So.we believe :that there will be careful*control and monitoring of leak rates in the system.
And the addition of the licensee's commitment to pressure test after each replace-ment will provide. additional assurance that there.won't be any major loss of contaminated water when the system is first started i
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I think this would adequately cover the issues addressed in that point.
19 Now as far as the precautions to be exercised during change-out, as you know.the handling of resins and all of the activities associated with change-out have been very care~
f.ully procedurized.
These procedures either have been or are being approved by the people onsite.
The procedures include health physics control.
And as a last point we have gone a few yards further in this type of an activity and we haye had an NRC audit of the ope-rations and training of the operators who do this activity by a member of our Operator Licensing Staff, and we 14 are satisfied that the people who will be qualified for opera-15 tion of the system will be adequately trained to perform all 16 the operations, not only trained to perform the operations but 17 trained to know what to do in a contingency, a malfunction or 18 some other type of emergency.
19 We do not intend to have any specific NRC monitoring 20 of each particular change-out, but we feel that the controls 21 are routine and surveillance of what's going on at the site, 22 in addition to our approval of the procedures and review of 23 the training, is an adequate overview of that.
24 On Item 4, the highest radiation levels will be Ace-Federal Reporters, Inc.
25 handled within the shielded transfer belt.
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8 20, And why is* the mi~~d.-bed :deminerali'ier *unit not *.
handled this way?* Wel'i, tworeasons.
THe first One is. that.it WO~ It' fit~ since. this particular.demineralizer unit'*is 6. foot by *6 *foot, and I be-lieve the. other on~.is. a' 4 by *4 **...
- But* even. so it's not imusuaI to handle.ac'bi\\l'ity.in-filters and.. so.. on* of this type, of a: dose rate in operating facilities..
And EPICOR II which*. has been utilized both before.
9
- and during and.since the accident EPICOR I,.excuse me.
10
. EPICOR I., which has be!;ri utili.zed before. and since.the: accident,
.11 is handling* routine_ly filters at this dose *1evel *..
12 I 'think the. training is ad~quate.
The experience ~a.
. 13
- _. been good/ *and a* number of the~e EPICOR I __ fiTters have:- already>.
been put in* the storage facility..
15 16 MR.* COLLINS: -. I ~01ild like to add. just one *thing on.*.
that.
That's *an upper bound e~timate on. the 20 rem.
Given 17 the efficiency, the* re~oval efficiency,. for.the two.upstream 18 demineralizers. before it reache_s that *third one, _ more often 19 than not, that's* going to be much_ lower*activity level than 20 what you see here.
For the purpose *o.f evaluation, we \\ upper-, *
- 21 bounded that -*number.**
22 MR. VOLLMER:
Oh it,em 5 we.did talk. about the* de-23 watering tests 'INhich are being done.
- And as far.as. the..,.trans-24 portation issue, I think the Commission. has *seen'about.a month*
Ace-Federal -Reporters, Inc:..
'25 ago a paper-which was sent-down which outlined.the procedures
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25 21 that.were required befOre any waste *shipment could.be sent from the si.te ~
And these.included a fairly* detailed checklist by the licensee as well as a checklist and approvals by the NRC.
And I think we would continue that type of a procedure and *we would use that to assure,ourselves that anything that was shipped offsi te.. indeed met all. the criteria necessary..
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I 25 22 Unless John wants to c.ornrnent further* as far as the I free ~_tanding criteria, we believe that that can be accommodatef and documented, and that we can get adequate assurance that I
a process control applied to the dewatering system will assure that continual basically dry resins will.be achieved.
And if that I s not the case then we '*11 certainly go back to the Commission.
And, in any event, as John said, we would not ship resins that we felt had any free*water.
They would need to be vacuum dried.
Item 6 I think we also discussed..
That was the solidification problem again.
If there are no other questions I'll go *on~
MR. SNYDER:
A minor one, Dick.
On Question 3 you didn't mention whether there would be any restrictions on handling of the. casks outdoors during inclement weather.
MR. VOLLMER:
I'm sorry, MR. COLLINS:
At this time th.ere*is no restriction placed-on the handling of rriaterial in inclement weather.
It is in a transfer bell_ moved outside* and placed in a shielded vault for transport to the staging area._
So I don 1't see* any need to limit the operation because of inclement weather.
MR. VOLLMER:
I ihink good sense would probably dictate, if you were in the middle of*a very severe storm or
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25 something like that ope.ration.a,l-ly it couldn t-t *be..accommoda.te.d_ i But if the thrust.of the_question is inclemency in terms of getting water on the thing, I think.,.._..,..
Ml\\. SNYDER:
Just mak..ing it more diff.icult to handle, especially the one that is not_ going to be *inside. the bell.
MR._ COLLINS:
It wouldn tt impair the handling of it at all because of inclement weather.
You may, because of certain high wind conditions, restrict operation.
But that's a normal safety precaution that 1s take. on many outdoor activities.
And it certainly could be placed in the operating procedures.
Just because it-rained-or-snowed shouldn't affect the operation at all.
MR,. EILPERIN:: A couple of questions.
At one point you said that if the EPICOR II didn **t decontaminate down to the factor you wanted to decontaminate to you could change the resin bed.
Or one other alternative was to put the water in holding tanks.
I thought the lack of holding tanks was--
CHAIRMAN HENDRIE:
Steve, could you hook up to the microphone system one way or the other?
MR. EILPERIN:
I thought that the lack of holding tanks right now was a constraint.
So I was wondering about that alternative.
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- MR~ COLLI!'JS :*
I 1:liink:'what 'o'ick was. l~ading' to was..
- *that'*if the water came through. the.EPICOR system: and did--not-1 meet the. specification-.eitli.er for.*re_;use of.<the.plant or :for*
.disposal *it could*theri eith~r be recycled through: taking it into the off.-spec.tank* a11d recycli11g._it back 'throtigh* the
- demineralizer, changingc Q~t th~* d~mineralize:rs.and putting in
- fresh.resins~
Or if*it were:found,:because of that particular.
- a batch, *the resin that was in there was not effective or. had*.
9 red_uced efficiency 'to it,* the type. of resin.. itse.lf coul.d. be 10
.changed.
11
- All the ma_terial processed* will.be backsampled *
- 12 13 14 15 16 17 i8 19 and analyzed for *its radioactive.- *co11;tent and its chemical
- content prior to being,:*processed thro~gh'there,~
Now there would. be. other tanks* that would:. be.
- available because you removed that water from.a tan~ in the
.auxiliary building.* That water.could a.lso then be moved.. hac~.
.to. that tank *.
MR. EILPERI.N:
An_d what about. the. ope.:r;:ati.ng procedures:?. Are those available n.ow?.
- 20 MR. COLLINS:
The ope.rattng p;i::,o.ce.dupe,s_ ;for th.e.
._.EPICOR II system, about :90 percent of;. all opepating. proce.dure.s.*
21
- 22
> including emergency and ai'arm procedures h.ave. been comp;Leted 23 24 Ace-Federal Reporters, Inc, 25
- and* approved.by. the NRC *. *. There* _are a* few. *remaining~ and
- they are being worked on, at the present time. by the staff~*
COMMISSIONER BRADFORD: *. When w;i-.li they be I
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I 25 1.... compl:eted?,,
2 3
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'MR~ COLLINS:*,' All.,Pf '.the' op~ratirn3': procedures'
- .should be completed by the*.end.of th_is' 0'week.*.
- COMMISSIONER KENNEDJ:'.'.:* : When you say** there are a.
- 5.
. few rern,ainirig,
- they are.. compietecL but are und*er >review by.the.
6 7
9 10 11 staff;
- is that correct?* *
- MR. COLLINS:*. That ':s:. correct.
CHAIRMAN HENDRIE.:**
- Are th.e.r,,e. 0th.er questions. o.n this point?
'GO ahead.
MR. VOLLMER;'
The. fi:r;:st i.tem.was: the limit for the.
12
. water cle.anup,to p~~determined le.ve.ls ;. And. as I indicated.
13 14 16 17 i8 19 20 21 22 23 24 before, Our.thrust there was *that *o:Ur< pr-ede:termin~d,,ieve.l woul9,c-
- .be* such.that *certain.. options -fo:t;" water d*i.sposa): could be exercised. *. And we didn't fe.e1* at 'this point. in.time tha.t it
. was.necessary to provid~ a specifi.C.decon.ta,rtlinatio:ri_* factor for' each-isotope. in th.e *water.. *
..
- w:e' h.a.ve: given what,.we. felt:
- were,. based on our ~ther
- experience., de:con.taminatton fa.ctors that we fe.l t* would* be achieved..
And.,,. if they a:ren '*'t *achieved,*
again, *the process John* just alluded, to;~..-. we could put th.em_
in. appropriate.* tanks, hold *them up* in,secure: ways. to e.ith_er I
upgrade the system or. to.. provide the. additional. a.e.contamination necessary~.
COMMISSIONER -BRADFORD: *. You say you have: given Ace-Federal Reporters, Inc.
25 those lev.els?
I
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25 26 MR. COLLINS: -.,No.
We have nbt-.,..
Well, the levels that, have been given* are basically~-
-- The initial c:;:-iteria were that the water should meet; if-it were to be discharged to the Susquehanna, that*the water*would have to meet-10 CPR Part 20 and Appendix type limitations; that is, downstream dosage considerations, as well -as th.e point of discharge
- considerations.
Now, recognizing that*the. disposal alte,rnative.s have not been assessed, this at least provides us. with_ a_
benchmark from "Which we could judge the. system adequacy.
A_nd we feel that would be most appropriate when we,found out wha_t water~ or what decontamination factors we did achieve and what the water was like *an_d.....,...
, COMMISSIONER, BR,ADFOR,D; So those are. the level_s you will be. using, then:,... to d.e.ci;de. whe:ther-you would have to put the water back. through th.e system again, or-change the.
system somehow?
MR. COLLINS:
Yes.
MR.* CASE:
- If *that option were. ch_osen._
COMMISSIONER BRADFORD; If somebody wants to know what an unsatisfactory level would be,. h.e sh.ould_go to Appendix I?
MR. VOLLMER:. As far as.,......
Okay~ Appendix I: is dose.
evaluation. _
CHAIR.MAN HENDRIE.:
Certa;i_n_ly i.n_ te.,rm$ _ of exposure.*.
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25 27 COMMISSIONER BRADFORD:
And then what should they do to get the number that~s going to tell you that the system isn't performing in-the way that you want it to?
MR. VOLLMER:
What they do is backcalculate.
Itts a very--
- Since it*s a calculation of dose in the environment back to a level of activity in an undetermined discharge. point,..
that would be difficult.
But the. water, in terms of meeting Part 20 requirements at the discharge.--
John, how would that.*.
MR. COLLINS: You would have to backcalculate that, too.
MR. VOLLMER:* Based on dilution. flow.
MR. COLLINS:
It* has never be.en standard practice
~o set decontamination factors on. pieces of equipment.. B.e.cause a decontami_nation factor varie.s wi.th the. input concentration of the material.
And then it also de.creases with. time.. The number of bed v:olumes passed through a demineral*izer, the _D.F may start up very high and become.s -- or starts decreas*i.ng with.
the number of beds, the volume of water passed through. it~
So what you 1*re trying to a.chi.eve is that when you have that water processed, that batch proce.ssed, you're trying to achieve a number.
If it were discharged.then you would take a sample and analyze it such that none of those concentrations of radionuclides would exceed those in Part 20 for unrestric.ted release.
So if you're saying, Can you backcalculate?
- Yes,
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you :.could backcalculate *.' If. you s*ta:rted off with:*the. uni-estric -
- 2 i ~d ar.ea, *. Pa~t 2 0 concehtra ti.ans; : and; applied 'those.in the')
.process tank,. that* is *\\wh.~t the>eff luen:t would ha,ve* to: meet 3
4 5
6 a*
9, 10 1.1 from the.EPICOR I.I. system~... **
Knowirig that, **and,your input Joncent~ation, from a
.. ~:. -:
. particular batch, would be the f~econ"t,am;i.nation facto:i::'.that:*.. that.
- ~---
particular batch would have. to achieve.
COMMISSIONER BRADFORD: *,Well_, you see what I'm after.
You :said in answer to Be~n.ie 's question* that the~e.is
- some level *of. performance **that-you expect of the system, and
. if it q.oesn' t meet it there ~re. cer.tai~ actions that you have*
12'
- to. take*
. And _what I take it this other ques t.;t'.on. is after,
.13 and what 'I *m trying -to. get at is how }10'\\l, wilL: decide whe:the.r.*
14 the.. system is performing 'in that way, what*. numbers are you 15 using *.
- 16
,MR. COLLINS:*** I:f
- i.t were de.cide.d that the water 17
- were to be discharged, -:that particular. batch. after. it has
- 18 been processed "'."'"-*and. rec<;:.>gnizing th.at *we.tr-e. proce.ssin.g
- a,ll
- 19
- the water on -a batch. basis....,.. *th.at would be. *cin.aly.zed a,.pq if
- 20. *
- those values exceeded Part 2 Q values for" i.ns:tantaneous ;t'*e.lease>
21.... it.would have.to be reprocessed,.
22 23
- COMMISSIONER BRADFORD,,*
Le.t l:5
- se.e.; th.i.s. is a,.
process,that has* to-~ lf
- we were to., say,. start usirig EPICOR:
24- **as soon as, we can you'd have water coming out of.. it.; h.ow loh_g
~ce-Federal Reporters; Inc.
25 from.now?
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. *:,::MR~-, COLLINS:: 'If* *approval v,~re __ *given tC?day:,.
. _. probably by. the end.. of.. the: week_.o:t th~ b~ginning. of *_hext we_ek 3
water-could be. bei11g processed, 4
COMMISSIONER BRADFORD:
., ~gain, how* would you* know.
s whether that water, 'wheil.i:t: firs.t. came out,;r*was being *handled:
6'
.* to a s~tisfactiory degree?
7
.COMMISSIONER AHEARNE.*;
S.;i.nce.' you would. not hav*e at a
that time a_ny decision on what to do_ wi.th. the wat"er,:. All you 9
would know is.that the water is.going to stay onsite.
10
- MR *.. COLLINS: You \\_re still a.pply:j.n_g the. same value
- 11.
whether it" is being.. _ disposed.,of. -or stored.
12 MR~ VOLLMER; We use th.at as. our disposal*
13 *. criterion;*
14 15 16 18 19 20
. 21' 22 23 24
. COMMISSTONER GIL:;ENSK.Y:
And what is that?.
MR. COLLINS:
Pa,:r;t 20 i
- COMMISSIONE~ GILINSKY; It \\.5 expressed in. what units?*
MR.. COLLINS*:. Mi,crocurie.s pel:'":"*.,..'
- MR.*. SNYDER:
. It ts. b.y isoto.p~.. a.lso, iri.d.ividua).
isotopes, specific activities* for unre.stricted
- r*e.J.:e.a.se, Tha,t seems* to me to _be a. reasonable thing~. I_... think. it. would have.
been helpful if the assessment h*a.d. s~:id *th.at; You have to_
have some measure* of _how effective *your sysd:em.is_.
That **s the point of tbe questitin.
- . Ace-Federal Reporters, *Inc.'-
- CHAIRMAN HENDRIE:.** Let-me_ see *if. I can confuse the. J 25
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- iss-ue. further in.the interests
__ of clarifying, things_ for myself.*:
- -Presuming "the water,is:. to '.1;>e: pr6ce.ssed :in Some.
~.
fashipn,, EPICOR or whatever,. at.some -point you' would rega_rd it as adequately processed, one i:iass through the sys-tern, -or two,
- or whatever it: t~ke.s *. ---
Now will th.e0_effluent from* tha:t:- bl:ack. box;' T will '
call adequate.. processing:: for* th.e :present purp;$*es~-.,.._ 'Now-.this water is headed for storage;:, it ts not h~ade.d'for:.-th.e river or*
tank ca:rs to: take
- it to who knows where.; it _l*s* he.aded for
- .storage: onsite *with "dispos~l *to be-.de:t;.ermine.d--late;r--'":
- Nevertheless,:Part~:20 concentratton limits:*would :*apply*;to tha_t at that point?
Now-what* that meah:s _ is if you ha,v:en ~~t_ -got _:J?a:r-t 20. _ -...
limits coming out: on -the* first pass_ throug~. EPICOR II,. -why,,
you' re* goi*ng to. put it ~v~:r: into -recycle. and run it again?
MR. COLLINS*:
That':s. correct~
-CHAIRMAN -HENDRIE;
- Tha_t. sounds. to-* me, *like..,,.:*-:- J-$ i.t _
clear tha.tthat'-s what you:want.to_ e.stabli.sb.n
- rt I s not clear 't~ me that.,.....,.
COMMISSIOl;*rnR GILTNSKY; Is th.at* too lax or.- too strict?*
- CHAIRMAN HENDRI:E.;,.
Look., th_e_ nat.ure of. th~!;, ic:iri exchange system* is* that even *when,.:j__t isn It working a.s _ we.11_* as-
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~-~--~~- ---- --------------
31 you m~ght like. it,.it,~ s. still: goi:r;ig to g_i ve you a deco.ntamina-tion* factor well' above a hundred.~: *I'.11 guarantee'.that.~
And I' 11 pracd:ically<'guara:ntee above a tho:usand.
And it ~s 1.j:kely:
to* be up._ in the 10 4
- and ~bo;e range. :,.*
NOW* if.you take.one pass*of contaminated water,,
then, through this*. system;,even* if**:it doesn~*t* me.et. Part 20 limits when it ~omes ou:t you *ve*.accomplished an enormous step forward in public health, and safety of_con~entrat:.ing_and_
fixing the_ bulk *cif the radioactive material, 99 percent,' 99.9.
or 99. 99* percent.of the materia'l.in a.* form*. and* in-a place whe:i:--e it can *.t easily get back: to th:e human environment;. *okay?
- So. that iri terms.. -of a health_ and :'safety step*,* why' neve:i; mind whether.. it meets. ]?°ar,t.20. out.; the.: oth~r end: that.ts.*,a..
problem we' 11 deal with in terms of* any disposal options..
But you have* accomplished. a very substantial _benefit; in my view,.in getting. the 'fission products.out of *a fqrm where, if the tariks leak or somebody turns. the wrong valve. or a-pipe bus ts. it Is going to be* messy *down. there and it' s going *to be a,
detriment.to the public hea_lth.andsafety.**
Let's. *ge*t this stuff,on the ion beds~*. And if we
_have to make a.one pass through.all the water and take it out
-at a part in. a thousand and still'not have--Part*,20 concen-trations on. the. stuff that.'.s
- le'ft-, you have.still taken. the great bulk of.it and* put it in a. *form.where it can't: get to people,. and you have. reduced the residual risk down, there. by... * *
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, that,much.>-.
Now the :que:stion; of wb.at you then-. do and what the.. :
concentrations ought, t~ -be_ wherf Y':m
- consider dispo~fal options., _
evaporation, -- discharge to the.river after dilution with other
- stre~ms through. the -plan:tr :shlp it,off~ite.:~~--*- I dontt know*; -
make. concrete :with it or whateve.r'You want to d_o_ ;with it,.
those certc3.inly remain to' be consi_d.ere.d ~-
One is going to ha.ve_. to-talk. ab.out certa.t_n_ly -
the Part_ 20 r~gulations, about the_ Appendix I limits_ and exposure of the public, which re.quires -really very low e:fflu..-.
ent -- _ amounts in_ the effluent.;
---, Now-," one of the 'things that h.a:s. bothered the
-pres.ent _ environmental as-sessmeri'-t is* th.e staff '*s.trying to say,.
Look, we aren '_ t quite sure what the disposal option*. chosen will be.; that you need.to know what the disposal opt1:on is and what other factors are., such as: a di.lut.ton be.fore r*elea.~e.,.
- I before you come_ ba_ck and determ;Lne. wh.a t th.e *limiting, concen""."
tiation of_ a* radi.onuclide is in this water which. will be. stored in tanks on_. the island *.after. having-beeh processed through EPICOR. - And "it ts because: they. aren 1t sure -~hat _to, say -about tb.'
dilution _factor in-particular.that they are leery'-of*quoting a limiting concen-tr:ation as the output -of this first'.pass*
. And it *is similarly the difficulty _if you say,* to anybody, Well I won't,tell you.what the. concentration is.but.I'll
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25 33 tell you that'we're going to apply Appendix I downstream where anybody could be exposed,. and let. you backcalculate.
Well, you can.backcalculate from the dose.
assumptions about exposure downstream if itts a discharge to the river case.
But eventually you_ ge.t back and your calculator will have to know what th.e. dj.lut,i:.on factor is before he could get back into the tank. wa.ter concentration~
And without that being defined..-.- and. it is not defined at this point -- why, it 1 s hard. to set a..,
- you really can 1:-t set a definitive number.
But I ihihk what we. want to keep in mind is that even without setting such concent:.ration limits on the product..
water from EPICOR II, that passi~gthe water through that system indeed removes the bulk -- and I'm talking about 9.99 parts out of a thousand,. or something like. th.at, of the radioactive material.
You know, an enormous step forward in reducing the hazard from this stuff.
Now I'm not sure where we. wa.nt to_ go with. re.gard, to trying to supply some sort of concen.trati'on_ limit numbers here in our discussion here of the. environmental assessment-or in any subsequent action we take,.
The Staff has been reluctant to do so other th.an to talk about Part 20_ limits for concen-.
tration.
But I'm not even-..-
It 1snot clear tci me.th.at you want to hang that on this system for th.i.s first processing step.
That is, I would rather pass all of t_his* stuff through.
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25 34 EPICOR II and_get the_great bulk of the radioactivity fixed in the resins, and* then look at the product water and decide that this batch and this_batch and this batch still have got traces.in them that are too high :for.any of the discharge options I wanted to consider, and th.en recycle them, you see, and pull it down.
I think the. game is. to get the bulk* of the. fission products tied up in a form where they can tt get back~.. to people.
CO:tv"'iMISSIONER GILINSKY:
H.ow do you see th.at their proposal interfers with. that?
CHAIRMAN HENDRIE:
I don tt see it at all.
What I see interfering with it pos.sibly is a concern that we.
can I t go forward* unless we set specific radionuclide. concentra~
tion limits.. And then th.is long discussion of mine. is saying simply I'm trying to clarify.
COMMISSIONER AHEARNE.:
But if you move on to absolute limits are you sciying thaf you would be in favor of a relative decontamination factor approach? '
CHAIRMAN HENDRI.E.:
I. would run this stuff thr*ough.
EPICOR and say,whatever is done with. it, that the product stream is going to go back into tanks for storage, and it isn't going togo anywhere else. until we talk about it h.er*e_
and there is an environmental a.sse.ssment on it..
And r wouldn_ "'t put any. limits -on it because I'm confident that even a pass toward the end* of the life of a. bed is going to takeout the.
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25 35 great bulk of the. radioactive materi.al and be. of. considerable benefit in a public health and.safety*sense,.
At this time I would not set decontamination factor or effluent concentration performance requirements on '*the system.
cbr-'!MISSIONER.KENNEDY:
You.would wait to do that until you know what the disposal system is.
MR. COLLINS:
It was the intent of the staff to include all of that in the next assessment of the disposition..
It will all be discussed in detail.
MR. VOLLMER:
I might clarify: On Part 20. it l*,s not clear to me that*for tritium you woulc. have the processed water through EPICOR meet Part 2 0. requirements for-tritium.*.
CHAIRMAN HENDRIE:
Just so~-
MR. VOLLMER:
As you point out, th.e bulk of-...,.
CHAIRMAN HENDRIE:
I think I. can he. very cautious*
about saying Part 20 on.the effluent from EPICOR.
But we want to keep. in mind that we ~ve_ got........ that th.e water we.'*'re.
talking about for EPICOR is ----wha,t? ;,-.,.. a quarter million gallons give or take a couple of truckloa.ds of material with fission products in it. -What we're proposing is to run it through_a chemical process system*and put it back in the same or similar tankag~ with amounts of ~adioactivity in it that are at least a factor of a hundred and. more. Likely factors of*a thousand or ten thousand or more less.
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. 0' MR~. COLLINS.:
That.ts correct~*
2 CHAIRMAN.HENDRIE:.}I_,*find.:,it':very hard: to find-a 3
difficul,ty for. the 'public health and safety there;. and I find.
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- considerable 'benefit for it.
Arid~ that{s -quite apart from ; :.*
5 whether* in turn,' the~; the,cconcentrations in:those_ t~Iiks/after*
6 process+/-rig *meets any sort of:,:~,meets,_ the. criter.ia,for. any_*.
7 particular dispo~al metl:lod,<<**.
8 COMMISSIONER GILINS:KY:_-.*W.e.11, le.tts*see:.-"="*
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. understood Mr. Collins and Mr.* Vollmer to be sayi.ng th.at they
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10 we.re aiming tQ get below the Part 20._ lirn:i.ts.
Th.ey would simply 11 recycle that--
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CHAIRMAN*.HENDRIE':._-** Thatls what I unde.r-stoo.d *them*.
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- to say, too. -AndI 1.m_saying_:.be:cautio'us*,,.that may*:not be.
- 14 what you want to do.
15 That is,* I hate. to see. you sit. th.ere. because of 16 tritium -limits or something.lik.e. that* and just r-e:cyc.le.arid 17 -
recycle two or three passes from on:e._. tan.k, while. all the*'rest' i8 of th.is contaminated water sits th.ere. waiting-. for you to cb it,_.
19 I think you :ought -to take. _it.all t_hr*ough the. system, on,ce.*.
20
.COMMISSIONER GILIN$.KY.;
'That *:s ju.st the order* in.
21 which you do things.
_22 CHAIRM.;.N HENDRIE:._- __ Just so *.
- But if you.. say once -
I take~-
Y~u know, it: all. depertdS Ol'.l how these. things g~t
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- _. written_,up.* And I 1ve se.eri* us write pr:escripti.ons wh.ich. say*
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25 - *. once you take the. water* out.of that. system and_ -start -it into
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25 37 the processing over here, you can't put it back.until it meets certain concentration requirements.
- And you*can then get*stuck going around in circles over here. in the process in order to*
meet that.
In the meantime,- all the rest of that stuff out there sits there unprocessed.
COMMISSIONER GILINSKY; But youtre not saying, are you, that once they have. run :it thro~gh and. gotten it de""'.'
contaminated that they shouldntt run it tb.rough_again to get it below Part 20 limits?
CHAIRMAN HENDRIE:
You betcha,* I 1m not saying that._
It's got to be be.low Part 20 limit$ for any of the di.$posal options*that, you know* --
COMMISSIONER GILINSKY: * ;{ou '*re. just te.lli:ng theII\\
to do i.t in the right sequence~?
CHAI.RM.AN HENDRI.E.:
I 'm te.llin.g them. to do,tt in.
the right sequence.
I'm also cautioning them *not to tie.
themselves up with unnecessary or* perhaps even unwise ov-er..,..
requirements on the system that might impede getting the. bulk of this stuff fixed on resins instead of sitting there in tanks-COMMISSIONER KENNEDY~
It'* s not a question of whether, it's only a question of when.
CHAIRMAN HENDRIE:
Yes.
COMMISSIONER AHEAR,NE:
If I. could a_s.k. a que.st.;i:,on on the when.
Let me ask, for an assumption, assume. that. TMI~l
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Since pa.rt of
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25 38 this is precipitated by the fact.that you have th.is flow in so you are increasing the amount of water that you want to run through, there is a limit to how much of the water you can run,through EPICOR.and put back.into the tanks from which it came, as the Chairman just indicated.might be the solution, so you're going to have to put it somewhere else~
Now to put it somewhere else and not put it in TMI-1, you are going to have to bring it down to SOJI\\e. leve.l, aren't you, below what it currently is.
So therei.is some upper bound that it has to be below in.order to put i.t in that other set of tanks.
What would that be?
MR. VOLLMER:
That.would lik.e.ly be. dictated* by sh.ie.lding considerations.*
I£ it is in,. f'or example., storage in the 130,000 or so gallon tank in the EPICOR buildi1:1g itself, that is a relatively unshielded tank and ybu would back-calculate if there were any shielding problem._
With the decontamination factors we. expe.ct of th.e.
system, we don't feel that th.ere would be a rroblem in storing it th.ere.
For a decontamination factor of, say, something like 100, then that wouldn't be a very prudent place to store it and you' re right, we have to be very selective about our ~--
COMMISSIONER AHE,ARN:E:. At 10 4.would it be.,....,...
MR. VOLLMER:
I would imagine that certainly at 10 4 or so you would have a great many tank.age options that you could be living with. And certainly if you cut down to a_gross
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CHAIRMAN HENDRIE:; *, That:,\\ s a very good pointf
- John,.
- and does _,pro,~id~ an incentive,.. in,: fact,' to g~t good,dec,ontami;."-,
nation fact~rs> B~cause, in fac~, ::if yoµ can get' dbwn. to*<~
-very low concentrations, then' as Dick.says your options,on.
temporary tankage are, verT broad*. T'he higher the level bf contamination in* that water,* why_ the more _limited those options
- are...
COMMISSIONER AHEARNE:,. That -was my conce;tn.,,
CIIAIRMAN. HENDRIE:> *, A very_, good point.,'
-**_.COMMISSIONER *BRADFORD i *. :_:ts*, there*: a-re:lationph:Lp '* *
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between Appendix I nurnbers*and the Part 20 numbers'?_
- MR. VOLLMER:.* _No, th.e. Part 20 numbers are numbers in terms of. either_ gross contam_ination or specific. isotope_
contamination, as set*out*-in Part-20 that must be.*met at.th.e.
point of discharge..
- Now if that* point of. discharge was-into* a fre.sh **.
water. :i;-ive:r,. :then you would have. to assess th:e dilution* provide 21
_by that river, the uptake* in the. aquatic spe.cies..in tha.t river,*'.*.
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, and-possible public water intakes' downstream and. do a, dose.
23 24 Ace-Federal Reporters, Ire.
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- asse*ssment and* see 'to _meet Part 20 -that no-pe:rson. wou,ld like.ly *
. receive more than three.millirems.,.._.,...
- to meet Appendix' I_~:
- If y01~.
were di~charg+/-ng,,ihto a' salt water environment, th.en of <cour:se I.*
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25 40 you would.not have the public water intake.
So it depends on really the environment and what happens after it's put into wherever you're putting it, and the dose assessment from that, includi~g recreational uses, fish uptake and water and so on.
So the _ -.two are difficult to equate.
But as far as Three Mile, my recollection serves me that our discharge limit to meet Appendix I values, for example, would be on the order of 10 curies a quarter from the.
site.
And for from the time of.the accident up to now, I think all the releases summed over that time has only been abou a half a curie.
So we feel that this operation would be-..-
COMMISSIONER GILINSKY:
Half a curie to what?
MR. VOLLMER:
Total.
Half a curie ar.e those* things which we would normally use in.the Appendix I calculation.
What I'm saying is what has gone into the river now would be allowable discharge from TMI-1 and from the industrial waste-water and so on is on. the order of half a curie**
In other words, th_e. allowance to meet Appendix I, for example, would be about 10 curies. a quarter, and th.at I s what's contained in the current facility tech specs.
Those are predicated on the.dose calculation for drinking water,.
recreational usage and fish consumption.
I 111 run through ve.ry briefly th.e re.st. of these,.
The alarm setpoint, this is in Table Two --- listed in Item Two
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41 at*the bottom of page 5, we did make some corrections in 2
response to the public comments.
One of*the corrections 3.
wasn't made.
The alarm setpoint wi.11 be about 2 0 percent of 4
10 CFR Part 20 release limits.
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was written our noble gases and iodine.,. which would like.ly provide the only.gaseous release from EPICOR, have suffered another 10. or so million decontamination by natural decay._
We don't'think this will be any type of a problem or that there will be any measurable. re.leases.
But., tn a,ny event, the monitor will be set below the lQ CFR :ra.rt 20_ discharge*
limits so as to provide assurance tha.t.i.f, tha.t limit i 9.
reached and the. alarm is sounded the. operat:j_~on can be shut down and you would have a fair ma,rgin of p;r:-ot~.c.tion,*probably about 10 3 dispersion be.tween th.e point of re.le.ase. of Part 20_
material and the ne.a,rest public exposur-e.._
So we. think youhav,e. a. fa,:j;_;i::,ly adequate "'.".,,..* mope th.an 18 adequate limitation on the se.tpoint..
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- The type of monitors;-*":"'
- . John, can you a.ddre.ss*
20 that?
-, 21 22 23 24 MR. COLLINS:
It 1,s a_ gross gamma,. beta. a.nd iodin.e. *,::--.*
or particulate and iodine cartridge on--
CHAIRMAN.HENDRIE:
Volume, John.
Volume..
Ace-Federa*I Reporters, Inc, MR. COLLINS:
Volume?
Oh, the sampling rate?
25 Oh, I 'm sorry; you want me to spe.ak up.
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25 42 CHAIRMAN HENDRIE:
If you will please shout at us.
MR. VOLL~R:
Item 3, the benefit... impact assess.,..
ment.
I think we've covered that adequately.
CO!V"MISSIONER BRADFOR,D:
Item 2, the same kind of question again.
There.is a set of numbers you can get from the. people. who made that comment, what.the se.tpoints ar*e?
MR. VOLLMER:
- Yes, They are. spe.cified.
We can do that.
Item 4 was the question of the. testing of th.e, floor drains.
I che.cked on thi.s thi.s morning,. and I unde.r~tand that' we have checked that th.ere. is no interface and they are not connected to the storm drain.
COMMISSIONER AHEARNE.:. They suggested a dye. test to make sure of that.
MR. VOLt.MER:
Okay.
In the. detaf:led *comments..
MR. COLLINS:
Th.ere are no drains connected to the storm drain in the chemical cleaning buildi~g..
Th.ere. are
.none.
MR.* VOLLME.R:
I gue.ss th_e que.stion is, put dye in
. there and see. wh.a t you. ge.t.
COMMISSIONER AHEARNE.:
Tha,t was the. proposal, as I recall.
MR. SNYDER:. It was from, th,e. State. of Pennsylvania.
COMMISSIONER AHEARNE:
They suggested a dye te.st just to verify.
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MR. COLLINS:
You put the dye in the drains and check the river and see if you
.. have. any c:J.ye~
I don't know how it would_. get out there.
43 CHAIRMAN HENDRIE:
A.re there drai.n$ in the building'P MR. COLLIN$:
There. are floor* drains, but they all go to the. sump of the buildi~g.. Everything drains-into the.
SUir.p.
MR. VOLLMER:
Can we communicate. ba_ck. to the. sta.te.
and see if they would like to suggest some spe.cif.ic te.s*t~ng.
program and th.en talk. to the licensee?
MR. SNYDER:
I. di.dn tt under-stand the. comment eith.e;r.
And the purpose of that item here was just to bring it to the.
fore.;.
And I think. it rnigh.t not be a bad. ide.a. j us*t to check.
with the people in.the State.
Maybe. there is something here that hasn't been communicated adequa.tely in.1:h.e.ir comment.
If there is physically no separation it doe.sn_ l*t ma,ke. sen.s-e.
to--
MR. VOLLMER:
Okay, wet 11 do th.a,t, and make su;r-e the state is indeed satisfied.
Item 5:
Will EPICOR IT be. us-ed for* other water?
A system of th.is-type. could be~ used for oth.e.l'.'
water, but we at this point in time have not r-e.ce.ived any indication from the licensee. that h.e intends on using it beyond the processing of the. auxiliary building water plus wha.t ~.s in.
the tank farm and the spent fue.l building._
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is typical of what you would do for any process system that 5
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This is als.o a not too unroutine operation,. so I:
don't think there would be anything particularly new or novel about doing such an operation.for EPICOR~
COMMISSIONER GILINSKY:
Wh.en would that.be done if EPICOR is only expected to be used for a relatively short time?
MR... VOLLMER:
I. really don'* t kn.ow.
. It depends on what the licensee. would like to do with. that building, if he wquld find other uses for EPICOR or if he wishes to propose its use. for a broader activity in terms of some. of.the wastes that* are. either coming out of the ~*- that will be taken out of the re.actor building in the future., for de.contamination of tha.t~
I would think tha.t th.ere. a.re. us.e.s for the.
facility.
But, again, no proposal ha.s be.en made for that.
Item 6: --
I 1m sorry, Bernie, but T gue.ss we didn't quite know for sure *what storage space. you were concerned with.
there, whether it was solid storage space or~-
MR. SNYDER:
. Solid storage, I:.be.l.j.'eve.*
- And it was a comment raised--
Ace-Federal Reporters, Inc.
i I think John per-hap~
25 MR. VOLLMER:
I* do recall fua.t.
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25 45 could comment on what that,.-
MR. SNYDER:
This was Franklin and Marshall College*s comment.
MR. COLLINS:* Actually the long term storage facility is. built on the module con,cept basis, where you can add modules to that facility.
And i.t was de.signed that way, not constructed that way, designed., that way,. so that if a processing method were conce.ived for the. higher activity water you would have available a de.sign concept already in place to handle those things.* But the modules would be built on an as-built basis.
They were forward looking, Franklin* and Marshall.
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tainly *to* move :the*:waste off. at.the ea:C-iies:t possibie* 'tinie.*s6 that 'i*f*th,e.,storage:"~Pace.is.-notneeded it's -certainly there-4 *_*.for c_onting~ncy._.:- * :i: f the burial grounds were closed up for -an
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5 extended period ',bf' tim~:~r:.:somethirig like 'that, then the high 6
integ~-i ty storage *space would. l:>*e -~~ailable.,*
7 Item 7,: ho consideration-of dem.ineralizing at a...
8 rate equal to cask.availabi-li ty *. to avoid onsi te storage..
- 9 I think Chairman Hendrie' s* comments.* that the real 10 incentive her.e is.,to get on with. the'. job of* taking t_he con-.
11 tamination* out of,the liquid.*form, I. think that woul.d respond
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- to *that particular c.ornment.
Item.,8,. the same. ALARA :-.standard* should not. be
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S.everal pe()ple have made this comment,* and I think* the
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environment it need be. appli*ed~
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Indeed, i.t '. s _:.as low as reasonable achievable, what-19 ever the conditions: you' re faced with.
20 CHAIRMAN HENDRIE:
Did. the comment mean. we shouldn't*..
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do -- that.the. *cleanup should-not be *conducted so as* to.reduce.,
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- exposures *as* low ap reasonably achievable?,r don't. understand *
-the comment at all.*
23 24 Ace:Federal R~porters, Inc, COMMI.SSIONER AHEARNE:
I*.'think. the* 'comment was to *.*.
1 25 say that previously you had some set o-f standards established.
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MR. VOLLMER:
More strict standards because of the accident.
CHAIRMAN HENDRIE.:
As low as reasonably achievable hopefully means just that.*
MR. SNYDER:
But aren't they translated into specific numbers -in the tech specs?-
I thought that was per-haps--
It was not clear to me what this comment means either.
MR. VOLLMER:
The tech spe.cs--
You're defining ALARA by the Appendix I values in the tech specs which are arrived at by some sort of an ALARA cost-benefit consideration.
I think--
Right off the. top of my head I think if we applied ALARA considerations.in terms of cost-benefit to this type of 14 an operation we would likely get higher release limits rather 15 than lower.
16 But I think Appendix I is the sort of basi-c criteria 17 that we I ve been going by here, - and the only thing that we haven I t 18 met that would be part of Appendix I requirements is we have 19 not specifically addressed whether or not the.addition of 20 another thousand dollars in invested equipment could reduce 21 the man-rem by one man-rem or more.
22 And I think the man-rem consideration for the liquid 23 discharges are traditionally fairly low in meeting current 24 Appendix I objectives.
I think they would likely be less than Ace-Federal Reporters, Inc.
25 a few man-rem to ten man-rem for the whole process.
And
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incrementally it would be hard tovisualize spending less than
$10,000.to make a significant impact on that.
So.I think even to the Appendix I cost-benefit evaluation,. if you want to go, through that type of routine,*
you could make a:very good case tha:t w:e:.are ALARA now if we can meet our current Appendix I objectives.
John, do you agree with that?
MR. COLLINS:
Yes.
MR. VOLLMER:
Okay.
Item 9 I think we have discussed, some of the reasons we didn't want to.go into looking at each nuclide by nuclide.
Item 10 addresses the objectivity.of the Staff.
I'm not exactly the one to respond to that.
MR.* COLLINS:
Well, I would like to respond because--
MR. VOLLMER:
I knew you wOuld.
MR. COLLINS:
Not because of that, because it really is a little more than that.
I think you took this a little out of context, Bernie.
I think it was saying that because we were on the site giving direct guidance to the licensee we now had lost our 22 objectivity.
And really, in response, we were performing our 23 normal.licensing function which is to provide design guidance 24 Ace-Federal Reporters, Inc.
for ra:dwaste systems or any reactor system.
And I think that 25 that's what the question asked, didn't it?.
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9 10 l l 12 13 49 MR. VOLLMER:
Yes, it's just that we.are doing more than the normal process.
COMMISSIONER AHEARNE:
So:objectively you feel you are being objective.
MR. VOLLMER:
Our very objective view would.be yes.
MR. COLLINS:
Absolutely.
MR. VOLLMER:
Item 11, :I think we have addressed that.
It was not in any way a foregone co~clusion that the water would be discharged into the river, but the discharge quality water, as I indicated, was an attempt to provide a criterion or a go-al.for the decontamination process, that it would meet these objectives *.
And certainly we've discussed that as meeting the Part 2,0 criteria.
14 And. then the last ques*tion, the impact of operating 15 EPICOR II without having the over-all approach I think is per-16 haps a legal question.
17 MR. BICKWIT:
That's right, and we can address that 18 question in our next meeting.
19 20 21 COMMISSIONER AHEARNE:
Could we now address perhaps the EPA questions?
MR. COLLINS:
I think* I read into* the EPA comment 22 they' re saying because of the higher. nature,* the higher. levels 23 of activity that may.be associated here, that certain addi,.
I I 24 tional criteria should be applied on the packaging and handling.
Ace-Federal Reporters, Inc.
25 And then they of course go*into a comparison which
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25 is a poor comparison because-they're taking_average numbers for shipments from PWRs rather than the upper-bound numbers because there are PWRs who make shipments of resins in much higher numbers than are.postulated here.
50 They just took.numbers and divided them by shipments which is really not a fair comparison.
It is a question that NMS and NRR have *been looking at on the total picture, the generic picture of maybe re-structuring the packaging criteria, but at the present time the liners and the shielded containers that-they would be shipped in do.meet the packaging requir~ments of both NRC and DOT.
CHAIRMAN HENDRIE:
Well,.let ts see.
My understand-ing about the welded steel tank liners to hold resins and the Type B transportation cask, together with other arrangements with regard to the transportation proposed-for moving the resins to. a burial. site see.m to me in fact to constitute sub-stantial packaging and handling as contrasted to the normal handling of resins, spent resin materials from normally. operat-ing facilities.
MR. COLLINS:
Of course any spent resin material from any*plant., it would depend.on the activity level of the resin.
I mean even on other reactors if the activity levels were high, they would have to go, because of the shielding requirements, in special packaging.
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16 17 18 19 51 CHAIRMAN HENDRIE:
But a lot of it does move in 55-gallon drums.
MR. COLLINS:
Certainly.
COMMISSIONER AHEARNE:
.I think what you' re pointing out, John 1 i.s* what you expect here still does not exceed the capability of the *cask and liner that-you would be putting it into.
MR. COLLINS:
No, it does not, and that was the
.criterion that was placed on the EPICOR II system for its contact readings on the liners such that they would meet packaging requirements *for shipment.
CHAIRMAN HENDRIE:
Corrosion resistance in storage if there is a need for extended storage before the stuff is moved.
COMMISSIONER KENNEDY:
That's onsite~
COMMISSIONER AHEARNE:
Onsite.
MR. COLLINS:
Wel.l, because of--. The liner itself of course has a certain amount of corrosion resistance to it.
The pH of the material itself is fairly neutral, so that it 20 wouldn't be high corrosion but it would be desirable--
That's 21 22 23 24 why the licensee didn 1 t*construct this*as a permanent facility; it I s a staging area..
And the sooner that material can be shipped to its final resting place the better it would be~
COMMISSIONER KENNEDY:
That doesn't *answer the ques-Ace-Federal Reporters, Inc.
25 tion.
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MR. COLLINS::
No' it doesn It.
Well, we are-not intending on any lengthy storage of the material.
52 COMMISSIONER AHEARNE:, What kind of storage do you think would be *without signifi_cant problems?
How long?
MR. COLLINS:
The storage facility itself has a design criteria applied to it of two_years.
COMMISSIONER KENNEDY:
Two years?
MR. COLLINS:
I believe it is three-eighth inch liner.
CHAIRMAN HENDRIE:. Three-eighth inch welded-plate 1211 tanks.
And it's a fairly well cleaned up--
Well, what equi va-13 14 15 16 17 lent pH in a dewatered resin?
MR. COLLINS:
It would be fairly neutral.
The influent solution is approximately between seven and eight.
I don't see a corrosion problem.
CHAIRMAN HENDRIE:
Unless there' is some reason you 18 II expect to get low pH sludges and so on down in the bottom 19 11 MR. COLLINS'.:: That can be handled by operating 20 II procedures.
21 22 CHAIRMAN HENDRIE:
-- you ought to go a long time.
MR. SNYDER:
The process adjusts the pH before they 23 II start running it t;.hrough.
24
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MR. COLLINS:
The resin itself adjusts the pH.
The 251/ ratio of the cation to the anion will adjust the pH.
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25 53 CHAIRMAN HENDRIE:
And finally do the proposed packaging.and storage procedures in*any way preclude or present further difficulty to the processing of waste *such as solidi-fication?
I MR. COLLINS:
Well, I think we have.said that the resin itself -- putting it on a resin at this*time *does -not prec1ude alternative ways of handling it, and that's what the licensee is looking at,.alternative ways of handling their solidified resins.
COMMISSIONER AHEARNE:
Thank you.
MR. VOLLMER:
The last item I wanted to address was a fairly lengthy discussion.in theSusquehannah Valley Alliance comments by a consultant, Mr. Kosarek, which basically used some of the Staff documents and other. documents, challenging the capability of or the Staff's evaluation at least of the capability of EPICOR II to clean up the water.
I think we could--
If you wish we could ask John to discuss sorne*of the specific allegations he made, but I think again I would like to get back*to the--
It has been the Staff's judgment that, based on the experience we have had with other systems of this type, tJ::"eating contaminated reactor water, that these are our best judgments as to how this system will perform, and if it doesn't*perforrn to expectations there are measures we could take to accommodate it.
So again, if you wish we can go into some of the
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25 54 details of his comments.
If not, we can leave*it at that.
CHAIRMAN HENDRIE:
Does somebody want~-
There is at least a summary write-up in the Staff's response to comments by the Susquehannah.Valley Alliance in.the papers that are here before*the Commission.
Does anybody want to pursue some of those?
COMMISSIONER GILINSKY:
The principal immediate alternative would be to store the water in the various tanks that are available, presumably principally in TMI l.*
MR. VOLLMER:
I'm sorry, the alternative for using -
COMMISSIONER GILINSKY:
To using EPICOR if it
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shouldn't operate as expected.
MR. VOLLMER:
I believe :that that really is about the only real alternative.
I don't believe that *putting it in the reactor building or construction of high integrity tanks at this point is really an alternative.
I think that is the only alternative.
MR. SNYDER:
Actually by doing the. laboratory scale testing with a.proven technology, unless there is something unique here that none of us know anything about, I donlt see any reason why it shouldn't work.
We' re going to do it on a
- small scal.e with samples of actual TMI water in a lab to see what the resins do.for you, and.. it's easy to scale up, It';s hardly a new process~
COMMISSIONER BRADFORD:
When are they goin*g to do
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25 55 that?
MR. COLLINS:
That work has been on-going and that's what I was referring to earlier, that the resul tS'.' o.f thai: would certainly be documented.
COMMISSIONER BRADFORD:
Bernie put it in the future and I was having trouble seeing when it would be done between now and the weekend.
MR. SNYDER:
I'm sorry.
CHAIRMAN HENDRIE:
Another one of those frantic Friday afternoons, Peter.
Are there other questions?
(No response.)
Bernie?*
MR. SNYDER:
No, sir.
I think they've covered everything that we raised plus the major comments-that the out-side raised very well.
. CHAIRMAN HENDRIE:
Steve?
MR. EILPERIN:
No further comments, I think they've covered.it pretty well.
CHAIRMAN HENDRIE:
Len?
MR. BICKIE:
NOthing further, CHAIRMAN HENDRIE:
- I would note that the Commission' discussion with the Staff here today, as well as the discussion the other day, in part have covered various aspects of the environmental assessment, in some ways supplementing it and
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25 56 supplementing it.
It seems.**to me.that the papers before *the* Commission, as well as the discussion here in the form of. the transcript.
of the meeting might usefully be appended to the environmental assessment so that when people ask whai materials-were before the Commission and considered in whatever decision we may make here by way of. having in hand an adequate.assessment of en-vironmental effects of any o.f our decisions, I think they ought to have clearly before them that all of this material and discussion.:was in fact a part of that process.
So with your agreement I will direct that we waive the customary rule about use of transcripts for tnis meeting and the last one on EPICOR and provide that they -- together of course with the Staff papers that are here --
COMMISSIONER AHEARNE:
You don't include the October 9th response to the comments?
CHAIRMAN JENDRIE:
Just so.
(Continuing) -- should be appended to the environ-mental assessment.
MR. BICKWIT:
I think you might vote that, Mr *. Chairman.
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25 57 COMMISSIONER BRADE-ORD: *.You're not suggesting including the transcript of the two meetings with the environ-mental assessment.
MR. BICKWIT:*
As part of the. administrative record leading to that, assuming that that becomes the basis. for the-your negative declaration.
CHAIRMAN HENDRIE:
At the moment we have a.rule tha says that transcripts are not available as parts of a record of that kind. And it seems to me in this case, because of some substantive discussion in addition to that record that has gone on here, tnat it would be.useful, and counsel has recommended tha.t a transcript of this. meeting kept and the past one be made a part of that record.
COMMISSIONER BRADFORD:
Let's see, the published document calle c1::the environmental assessment, then MR. BICKWIT:
All you would publish wb.uld be your negative declaration, if you felt the* assessment was adequate for that purpose.
That is the only legally required document to publish.
I think this is the equivalent of just as an administrative hearing is deemed to modify the Environmental Impact Statement.* So here, too, your discussions would b.~::-.
deemed to modify the environmental assessment.
And in toto that would be the basis for whatever decision you might reach.
- So far the environmental assessment serves two
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25 58 purposes:
it's obviously helping you make your decision on how you want to handle EPICOR and it also forms the basis for a negative declaration.
It certainly, I think, would be i.in the public interest to tell the,public part of the basis for your decision was certainly this discussion. -
CHAIRMAN HENDRIE:
_And the one at the previous -
meeting of the same time and on.the same subject.
Well I would propose that the transcripts -- that the normal rule on transcripts be suspended for -the purpose of allowing these two transcripts to become a part of the, what should I call it.* the record, the administrative record in this matter.
And I will call for those in favor
- COMMISSIONER KENNEDY:
Aye.
CHAIRMAN HENDRIE:
Aye.
COMMISSIONER BRADFORD:_ Let me raise another question.
I don't think I have any objection to this, but what seems peculiar to me at the moment is we have not yet made a decision about it.
MR. BICKWIT:
That's right.
As I stated it, you would do-this only if you came to the conclusion that you wante to issue a negative declaration
- COMMISSIONER BRADFORD:
That's what was perplexing me, I would think we would make that decision first.
CHAIRMAN HENDRIE:
I thought it would be useful to include the material to make it clear that we propose to
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25 li' 59 include the material in the record at this point.
This is a public meeting of the Commission on the subject, and it seemed to me that one might do it, might preferably do it that way~
'>I Now, I ~on' t regard this as 'prejudicing 'the sub-sequent determination which will have to* -ride on the merits and the votes of the Commissioners as they may *come out.
COMMISSIONER AHEARNE:
Are you saying that if we*
make a negative declaration, that it be include.a, and if we don't then the motion is moot?
MR. BICKWIT:
That's right.
CHAIRMAN HENDRIE:
In a practical way, that's how it turns out.
Let me ask for aye's again.
COMMISSIONER AHEARNE:
Aye.
COMMISSIONER KENNEDY:
Aye.
COMMISSIONER BRADFORD:
I'll abstain until after we've made a decision on the negative*aeclaration.
COMMISSIONER GILINSKY:
I think you ought to take it in the opposite order.
carried on basis.
CHAIRMAN HENDRIE:
So you would abstain pending that COMMISSIONER_ GILIN$KY:;
Ye.$._ -
CHAIRMAN HENDRIE:
All right.
The motion is a*three-to-two abstention,*three for,.two abstentiol And I think unless anybody else has other business
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25 60 that we :ought: to transact* here, I think we ought to get on and hear the advice of our legal staffs in closed session.
Thank you very much.
(Whereupon; at 2:47 p.m., the meeting of the -
Commissioners was adjourned.)