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 Pages 1 - 60 Telephone :
(202 ) 3.47-3700 ACE - FEDERAL REPORTERS, INC.
Official Reporten 444 North Capitol Street Washington, D.C. 20001 NATIONWIDE COVERAGE.* OAJLY 0
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.
1 R 7619 UNITED STATES OF AMERICA
'?rueom/wb 2 NUCLEAR REGULATORY COMMISSION 3
PUBLIC MEE'l'Il-JG .
4 DISCUSSION OF RADIOACTIVELY*CONTAMINATED 5 WATER AT. TMI AND RELATED. SUBJECTS (EPICOR. II)
- 6 7 Room 1130, 1717 H Street, N.W.,
8 Washington, D.C.
Wednesday, 10 October 1979 9 The Commission met, pursuant to notice, at 10 1:10 p.m.
11 BEFORE:
12 .DR. JOSEPH M. HENDRIE, Chairman
- 13 14 VICTOR GILINSKY, Commissioner RICHARDT. KENNEDY, Commissioner 15 PETER A. BRADFORD, Commissioner 16 JOHN F. AHEARNE, Commissioner 17 ALSO PRESENT:
18 Leonard Bickwit, Jr., Esq.
Steven Eilperin, Esq._
19 Martin Malsch, Esq.
Bernard Snyder, Esq.
20 Lee Gossick Edson Case 21 Richard Vollmer
- 22 23 John Collins Howard Shapar, Esq.
- 24 Ace-Federal Reporters, Inc.
25
2 ebl C3 2 CHAIRMAN aENDRIE: If we can come to order?
3 Mr. Kennedy will join us directly. In the meantime 4 we should go. ahead.
5 The Commission meets this afternoon for a continua-6 tion of its discussion of what to do with the contaminated 7 water at Three Mile Island and related subjects, the proposed 8 use of the EPICOR II system, and so on, 9 The first thing I would note is that we will hear 10 from the Staff this .afternoon, who have be~n asked to prepare ll some further material in response to comments on the environ-12 mental assessment of the EPICOR II system and its proposed 13 limited use.
14 Later on the Commission will want to discuss certain 15 legal aspects of possible Commission actions in *connection with 16 this matter, and we will do that at a second meeting this 17 afternoon which will be closed since we will want to discuss 18 with the Commission's lawyers various matters connected with 19 possible litigation.
20 I welcome the Staff. Lee, I see you have brought 21 Ed Case, Mr. Vollmer and John Collins. I think we ought to turn 22 to the papers they have prepared, responding to some of the 1 23 comments on the environmental assessment and associated matters.I 24 Why don't you go ahead?
Ace-Federal Reporters, Inc.
25 MR. GOSSICK: Why don't you go ahead, Mr. Chairman?
3 eb2 THe paper we sent down I'm sure you've hardly had a chance*
2 to read, but Mr. Vollmer is prepared to go through and brief.
3 you one~.the comments that the Staff has.
4 Dick, do you want to go ahead?
5 CHAIRMAN HENDRIE: I think we ought to* do that in 6 any case, and I will just note that fortunately .my colleagues 7 and I are fast readers and quick absorbers of information, 8 fortunately.
9 Why don't you go ahead?
10 MR. VOLLMER: Okay. Thank you.
11 What I would like to do if. I may to start out with 12 is basically summarize the options. that were discussed at the 13 last meeting. And rather than going through the point by 14 point comments that we have provided you in the October 9th 15 memorandum, I'd like to use if I may the opportunity presented 16 with Mr. Snyder's memo which does I think pretty well highlight 17 some of the important issues and the technical comments, and 18 go down those and discuss those with the Commission. And if 19 there are residual comments then we can take them as they come 20 up, 21 CHAIRMAN HENDRIE: I'm sure the Commissioners will 22 have assorted questions with respect to these papers.
23 MR. VOLLMER: As we talked about last time; we* see 24 three major options for processing or storage or interim Ace-Federal Reporters, Inc.
25 treatment of the contaminated water that is now housed in tanks
4 eb3 in the auxiliary building and the fuel handl.;i.ng building.
2 One of these options was the use of available tanks
-- 3 4
5 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 6 2 to proceed with the needed.operations and the leakage that 7 accrues from maintaining the Unit 2- system in the safe shut-8 down configuration.
9 As we discussed before, there are several problems 10 with the transfer to Unit 1, I think generally.characterizing 11 i t as spreading out the contamination problem and not provid-12 ing for a fix which would immobilize the contained radio-
- 13 14 activity in the water, whic~-was the basis reason-that the Staff felt that that option was not desirable.
15 Another*option we discussed briefly was the transfer 16 of water to the reactor building. At *this point in time we 17 are roughly 150-or 200 thousand gallons away from reaching 18 the decay heat removal valves, the decay heat removal system 19 valves in the reactor building. We feel these valves are 20 fairly critical to have them in working order during the 21 operation, so we don't feel i t would be 'really a good solu-22 tion to put additional water into the reactor building.
23 There are other problems with that. This water
- 24 Ace-Federal Reporters, Inc.
25 would contact various parts of the primary system, cutting down -- providing a heat transfer medium which would tend to
5 eb4 counteract'the natural circulation that is currently going on 2 in the system.
3 The third thing that was considered of* course was 4 the thing we've been discussing for some time and that's the 5 use of EPICOR II for processing the water. And I think to 6 summarize the Staff's-position on this, it is that we feel that 7 the public. interest can best be served by immobilizing .the 8 activity in the contained radioactive water by putting.-them 9 on -- fixing them.on resins, and we feel that this also would 10 provide needed relief in the auxiliary building to try-to 11 clean up areas in there and to over-all reduce the occupa-12 tional ,exposure~
13 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
- Ace-Federal Reporters, Inc.
25 Solidification of the Resins, 11 and then go on to the 12 or 15
6 ebS 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.
- 4.
- others have raised ,that perhaps *were
- not adequately handled 5 in our original environmental assessment~
6 As far .as Item 1, the adequacy of the EPICOR II 7 system, I think that we have.in the environmental assessment 8 perhaps. not provided an. extremely direct analysis of how, 9 isotope by isotope, the system itself will be capable of de-10 contaminating the water. We have used,.rather than that, 11 basically a criteria approac,h.
12 The criteria was basically that the system should
- 13 14 operate.such that.the effluent water from the system would be capable of many disposal alternatives. And one of these 15 disposal alternatives that would need to be considered in a 16 separate assessment would be the alternative of discharge to 17 a river, as well as the others would be tanking offsite, 18 evaporation or solidification or others.
19 So what the Staff did was basically assure them-20 selves that the technology we see with the use of a system 21 like EPICOR, which we feel will give decontamination factors
- 22 23 in the order of 10 5 or so; would be certainly: adequate to cle.an the water up to a point where i t could be below 10 CFR
- 24 Ace-Federal Reporters, Inc:
25 Part 20 disposal standards and could be below* the standards set by Appendix I if the river '1.-iere used* as a discharge
eh6 '. 1* criteria:. *.
- 2. There was no* intent*here,*to/in'. advance/, .pick'.~
3 d:Lscharge .aiterriative but/ rath~r, -it *was' the. selection. of a*
4 criteria and' a goal* by which* the :system qould** be. performance-_****
5
- oriented:
6 Work- is* going *on currently, and ,we .don't have, the,:*
7 results from those to try to:assess/what* type of decontamina-,
8 tion factors would be achieved.by the system. If you wish to
. 9: go into that further I'm sure-John .can comment ,on it.* I don't 10 *know when-we might expect' the results.*
- 11. MR. 'COLLINS: .. We_ *can expect those' do'cumented re-12 sults in .about a.:week 'or' ten days from now . . Most *of 'the 'studie 13 14 15 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 16 . the* environmental *.assessment, the water from- EPICOR would be 17 Put .into a holding tank and if the *de~ontamination factors 18 that we expect or the resultant water . did not achieve*. the . goals **
19 that we're-lookingfor, i t could be*put back through the.system 20 or other decbntarnina tion activities could .be *unde.rtaken if 21 . necessary* *.
- 22 23 24 COMMISSIONER AHEARNE:
'MR .. VOLLMER:
. Such *as --.?
Well,' if .necessary, LE the system.
'its elf. didn It. work' we could:_.go .back into. puttipg it' back A'ede~al Reporters, Inc. I .
25 into holding. tan:ks and. a dif:fe*rent., type of resin mix could .be I I
8 eb7 used. I guess if necessary it could be put through an evapora-2 tor or something like that, which would make i t less of a con-3 centration problem. But I think the resin would be the first 4 solution.
5 Isn't that right, John?
6 MR. COLLINS: Yes.
7 MR. VOLLMER: So I think it 1 s a technology that 8 we're talking about, and we would expect, based on a great 9 deal of experience with operating plants, with military 10 applications, that it's the Staff 1 s best judgment that this 11 facility will provide us with the decontamination factors that 12 we have been alluding to in* our environmental assessment*.
13 CHAIRMAN HENDRIE: Hold ii;: just a second:
14 Let me ask the people back in the back row, first 15 of all can you hear me when I talk about like this?
16 And the second question is can you hear these folks 17 when they talk about like they've been-talking?
18 VOICE:FROM THE AUDIENCE: No.
19 . CHAIRMAN HENDRIE: I hear some heads shaking, so 20 I will ask you to hold your mikes* up. a little bit and boom 21 out so the people in the back can hear. You. know, if we 22 charged less for the back seats why then I suppose it would be 23 fair that the people back there.not hear as well as the people
- 24 up front, but since it is sort of one-price seating, why Ace-Federal Reporters, Inc.
25 *everybody is entitled to the same receipt of information.
'9
.eb8 l 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
-5 issue ;f whether or* nOt a hydro'.statfc *test* o"f the system* with
- 6* clean_ water would- be condµcted* after deminE!ralizing. unit re-:-
7 -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 also the Staff felt that opeiations*really*provide you with a 12 continual* testing of the* system by virtue of. the fact you. do .*
-*- 13 14
-have. leak -detection systems. and so on ..
However, the licensee ha*s informed us that they-.
15 would indeed.plan.ondoing-a performance test, a leak.perform:...
16 anc;::e *test .after replacement of the resins each time with clean 17 water, so I think that' particular. issue',! as: far as. demonstra-18 tion. each time a process is initi*ated aff.er a changecout,
)9 disconnect and con.necting the hos*es, w.ill be -taken care of.
20
- 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 .. *
- Ace-Federal Reporters, 'inc.
25 In a letter f-rom Bill Dirks* to >Harold Dentow dated
10 eb9 0ctober .. 3rd i t 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.
4 .. And in the discussions we had *1ast-.week _I think. there. was -a 5 -consensus that, on *a .best-effqrts basis, we would._ g_o fro_:m :the 6 v~cutim; _dewai:ered resins. into'* a: .solidified matrix resin for 7 shipm~nt, :but that this should not. preclude* the* application* of 8 EPICOR,. rather, that we. should proceed with* the oper~ti'on
- 9 and a-s
- soon as the system could . be put into place,. there would .
l O. .be, from that time forward, solidification -of resins for ship-11 ment.
- 12 Ed, so :f:a'.r as L know ;.i there was no. real reservation
- 13 14 15 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*
16 time,. to a point .whe:re. :only -so*lidified re~i11s .might be. shipped.
17 . I don't. think, talking to both. of them, it was clear to me*
18
- 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
W .24 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
- 11 ebl0. time as part of the initial.understanding on the matter so that 2 it simply does not drift- and keep getting pushed out as time 3 goes on.
4 And in that context-- Let's see. In fact you 5 represent one side of that issue but: I. see others who can 6 represent* the other* side if necessary.*
7 How good or bad is six months as a target?
8 MR. COLLINS: Let me address that, Mr. Chairman.
9 Following our last meeting with you, I met with the 10 licensee and I think i t was pretty clear to_ the licensee the 11 direction in which the*staff and the Commissioners were heading 12 as far as solidification>
13 The licensee has undertaken a study to identify the 14 best method available for solidification. There are many -
15 alternatives and he has*undertaken*a study to identify the 16 CHAIRMAN HENDRIE: ANd some of those I notice have 17 already resulted in the arrival at burial grounds of containers 18 with free water in them, or at least free liquid.
19 MR. COLLINS: But not from TMI though.
20 COMMISSIONER GILINSKY: I thought no reactors had 21 implemented this requirement yet.
22 COM.1'1ISSIONER AHEARNE: There are abo.ut nine *or some-23 thing.
24 MR. SNYDER: They do i t on their own option I be-Ace-Federal Reporters, Inc.
25 lieve.
12 ebll CHAIRMAN HENDRIE: There are a ...number that have 2 tried one or another solidification process; and I made the
- 3 4
5 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.
6 There's . a good deal to it arid one.* has to be careful 7 in choosing the process and working* out_ the details.
8 MR. COLLINS: That's what the licensee is attempt-9 ing to do at the present time.
10 COMMISSIONER GILLINSKY: Let me just raise this 11 point. There are reactors now --
12 MR. COLLINS: -- who have the capability to solidify
- 13 14 COMMISSIONER GILLINS~Y:
matter of course, --
They do that now as a 15 MR. COLLINS: Yes, 16 COMMISSIONER GILLINSKY: -- and ship .their waste in 17 that form.
18 MR. COLLINS: Some of them would ship the resins 19 in solidified form in 55-gallon drums.
20 CHAIRMAN HENDRIE: You may remember that some of 21 those drums containing solidified resins in fact leaked*at
- 22 23 the Nevada site not so long ago and caused a certain amount of discussion between ourselves and Governor List.
- 24 Ace-Federal Reporters, Inc.
25 COMMISSIONER GILLINSKY:
these solidification schemes?
Did they employ one of
13 ebl2 CHAIRMAN HENDRIE: Yes.
2 COMMISSTONER GILLINSKY: The Palisade*s reactor?
3 CHAIRMAN HENDRIE: Yes.
4 MR. COLLINS: They were using urea formaldehyde.
5 So I guess, to sum it up, they are prepartng --*they 6 are going. through this study and will prepare a* report to us 7 identifying the present method.to handle the solidification 8 of the*EPICOR II resins.
9 I would hope that the Staff would see that report in the very near future. I don't have a permanent date as to 11 when they will submit it to us.* I would certainly expect it 12 would be within the next co~ple of weeks though. But that 13 study is underway.
14 CHAIRMAN HENDRIE: But try to set a target time 15 after which one would not ship spent resins unless solidified.
16 The six-months number sounds to you short?
17 MR. COLLINS: I think six months is entirely too 18 short.
19 COMMISSIONER GILINSKY: Why do you need to ship 20 resins at all during the six months? Why can't EPICOR operate 21 and the resins* then be stored and solidified when that process
- 22 is available?
23 MR. COLLINS: The resins can be stored and that was
- 24 the purpose of constructing an:;onsite interim staging area, Ace-Federal Reporters, Inc; 25 because of the availability of shipping casks to make those
ebl3 shipments *.
- 2 COMMISSIONER*' GILINSKY: *. But .this *wpuld*.* get away_ from.
3 this six-month limit, Mr. chairman? - .
\ ..
4 - MlL : COLLINS: T thirtk* the . six mon th.s is not . very
"',L 0 5 *realistic at all.* .*I. think.:it**is-very '-unrealistic,. six months*'
.6 to do that. .
7 MR. VOLLMER: What you say _is- certainly: true *.
- The -
8 facilities were constructed to .accommodate long_.:t:,erm, storage~ .
9 *And I th.i..nk we talked about before* that the generation of re.sin JO would be a lot faster. if the* system .is . used as expected .than-.
11 the shipment ~nyway.
12
- But the, _feeling was that rather. than -sort* of. getting .
- 13 14
. into,: the mode -of pi:li~g up wastes that' we felt. i t .would .'be' more appropriate to. get i t ,out ... But that certainly is another 15 option.
16 CO.MMISSIONER GILINSKY: As the Chairman s.aid*,. you '_re 17 already off hy a factor of* 100,. Arn I .recalling* you* correctly? ..-
18 CHAIRMAN HENDRIE: Get*the stuff out of the water 19 is my aim.
20 COMMI_SSIONER AHEARNE :. on* the question of no free ....
21 . standing water criteria,. do. you intend to .comment on that?
- 22 23 MR. COLLINS.;. I believe .that' they go on to say that. the licensee has undertaken tests* to derrion~trate *no_
-- 24.
Ace-Federal Reporters,Jnc.
25
- free-standing water:/ and; those* tests have*_ been on-going.
I tve seen some prel:Lminary_'. resul:ts*_: from-: t:.ha t:
and
15 ebl4 2
again I have asked the.licensee-to submit to us the documen-tation of the results of their tests to *show us no free-
- 3 standing water in those resins: .
4 COMMISSIONER AHEARNE: That would be a criterion 5 that you would 6 MR. COLLINS: Absolutely, no free~standing water; 7 no question about it.
8 CHAIRMAN" HENDRIE: Go ahead, please.
9 MR, VOLLMER: This is probably a good time to pick 10 up the .comment that has*been made several places and that is
-11 what about the environmental assessment or inclusion of the 12 transportation and burial .in the environmental .assessment.
13 In particular, I_guess the comment -- the_question 14 came up as to whether or not the environmental risks associated 15 with either the dewatered resin shipment or the solidified 16 resin shipments would .be much different, and I think we believe 17 that the risks associated with the -transportation of the. de-18 watered resins or the solidified resins are roughly equivalent.
19 _Both of these would have to comply with the same 20 federal limits for contact dose rate and dose rate at the 21 site of the trailer. So each package, be i t solidified or
- 22 23 not, would have to be shielded as necessary.
Also, the NRC and DOT package requirements would
- 24 Ace-Federal Reporters, Inc.
25 have to be satisfied so that the radioactive content.would be in-
-an overpack capable of with.standing a 30-foot drop test, the II I!
16 ebl5 fire at 1475, and water immersion.*
2 Things are somewhat equivalent from an environmental 3 assessment point of view. The only major difference that we 4 can see on the solidification side -- and*I would like to re-5 characterize i t as not a major difference. If the resins are 6 truly dewatered as we would require them before shipment, we 7 don't see a major transportation and/or burial problem.
8 On the side against solidification, we believe that 9 it will involve more operator exposure to go the solidification
-10 route, but I think a careful_ assessment and preplanning of 11 the system that is used for solidification will certainly mini-12 mize that. And that would be one of -the criterion that we
- 13 14 would look very carefully at in assessing that system.
So I guess on balance we would conclude that there 15 is no major environmental difference between the shipment of 16 the dewatered resiris or the shipment of the solidified resins.
17 I think, in my view anyway, it would be more of a policy 18 question of how quickly you feel it is necessary to get the 19 resins off.site as opposed to waiting on_ an interim storage 20 basis for a solidification*process to be put into effect.
21 But I don't think on balance it would affect signi-*
- 22
- 23 ficantly the transportation issue.
COMMISSIONER AHEARNE: Since you have raised the
- 24 Ace-Federal Reporters, Inc.
25 transportation question, could you comment on EPA's question-ing about the perhaps need for special packaging since they
17 ebl6 conclude that the.resins are so different-than the.normal 2 resins?
-. 3 4
MR. VOLLMER: - I think the packaging issue really gets to -the integrity of the package and _ the dos.e rates, the 5 surface dose rates and the dose 'rates* to the trailer, and i 6 whatever the-isotope involved" we would require that these 7 basic criteria be_ met.
-8 This just got stuck in front of 'my nose-and John 9 hasn' t seen - it. _
10 MR. COLLINS: Can we come back to this?
1l COMMISSIONER AHEARNE: Yes~ I just received it, 12 too. It's easier *to ask a question than to answer it.
- 13 14 MR. VOLLMER:. Okay. *.On page 4 of the OBE memo, Item 3 lists a number of suggested question for the Staff, 15 and I would like to briefly respond to these, _and again I think 16 we do characterize a lot of the major issues that have been 17 brought up.
18 The first one deals with the*issue of-- The EPICOR 19 system has a pipe fo.1r transfer of contaminated liquids between 20 the-auxiliary building and the EPICOR II building, and the 21 question*would be how would such leakage in that particular 22 transfer system *be detected?
23 As we indicated before, both the pipe that is used
- 24 Ace-Federal -Reporters, Inc.
25 to transfer the liquid .and the guard_pipe which surrounds it and that in turn is surrounded by concrete which you can't
18 really -give a great deal of leak integrity credit for anyway, ebl7 ** l 2 but the first two, the main pipe and the guard pipe, are both
-- 3 4
5 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.
6 So we feel that _if a leak did occur on the system 7 which was somewhere between. a leak that would be not detected 8 because you're.missing some -of. the water that you think is 9 going into. the building but still i t is a measurable leak rate, 10 it would go in to the sump and be not only held up that .way 11 but also detected.
12 If it's a very small leak of course i t would take
- 13 14 longer to detect, but we think it's an adequate *cure for that.
Item 2 on the system testing. I think we mentioned 15 that a few minutes ago. I also would like to mention that 16 during process of the water itself there is monitoring of the 17 potential leak rate both by the sump levels-- Perhaps you 18 can see it in the airborne. contamination. If i t was a mist 19 it could be carried along. And you.also have TV monitoring 20 the system.
21 So.we believe :that there will be careful*control and 22 monitoring of leak rates in the system. And the addition of 23 the licensee's commitment to pressure test after each replace-
- 24 Ace-Federal Reporters, Inc.
25 ment will provide. additional assurance that there.won't be any major loss of contaminated water when the system is first started i
I I
19
. ebl8 up after replacement .
2 I think this would adequately cover the issues 3 addressed in that point.
4 Now as far as the precautions to be exercised during 5 change-out, as you know.the handling of resins and all of 6 the activities associated with change-out have been very care~
7 f.ully procedurized. These procedures either have been or are 8 being approved by the people onsite.
9 The procedures include health physics control.
10 And as a last point we have gone a few yards further 11 in this type of an activity and we haye had an NRC audit of 12 the ope-rations and training of the operators who do this 13 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.
20, eb19 *_ 1' And why is* the mi~~d.-bed :deminerali'ier *unit not *.
2 handled this way?* Wel'i, tworeasons.
3 THe first One is. that.it WO~ It' fit~ since. this 4 particular .demineralizer unit'*is 6. foot by *6 *foot, and I be-5 lieve the. other on~ .is . a' 4 by *4 **...
6 *But* even. so it's not imusuaI to handle .ac'bi\l'ity .in-7 filters and ..so .. on* of this type, of a: dose rate in operating 8 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 MR.* COLLINS: - . I ~01ild like to add. just one *thing on.*.
16 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
21
. eb20 that.were required befOre any waste *shipment could .be sent 2 from the si.te ~ And these .included a fairly* detailed checklist
-- 3 4
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 6 was shipped offsi te . indeed met all. the criteria necessary ..
2a 7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
- 24 Ace-Federal Reporters, Inc.
25
r-i 22 I
2B WRB/wbl Unless John wants to c.ornrnent further* as far as the 2 free ~_tanding criteria, we believe that that can be accommodatef 3 and documented, and that we can get adequate assurance that I 4 a process control applied to the dewatering system will assure 5 that continual basically dry resins will.be achieved.
6 And if that I s not the case then we '*11 certainly go back to the 7 Commission.
8 And, in any event, as John said, we would not 9 ship resins that we felt had any free*water. They would need 10 to be vacuum dried.
11 Item 6 I think we also discussed.. That was the 12 solidification problem again.
13 If there are no other questions I'll go *on~
14 MR. SNYDER: A minor one, Dick.
15 On Question 3 you didn't mention whether there 16 would be any restrictions on handling of the. casks outdoors 17 during inclement weather.
18 MR. VOLLMER: I'm sorry, i9 MR. COLLINS: At this time th.ere*is no restriction 20 placed-on the handling of rriaterial in inclement weather. It 21 is in a transfer bell_ moved outside* and placed in a shielded
- 22 23 vault for transport to the staging area._ So I don 1't see* any need to limit the operation because of inclement weather.
i Ace-Federal* Reporters, 24 Inc.
25 MR. VOLLMER: I ihink good sense would probably dictate, if you were in the middle of*a very severe storm or
something like that ope.ration.a,l-ly it couldn t-t *be. .accommoda.te.d_ i WRB/wb2 2 But if the thrust.of the_question is inclemency in terms of 3 getting water on the thing, I think.,.._..,..
4 Ml\. SNYDER: Just mak..ing i t more diff.icult to 5 handle, especially the one that is not_ going to be *inside. the 6 bell.
7 MR._ COLLINS: It wouldn tt impair the handling of 8 it at all because of inclement weather. You may, because of 9 certain high wind conditions, restrict operation. But that's 10 a normal safety precaution that 1 s take. on many outdoor 11 activities. And it certainly could be placed in the operating 12 procedures.
- 13 14 Just because it-rained-or-snowed shouldn't affect the operation at all.
15 MR,. EILPERIN:: A couple of questions.
16 At one point you said that if the EPICOR II didn **t 17 decontaminate down to the factor you wanted to decontaminate i8 to you could change the resin bed. Or one other alternative 19 was to put the water in holding tanks. I thought the lack of 20 holding tanks was--
21 CHAIRMAN HENDRIE: Steve, could you hook up to the
- 22 23 microphone system one way or the other?
MR. EILPERIN: I thought that the lack of holding
- 24 Ace-Federal Reporters, Inc.
25 tanks right now was a constraint.
that alternative.
So I was wondering about I
- 24,
- WRB/wb3 .1 MR~ COLLI!'JS :* I 1:liink:'what 'o'ick was. l~ading' to was ..
1*** 2 * *that'*if the water came through. the .EPICOR
- 1 system: and did--not-meet the. specification-.eitli.er for.*re_;use of.<the .plant or :for*
4 .disposal *it could*theri eith~r be recycled through: taking i t 5 into the off.-spec .tank* a11d recycli11g ._it back 'throtigh* the
)
6 *demineralizer, changingc Q~t th~* d~mineralize:rs .and putting in
- 7 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 and analyzed for *its radioactive.- *co11;tent and its chemical
- - 13 14 15
- 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 16 .auxiliary building.* That water .could a.lso then be moved.. hac~.
17 .to. that tank *.
i8 MR. EILPERI.N: An_d what about. the. ope.:r;:ati.ng 19 procedures:?. Are those available n.ow? .
- 20 MR. COLLINS: The ope.rattng p;i::,o.ce.dupe,s_ ;for th.e.
21 ._.EPICOR II system, about :90 percent of;. all opepating. proce.dure.s .*
- ..
- 22 > including emergency and ai'arm procedures h.ave. been comp;Leted 23 *and* approved .by. the NRC *. * . There* _are a* few. *remaining~ and
- they 24 are being worked on, at the present time. by the staff~*
Ace-Federal Reporters, Inc, 25 COMMISSIONER BRADFORD: *. When w;i-.li they be I
25 WRB/wb4- 1 .... compl:eted?, ,
- 2 3
'MR~ COLLINS:*,' All .,Pf '.the' op~ratirn3': procedures'
- .should be completed by the*.end .of th_is' 'week.*. 0 4
- COMMISSIONER KENNEDJ:'.'.:* : When you say** there are a . *
- 5. . few rern,ainirig,
- they are ..compietecL but are und*er >review by .the.
6 staff;
- is that correct?* *
- 7 MR. COLLINS:* . That ':s:. correct.
CHAIRMAN HENDRIE.:** *Are th.e.r,,e . 0th.er questions .o.n 9 this point?
10 'GO ahead.
11 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 before, Our .thrust there was *that *o:Ur< pr-ede:termin~d ,,ieve.l woul9,c-14 *.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 16 . was .necessary to provid~ a specifi.C.decon.ta,rtlinatio:ri_* factor 17 for' each- isotope. in th.e *water .. *.
- w:e' h.a.ve: given what ,.we. felt:
i8
- were, . based on our ~ther
- experience., de:con.taminatton fa.ctors 19 that we fe.l t* would* be achieved.. And.,, . if they a:ren '*'t *achieved,*
20 again, *the process John* just alluded, to;~..-. we could put th.em_
21 in. appropriate.* tanks, hold *them up* in ,secure: ways. to e.ith_er
, I
- 22 upgrade the system or. to . provide the. additional. a.e.contamination 23 necessary~.
24 COMMISSIONER -BRADFORD: *. You say you have: given Ace-Federal Reporters, Inc.
25 those lev.els?
I
26 WRB/wbS MR. COLLINS: - .,No. We have nbt-.,.. Well, the levels 2 that , have been given* are basically~- - The initial c:;:-iteria 3 were that the water should meet; if-it were to be discharged 4 to the Susquehanna, that*the water*would have to meet-10 CPR 5 Part 20 and Appendix type limitations; that is, downstream 6 dosage considerations, as well - as th.e point of discharge 7 *considerations.
8 Now, recognizing that*the. disposal alte,rnative.s 9 have not been assessed, this at least provides us. with_ a_
10 benchmark from "Which we could judge the. system adequacy. A_nd 11 we feel that would be most appropriate when we ,found out wha_t I 12 water~ or what decontamination factors we did achieve and
- 13 14 what the water was like *an_d .... .,...
, COMMISSIONER, BR,ADFOR,D; So those are. the level_s 15 you will be. using, then:, ... to d.e.ci;de. whe:ther- you would have to 16 put the water back. through th.e system again, or- change the.
17 system somehow?
18 MR. COLLINS: Yes.
19 MR.* CASE:
- If *that option were. ch_osen ._
- 20. COMMISSIONER BRADFORD; If somebody wants to know 21 what an unsatisfactory level would be,. h.e sh.ould_go to
- 22 23 Appendix I?
MR. VOLLMER: . As far as.,...... Okay~ Appendix I: is dose.
24 evaluation. _
Ace-Federal *Reporters, Inc.
25 CHAIR.MAN HENDRIE.: Certa;i_n_ly i.n_ te.,rm$ _of exposure.*.
27 WRB/wb6 COMMISSIONER BRADFORD: And then what should they 2 do to get the number that~s going to tell you that the system
- 3 4
5 isn't performing in-the way that you want i t to?
a very--
MR. VOLLMER: What they do is backcalculate.
- Since it*s a calculation of dose in the environment Itts 6 back to a level of activity in an undetermined discharge. point,..
7 that would be difficult. But the. water, in terms of meeting 8 Part 20 requirements at the discharge.-- John, how would that .*.
9 MR. COLLINS: You would have to backcalculate that, 10 too.
11 MR. VOLLMER:* Based on dilution. flow.
12 MR. COLLINS: It* has never be.en standard practice
- 13 14
~o set decontamination factors on. pieces of equipment. . B.e.cause a decontami_nation factor varie.s wi.th the. input concentration 15 of the material. And then it also de.creases with. time .. The 16 number of bed v:olumes passed through a demineral*izer, the _D.F 17 may start up very high and become.s -- or starts decreas*i.ng with.
i8 the number of beds, the volume of water passed through. it~
i9 So what you 1*re trying to a.chi.eve is that when you 20 have that water processed, that batch proce.ssed, you're trying 21 to achieve a number. If it were discharged.then you would take
- 22 23 a sample and analyze i t such that none of those concentrations of radionuclides would exceed those in Part 20 for unrestric.ted
- 24 Ace-Federal Reporters, Inc.
25 release.
So if you're saying, Can you backcalculate? Yes,
- 28 WRB/wb7* l 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')
3 .process tank, . that* is *\wh.~t the>eff luen:t would ha,ve* to: meet 4 from the .EPICOR I.I . system~ ... **
5 Knowirig that, **and,your input Joncent~ation, from a
' - . : . . . . . ' .. ~:. -: . . ' ,* . :. *,
6 . .
. particular batch, would be the f~econ"t,am;i.nation facto:i::' .that:*..that .
. *~---
particular batch would have . to achieve.
a* COMMISSIONER BRADFORD: *,Well_, you see what I'm 9, after. You :said in answer to Be~n.ie 's question* that the~e .is
- 10 some level *of. performance **that- you expect of the system, and 1.1 . 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>
- 4.100. 21 .... it .would have .to be reprocessed,.
22
- COMMISSIONER BRADFORD,,* Le.t l:5
- se.e.; th.i.s . is a,.
23 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?
29
'If* *approval WRB/wb8 1 . *: ,::MR~-, COLLINS:: 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 . COMMISSTONER GIL:;ENSK.Y: And what is that?.
15 MR. COLLINS: Pa,:r;t 20 i 16 *COMMISSIONE~ GILINSKY; It \.5 expressed in. what units?*
18 MR.. COLLINS*: . Mi,crocurie.s pel:'":"*.,..'
19
- MR.*. SNYDER: . It ts. b.y isoto.p~.. a.lso, iri.d.ividua).
20 isotopes, specific activities* for unre.stricted
- r*e.J.:e.a.se, Tha,t
. 21' seems* to me to _be a .reasonable thing~ . I_...think. it. would have.
22 been helpful if the assessment h*a.d. s~:id *th.at; You have to_
23 have some measure* of _how effective *your sysd:em .is_. That **s the 24 point of tbe questitin.
- . Ace-Federal Reporters, *Inc.'-
25
- CHAIRMAN HENDRIE:.** Let- me_ see *if. I can confuse the . J
WRB'/wb9* - iss-ue. further in .the interests_ of clarifying ,things_ for myself.*:
- 2- - - Presuming "the water ,is:. to '.1;>e: pr6ce.ssed :in Some .
. ~ . : ' , . . . . - . *.. . '. . .
3 fashipn,, EPICOR or whatever, . at .some -point you' would rega_rd it 4 as adequately processed, one i:iass through the sys-tern, -or two, 5
- or whatever it: t~ke.s *. ---
6 Now will th.e0_effluent from* tha:t:- bl:ack. box;' T will '
7 call adequate.. processing:: for* th.e :present purp;$*es~-.,.._ 'Now- .this 8 water is headed for storage;:, it ts not h~ade.d'for:.-th.e river or*
9 tank ca:rs to: take
- i t to who knows where.; it _l*s* he.aded for
.10 *.storage: onsite *with "dispos~l *to be-.de:t;.ermine.d--late;r--'":
11 ** Nevertheless,:Part~:20 concentratton limits:*would :*apply*;to tha_t 12 at that point?
13 14 15 Now- what* that meah:s _is if you ha,v:en ~~t_ -got _:J?a:r-t 20. _-. ..
16 limits coming out: on -the* first pass_ throug~. EPICOR II,. -why,,
17 you' re* goi*ng to. put it ~v~:r: into - recycle. and run it again?
18 MR. COLLINS*: That':s. correct~
- 19. -CHAIRMAN -HENDRIE;
- Tha_t. sounds . to-* me, *like..,,.:*-:- J-$ i.t _
20 clear tha.tthat'-s what you:want .to_ e.stabli.sb.n 21 *rt I s not clear 't~ me that.,.....,.
- 22 23 strict?*
COMMISSIOl;*rnR GILTNSKY; Is th.at* too lax or.- too
- 24 Ace-Federal .Reporters; Inc.
25
- 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-
31
- W-RB/wbl0*
- l you m~ght like. it, .it,~ s . still: goi:r;ig to g_i ve you a deco.ntamina-
- 2 tion* factor well' above a hundred.~: *I'.11 guarantee'.that.~ And
- ~- ,,
3 4
5 I' 11 pracd:ically<'guara:ntee above NOW*
a tho:usand.
to* be up._ in the 10 4
- and ~bo;e range. : , .*
And it ~s 1.j:kely:
if .you take .one pass*of contaminated water,,
6 then, through this*. system; ,even* if**:it doesn~*t* me.et. Part 20 7 limits when it ~omes ou:t you *ve*.accomplished an enormous 8 step forward in public health, and safety of_con~entrat:.ing_and_
9 fixing the_ bulk *cif the radioactive material, 99 percent,' 99 .9.
10 or 99. 99* percent .of the materia'l .in a.* form*. and* in- a place 11 whe:i:--e it can *.t easily get back: to th:e human environment;. *okay?
- 12 So. that iri terms . -of a health_ and :'safety step*,* why' neve:i;
- 13 14 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 ..
- 15. But you have* accomplished. a very substantial _benefit; in my 16 view, .in getting. the 'fission products .out of *a fqrm where, if 17 the tariks leak or somebody turns. the wrong valve. or a- pipe 18 bus ts . it Is going to be* messy *down. there and it' s going *to be a ,
19 detriment.to the public hea_lth.andsafety.**
20 Let's. *ge*t this stuff ,on the ion beds~* . And if we 21 _have to make a.one pass through.all the water and take it out
- 22 23
-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
- 24 Ace-Federal .Reporters, Inc.
25 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. . **
- . WRB/wbll * , that ,much.>-.
-** 2 Now the :que:stion; of wb.at you then-. do and what the.. :
--* *3 4
5 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*; -
I~: 6 make. concrete :with it or whateve.r'You want to d_o_ ;with it,.
-7 those certc3.inly remain to' be consi_d.ere.d ~-
8 One is going to ha.ve_. to- talk. ab.out certa.t_n_ly -
9 the Part_ 20 r~gulations, about the_ Appendix I limits_ and 10 exposure of the public, which re.quires -really very low e:fflu..-.
n ent -- _amounts in_ the effluent.;
12 --- , Now-," one of the 'things that h.a:s. bothered the 13 -pres.ent _environmental as-sessmeri'-t is* th.e staff '*s .trying to say,.
14 Look, we aren '_ t quite sure what the disposal option*. chosen 15 will be.; that you need .to know what the disposal opt1:on is 16 and what other factors are., such as: a di.lut.ton be.fore r*elea.~e.,.
- I 17 before you come_ ba_ck and determ;Lne. wh.a t th.e *limiting, concen""."
18 tiation of_ a* radi.onuclide is in this water which. will be. stored 19 in tanks on_. the island * .after. having- beeh processed through 20 EPICOR. - And "it ts because: they. aren 1 t sure -~hat _to, say -about tb.'
21 dilution _factor in-particular.that they are leery'-of*quoting
- 22 a limiting concen-tr:ation as the output -of this first' .pass*
- 24
.Ace-Federal Reporters,, Inc.
25
. And it *is similarly the difficulty _if you say,* to anybody, Well I won't,tell you.what the. concentration is.but.I'll
33 WRB/wbl2 tell you that'we're going to apply Appendix I downstream where 2 anybody could be exposed,. and let. you backcalculate.
3 Well, you can.backcalculate from the dose.
4 assumptions about exposure downstream if itts a discharge to 5 the river case. But eventually you_ ge.t back and your 6 calculator will have to know what th.e. dj.lut,i:.on factor is 7 before he could get back into the tank. wa.ter concentration~
8 And without that being defined ..-.- and. it is not defined at 9 this point -- why, it 1 s hard . to set a.. ,
- you really can 1:-t 10 set a definitive number.
11 But I ihihk what we. want to keep in mind is that 12 even without setting such concent:.ration limits on the product .
- 13 14 water from EPICOR II, that passi~gthe water through that system indeed removes the bulk -- and I'm talking about 9.99 15 parts out of a thousand, . or something like. th.at, of the 16 radioactive material. You know, an enormous step forward in 17 reducing the hazard from this stuff.
18 Now I'm not sure where we. wa.nt to_ go with. re.gard, 19 to trying to supply some sort of concen.trati'on_ limit numbers 20 here in our discussion here of the. environmental assessment- or 21 in any subsequent action we take,. The Staff has been reluctant
- 22 23 to do so other th.an to talk about Part 20_ limits for concen-.
tration. But I'm not even-..- It 1 snot clear tci me.th.at you
- 24 Ace-Federal Reporters, Inc.
25 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.
34 WRB/wbl3 EPICOR II and_get the_great bulk of the radioactivity fixed 2 in the resins, and* then look at the product water and decide 3 that this batch and this_batch and this batch still have got
- 4 traces.in them that are too high :for.any of the discharge 5 options I wanted to consider, and th.en recycle them, you see, 6 and pull i t down.
7 I think the. game is. to get the bulk* of the. fission 8 products tied up in a form where they can tt get back~..to people.
9 CO:tv"'iMISSIONER GILINSKY: H.ow do you see th.at their 10 proposal interfers with. that?
11 CHAIRMAN HENDRIE: I don tt see i t at all. What 12 I see interfering with it pos.sibly is a concern that we.
- 13.
14 can I t go forward* unless we set specific radionuclide. concentra~
tion limits. . And then th.is long discussion of mine. is saying 15 simply I'm trying to clarify.
16 COMMISSIONER AHEARNE.: But if you move on to 17 absolute limits are you sciying thaf you would be in favor of i8 a relative decontamination factor approach? '
19 CHAIRMAN HENDRI.E.: I. would run this stuff thr*ough.
20 EPICOR and say,whatever is done with. it, that the product 21 stream is going to go back into tanks for storage, and it 22 isn't going togo anywhere else. until we talk about it h.er*e_
23 and there is an environmental a.sse.ssment on it.. And r wouldn_ "'t
- 24 Ace-Federal Reporters, Inc.
25 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.
35
. WRB/wbl4 great bulk of the. radioactive materi.al and be. of. considerable 2 benefit in a public health and.safety*sense,.
3 At this time I would not set decontamination factor 4 or effluent concentration performance requirements on '*the 5 system.
6 cbr-'!MISSIONER .KENNEDY: You .would wait to do that 7 until you know what the disposal system is.
8 MR. COLLINS: It was the intent of the staff to 9 include all of that in the next assessment of the disposition ..
10 It will all be discussed in detail.
11 MR. VOLLMER: I might clarify: On Part 20. it l*,s not 12 clear to me that*for tritium you woulc.' have the processed 13 water through EPICOR meet Part 2 0. requirements for- tritium.*.
14 CHAIRMAN HENDRIE: Just so~-
15 MR. VOLLMER: As you point out, th.e bulk of-...,.
16 CHAIRMAN HENDRIE: I think I. can he. very cautious*
4.240 17 about saying Part 20 on.the effluent from EPICOR. But we 18 want to keep. in mind that we ~ve_ got ........that th.e water we.'*'re.
19 talking about for EPICOR is ----wha,t? ;,-.,.. a quarter million 20 gallons give or take a couple of truckloa.ds of material with 21 fission products in it. -What we're proposing is to run it
- 22 23 through_a chemical process system*and put it back in the same or similar tankag~ with amounts of ~adioactivity in it that are
- 24 Ace-Federal Reporters, Inc.
25 at least a factor of a hundred and. more. Likely thousand or ten thousand or more less.
factors of*a
I
. 0' WRB/wblS
' 2 MR~. COLLINS.: That.ts correct~*
CHAIRMAN.HENDRIE:.}I_,*find.:,it':very hard: to find-a 3 difficul,ty for. the 'public health and safety there;. and I find.
- 4* 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:.-"="* I 9 . understood Mr. Collins and Mr.* Vollmer to be sayi.ng . /
th.at they 10 we.re aiming tQ get below the Part 20 ._ lirn:i.ts. Th.ey would simply 11 recycle that--
12: CHAIRMAN*.HENDRIE': ._-** Thatls what I unde.r-stoo.d *them*.
13 *to say, too. -AndI .m_saying_:.be:cautio'us*,,.that may*:not be.
1
- 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$.KY.; 'That *:s ju.st the order* in.
21 which you do things.
_22 CHAIRM.;.N HENDRIE: ._- _ Just so *.
- But if you.. say once -
23 I take~- Y~u know, it: all. depertdS Ol'.l how these. things g~t
- 24 *_. written_ ,up.* And I 1ve se.eri* us write pr:escripti.ons wh.ich. say*
Ace-Federal Reporters, Inc:
25 - *. once you take the. water* out .of that. system and_ -start -it into
- 37 wr.gbl the processing over here, you can't put i t back .until it meets 2
certain concentration requirements.
- And you*can then get*stuck 3
going around in circles over here. in the process in order to*
4 meet that. In the meantime,- all the rest of that stuff out 5
there sits there unprocessed.
6 COMMISSIONER GILINSKY; But youtre not saying, are 7
you, that once they have. run :it thro~gh and. gotten it de""'.'
8 contaminated that they shouldntt run it tb.rough_again to get 9
it below Part 20 limits?
10 CHAIRMAN HENDRIE: You betcha,* I 1 m not saying that._
11 It's got to be be.low Part 20 limit$ for any of the di.$posal 12
- 13 14 options*that, you know* --
COMMISSIONER GILINSKY: * ;{ou '*re. just te.lli:ng theII\
to do i.t in the right sequence~?
15 CHAI.RM.AN HENDRI.E.: I 'm te.llin.g them. to do ,tt in.
16 the right sequence. I'm also cautioning them *not to tie.
17 themselves up with unnecessary or* perhaps even unwise ov-er..,..
18 requirements on the system that might impede getting the. bulk 19 of this stuff fixed on resins instead of sitting there in tanks-20 COMMISSIONER KENNEDY~ It'* s not a question of 21
- 22 23 whether, it's only a question of when.
CHAIRMAN HENDRIE: Yes.
- 24 Ace-Federal Reporters, Inc.
25 on the when.
COMMISSIONER AHEAR,NE: If I . could a_s.k. a que.st.;i:,on Let me ask, for an assumption, assume. that. TMI~l
- i is not available, so I 1 m just addressing TMJ-,--2. Since pa.rt of I
38 1
wr-gb2 this is precipitated by the fact.that you have th.is flow in 2
so you are increasing the amount of water that you want to
- 3 4
5 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, 6
so you're going to have to put i t somewhere else~
7 Now to put it somewhere else and not put it in 8
TMI-1, you are going to have to bring it down to SOJI\e. leve.l, 9
aren't you, below what it currently is. So therei.is some 10 upper bound that it has to be below in.order to put i.t in 11 that other set of tanks. What would that be?
12
- 13 14 MR. VOLLMER:
sh.ie.lding considerations.*
That .would lik.e.ly be. dictated* by I£ it is in,. f'or example., storage in the 130,000 or so gallon tank in the EPICOR buildi1:1g itself, 15 that is a relatively unshielded tank and ybu would back-16 calculate if there were any shielding problem._
17 With the decontamination factors we. expe.ct of th.e.
i8 system, we don't feel that th.ere would be a rroblem in storing 19 it th.ere. For a decontamination factor of, say, something like 20 100, then that wouldn't be a very prudent place to store it 21
- 22 23 and you' re right, we have to be very selective about our ~--
COMMISSIONER AHE,ARN:E:. At 10 4 .would it be .,....,...
- 24 Ace-Federal Reporters, Inc.
25 10 4 or so MR. VOLLMER: I would imagine that certainly at you would have a great many tank.age options that you could be living with. And certainly if you cut down to a_gross
- 39 railroad cais:oralmost-anypiace you.store it,, y~u 1ddjave 3 reasonable assurance thp.t ---
4* CHAIRMAN HENDRIE:; * , That:,\ s a very good pointf
- John,.
- 5 and does _,pro,~id~ an incentive,.. in,: fact,' to g~t good ,dec,ontami;."-,
6 nation fact~rs> B~cause, in fac~, ::if yoµ can get' dbwn. to*<~
7 -very low concentrations, then' as Dick .says your options ,on.
temporary tankage are, verT broad* . T'he higher the level bf 9 contamination in* that water,* why_ the more _limited those options
- 10 are ...
COMMISSIONER AHEARNE: , . That -was my conce;tn., ,
12 CIIAIRMAN . HENDRIE:> *, A very_, good point.,'
13 - **_.COMMISSIONER *BRADFORD i *. :_:ts*, there*: a- re:lationph:Lp '* *
.* ~ .
14 between Appendix I nurnbers*and the Part 20 numbers'?_
15
- MR. VOLLMER:.* _No, th.e. Part 20 numbers are numbers l6 in terms of. either_ gross contam_ination or specific. isotope_
17 contamination, as set*out*-in Part-20 that must be.*met at.th.e.
' 18 point of discharge ..
- i I
Now if that* point of. discharge was- into* a fre.sh * .
20 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,*'.*.
22 , and- possible public water intakes' downstream and. do a, dose.
23
- asse*ssment and* see 'to _meet Part 20 -that no-pe:rson. wou,ld like.ly
- 24 . receive more than three .millirems .,.._.,...
- to meet Appendix' I_~:
- If y01~ .
Ace-Federal Reporters, Ire .
. 25 were di~charg+/-ng, ,ihto a' salt water environment, th.en of <cour:se I .*
40 you would.not have the public water intake.
2 So it depends on really the environment and what 3
happens after it's put into wherever you're putting it, and 4
the dose assessment from that, includi~g recreational uses, 5
fish uptake and water and so on. So the _-.two are difficult to 6
equate.
7 But as far as Three Mile, my recollection serves 8
me that our discharge limit to meet Appendix I values, for 9
example, would be on the order of 10 curies a quarter from the.
10 site. And for from the time of .the accident up to now, I 11 -* -
think all the releases summed over that time has only been abou 12 a half a curie. So we feel that this operation would be-..-
13 COMMISSIONER GILINSKY: Half a curie to what?
14 MR. VOLLMER: Total. Half a curie ar.e those* things 15 which we would normally use in .the Appendix I calculation.
16 What I'm saying is what has gone into the river now would be 17 allowable discharge from TMI-1 and from the industrial waste-13 water and so on is on. the order of half a curie**
In other words, th_e. allowance to meet Appendix I, 20 for example, would be about 10 curies. a quarter, and th.at I s 21 what's contained in the current facility tech specs. Those 22 are predicated on the .dose calculation for drinking water,.
23 recreational usage and fish consumption.
24 Ace-Federal Reporters, Inc. I 1 11 run through ve.ry briefly th.e re.st. of these,.
25 The alarm setpoint, this is in Table Two --- listed in Item Two
41 WRB/wbl 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.
5 I might point out th.at since this: as.sessment.
6 was written our noble gases and iodine.,. which would like.ly 7 provide the only.gaseous release from EPICOR, have suffered 8 another 10. or so million decontamination by natural decay._
9 We don't'think this will be any type of a problem or that 10 there will be any measurable. re.leases. But., tn a,ny event, 11 the monitor will be set below the lQ CFR :ra.rt 20_ discharge*
12 limits so as to provide assurance tha.t .i.f, tha.t limit i 9.
13 reached and the. alarm is sounded the. operat:j_~on can be shut 14 down and you would have a fair ma,rgin of p;r:-ot~.c.tion,*probably 15 about 10 3 dispersion be.tween th.e point of re.le.ase. of Part 20_
16 material and the ne.a,rest public exposur-e.._
i7 So we. think youhav,e. a. fa,:j;_;i::,ly adequate "'.".,,..* mope th.an 18 adequate limitation on the se.tpoint ..
19 !
- The type of monitors;-*":"' *. John, can you a.ddre.ss*
20 that?
-, 21 MR. COLLINS: It 1,s a_ gross gamma,. beta. a.nd iodin.e. *,::-- .*
22 or particulate and iodine cartridge on--
23 CHAIRMAN .HENDRIE: Volume, John. Volume ..
24 MR. COLLINS: Volume? Oh, the sampling rate?
Ace-Federa*I Reporters, Inc, 25 Oh, I 'm sorry; you want me to spe.ak up.
42 WRB/wb2 CHAIRMAN HENDRIE: If you will please shout at us.
2 MR. VOLL~R: Item 3, the benefit ... impact assess.,..
3 ment. I think we've covered that adequately.
4 CO!V"MISSIONER BRADFOR,D: Item 2, the same kind of 5 question again. There.is a set of numbers you can get from 6 the. people. who made that comment, what .the se.tpoints ar*e?
7 MR. VOLLMER: Yes, They are. spe.cified. We can 8 do that.
9 Item 4 was the question of the. testing of th.e, 10 floor drains. I che.cked on thi.s thi.s morning,. and I unde.r~tand ll that' we have checked that th.ere. is no interface and they are 12 not connected to the storm drain.
- 13 14 COMMISSIONER AHEARNE.: . They suggested a dye. test to make sure of that.
15 MR. VOLt.MER: Okay. In the. detaf:led *comments ..
16 MR. COLLINS: Th.ere are no drains connected to
'7 1, the storm drain in the chemical cleaning buildi~g .. Th.ere. are 18 .none.
i; l MR.* VOLLME.R: I gue.ss th_e que.stion is, put dye in
,v
'it"\
.there and see. wh.a t you. ge.t.
21 COMMISSIONER AHEARNE.: Tha,t was the. proposal, as I 22 recall.
23 MR. SNYDER: . It was from, th,e. State. of Pennsylvania.
- 24 Ace-Federal Reporters, Inc.
25 COMMISSIONER AHEARNE:
just to verify.
They suggested a dye te.st
43 WRB/wb3 MR. COLLINS: You put the dye in the drains and 2 check the river and see if you ..have. any c:J.ye~ I don't know
-- 3 4
5 how it would_. get out there.
CHAIRMAN HENDRIE:
MR. COLLIN$:
A.re there drai.n$ in the building'P There. are floor* drains, but they all 6 go to the . sump of the buildi~g. . Everything drains- into the.
7 SUir.p.
8 MR. VOLLMER: Can we communicate. ba_ck. to the. sta.te.
9 and see if they would like to suggest some spe.cif.ic te.s*t~ng.
10 program and th.en talk. to the licensee?
ll MR. SNYDER: I. di.dn tt under-stand the. comment eith.e;r .
12 And the purpose of that item here was just to bring it to the.
- 13 14 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 15 that hasn't been communicated adequa.tely in.1:h.e.ir comment.
16 If there is physically no separation it doe.sn_ l*t ma,ke. sen.s-e.
17 to--
i8 MR. VOLLMER: Okay, wet 11 do th.a,t, and make su;r-e JO!
' ! the state is indeed satisfied.
I 20 Item 5: Will EPICOR IT be. us-ed for* other water?
- 21. A system of th.is- type. could be~ used for oth.e.l'.'
- 22 23 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
- 24 Ace-Federal Reporters, Inc.
25 the processing of the. auxiliary building water plus wha.t ~.s in.
the tank farm and the spent fue.l building._
44 WRB/wb4 As far as the decommissioning, the type of decom~
2
- missioning would undoubtedly be. a flush and using a decontamina-3 tion fluid to clean out the* pipe.s, a dismantling operation that 4 is typical of what you would do for any process system that 5 gets contaminated:either by crud or by fission products *.
6 This is als.o a not too unroutine operation,. so I:
7 don't think there would be anything particularly new or novel 8 about doing such an operation.for EPICOR~
9 COMMISSIONER GILINSKY: Wh.en would that.be done if 10 EPICOR is only expected to be used for a relatively short ll time?
12 MR ... VOLLMER: I. really don'* t kn.ow. . It depends on 13 what the licensee. would like to do with. that building, if he 14 wquld find other uses for EPICOR or if he wishes to propose 15 its use. for a broader activity in terms of some. of .the wastes 16 that* are. either coming out of the ~*- that will be taken out of
,7 the re.actor building in the future., for de.contamination of tha.t~
18 I would think tha.t th.ere. a.re. us.e.s for the.
I':- facility. But, again, no proposal ha.s be.en made for that.
Item 6: -- I 1 m sorry, Bernie, but T gue.ss we didn't 21 quite know for sure *what storage space. you were concerned with.
22 there, whether it was solid storage space or~-
23 MR. SNYDER: . Solid storage, I: .be.l.j.'eve.*
- And it was 24 a comment raised--
Ace-Federal Reporters, Inc.
i 25 MR. VOLLMER: I* do recall fua.t. I think John per-hap~
. I I
I
45
-WRB/wbS could comment on what that,.-
2 MR. SNYDER: This was Franklin and Marshall College*s
- 3 comment.
4 MR. COLLINS:* Actually the long term storage 5 facility is. built on the module con,cept basis, where you can 6 add modules to that facility. And i.t was de.signed that way, 7 not constructed that way, designed., that way,. so that if a 8 processing method were conce.ived for the. higher activity water 9 you would have available a de.sign concept already in place to 10 handle those things.* But the modules would be built on an l1 as-built basis. They were forward looking, Franklin* and 12 Marshall.
2.ls 13 14 15 16
~7, i8 1-~* iI I
20 21
- - 22 23
- 24 Ace-Federal Reporters, Inc.
25
- 0. ' ,
2c, ebl
. 2 tainly *to* move :the*:waste off. at .the ea:C-iies:t possibie* 'tinie.*s6 3 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
':*, .. ,_-*,:* *. -.i:<-**
5 extended period ',bf' tim~:~r:.:somethirig like 'that, then the high 6 integ~-i ty storage *space would. l:>*e -~~ailable. ,*
. c5 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
'12°
- to *that particular c.ornment .
- 13 14 15 . tions.
Item .,8,. the same. ALARA :-.standard*
applied to the *accident contamination as that for normal opera-S.everal pe()ple have made this comment,* and I think* the should not. be
- 16
- basic definition of ALARA would stand,. *no matter in what.*
17* environment i t need be. appli*ed~
18 *" 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* ..
- 21. do -- that.the. *cleanup should- not be *conducted so as* to .reduce.,
22
- exposures *as* low ap reasonably achievable? ,r don't. understand
- 23 -the comment at all.*
24 COMMI.SSIONER AHEARNE: I*.'think. the* 'comment was to * .* .1 Ace:Federal R~porters, Inc, 25 say that previously you had some set o-f standards established.
I
b2 , under ALARA and that you should now establish lower standards.
2 MR. VOLLMER: More strict standards because of the 3 accident.
4 CHAIRMAN HENDRIE.: As low as reasonably achievable 5 hopefully means just that.*
6 MR. SNYDER: But aren't they translated into 7 specific numbers -in the tech specs?- I thought that was per-8 haps-- It was not clear to me what this comment means either.
9 MR. VOLLMER: The tech spe.cs-- You're defining 10 ALARA by the Appendix I values in the tech specs which are 11 arrived at by some sort of an ALARA cost-benefit consideration.
12 I think-- Right off the. top of my head I think if we applied
- 13 14 15 ALARA considerations .in terms of cost-benefit to this type of an operation we would likely get higher release limits rather 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
48 I eb3 , incrementally i t would be hard tovisualize spending less than 2 $10,000.to make a significant impact on that.
3 So .I think even to the Appendix I cost-benefit 4 evaluation,. if you want to go, through that type of routine,*
.5 you could make a:very good case tha:t w:e:.are ALARA now if we 6 can meet our current Appendix I objectives.
7 John, do you agree with that?
.8 MR. COLLINS: Yes.
9 MR. VOLLMER: Okay.
Item 9 I think we have discussed, some of the 11 reasons we didn't want to .go into looking at each nuclide by 12 nuclide .
- 13 14
- 15 Item 10 addresses the objectivity .of the Staff.
not exactly the one to respond to that.
I'm MR.* COLLINS: Well, I would like to respond because--
16 MR. VOLLMER: I knew you wOuld.
17 MR. COLLINS: Not because of that, because it really 18 is a little more than that. I think you took this a little 19 out of context, Bernie.
20 I think it was saying that because we were on the 21 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 for ra:dwaste systems or any reactor system. And I think that Ace-Federal Reporters, Inc.
25 that's what the question asked, didn't it?.
49 I I
eb4 we MR. VOLLMER: Yes, it's just that .are doing more
- 2. than the normal process.
3 COMMISSIONER AHEARNE: So:objectively you feel you 4 are being objective.
5 MR. VOLLMER: Our very objective view would.be yes.
6 MR. COLLINS: Absolutely.
7 MR. VOLLMER: Item 11, :I think we have addressed 8 that. It was not in any way a foregone co~clusion that the 9 water would be discharged into the river, but the discharge 10 quality water, as I indicated, was an attempt to provide a ll criterion or a go-al .for the decontamination process, that it 12 would meet these objectives *. And certainly we've discussed 13 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 COMMISSIONER AHEARNE: Could we now address perhaps 20 the EPA questions?
21 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,.
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
50 is a poor comparison because-they're taking_average numbers
- .\
eb5 2 for shipments from PWRs rather than the upper-bound numbers 3 because there are PWRs who make shipments of resins in much 4 higher numbers than are.postulated here.
5 They just took.numbers and divided them by shipments 6 which is really not a fair comparison.
7 It is a question that NMS and NRR have *been looking 8 at on the total picture, the generic picture of maybe re-9 structuring the packaging criteria, but at the present time 10 the liners and the shielded containers that-they would be ll shipped in do.meet the packaging requir~ments of both NRC and 12 DOT.
- 13 14 15 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 16 with regard to the transportation proposed-for moving the 17 resins to. a burial . site see.m to me in fact to constitute sub-18 stantial packaging and handling as contrasted to the normal 19 handling of resins, spent resin materials from normally. operat-20 ing facilities.
.. 21 MR. COLLINS: Of course any spent resin material
- 22 23 from any*plant., it would depend.on the activity level of the resin. I mean even on other reactors if the activity levels
- 24 Ace-Federal Reporters, Inc.
25 were high, they would have to go, because of the shielding requirements, in special packaging.
51 eb6, CHAIRMAN HENDRIE: But a lot of i t does move in 55-2 gallon drums.
3 MR. COLLINS: Certainly.
4 COMMISSIONER AHEARNE: .I think what you' re pointing 5 out, John 1 i.s* what you expect here still does not exceed the 6 capability of the *cask and liner that-you would be putting 7 it into.
8 MR. COLLINS: No, i t does not, and that was the 9 .criterion that was placed on the EPICOR II system for its 10 contact readings on the liners such that they would meet 11 packaging requirements *for shipment.
12 CHAIRMAN HENDRIE: Corrosion resistance in storage
- 13 14 15*
if there is a need for extended storage before the stuff is moved.
COMMISSIONER KENNEDY: That's onsite~
16 COMMISSIONER AHEARNE: Onsite.
17 MR. COLLINS: Wel.l, because of--. The liner itself 18 of course has a certain amount of corrosion resistance to it.
19 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 why the licensee didn 1 t*construct this*as a permanent facility; 22 it I s a staging area.. And the sooner that material can be 23 shipped to its final resting place the better it would be~
24 COMMISSIONER KENNEDY: That doesn't *answer the ques-Ace-Federal Reporters, Inc.
25 tion.
52 eb7 MR. COLLINS:: No' it doesn It.
2 Well, we are-not intending on any lengthy storage 3 of the material.
[
4 COMMISSIONER AHEARNE:, What kind of storage do you 5 think would be *without signifi_cant problems? How long?
6 MR. COLLINS: The storage facility itself has a 7 design criteria applied to it of two_years.
8 COMMISSIONER KENNEDY: Two years?
9 MR. COLLINS: I believe it is three-eighth inch 10 liner.
11 CHAIRMAN HENDRIE:. Three-eighth inch welded-plate 1211 tanks. And it's a fairly well cleaned up-- Well, what equi va-
- 13 14 15 lent pH in a dewatered resin?
MR. COLLINS: It would be fairly neutral. The influent solution is approximately between seven and eight. I 16 don't see a corrosion problem.
17 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 CHAIRMAN HENDRIE: -- you ought to go a long time.
22 MR. SNYDER: The process adjusts the pH before they 23 II start running it t;.hrough.
- 24
-Ace-Federal Reporters, Inc.
MR. COLLINS: The resin itself adjusts the pH.
251/ ratio of the cation to the anion will adjust the pH.
The
53 ebB CHAIRMAN HENDRIE: And finally do the proposed 2 packaging .and storage procedures in*any way preclude or present 3 further difficulty to the processing of waste *such as solidi-4 fication?
I 5
MR. COLLINS: Well, I think we have.said that the 6 resin itself -- putting i t on a resin at this*time *does -not 7
prec1ude alternative ways of handling it, and that's what the 8
licensee is looking at, .alternative ways of handling their 9
solidified resins.
10 COMMISSIONER AHEARNE: Thank you.
11 MR. VOLLMER: The last item I wanted to address was 12 a fairly lengthy discussion .in theSusquehannah Valley Alliance
- 13 14 15 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 16 capability of EPICOR II to clean up the water.
17 I think we could-- If you wish we could ask John 18 to discuss sorne*of the specific allegations he made, but I 19 think again I would like to get back*to the-- It has been the 20 Staff's judgment that, based on the experience we have had 21 with other systems of this type, tJ::"eating contaminated reactor
- 22 23 24 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.
Ace-Federal Reporters, Inc.
25 So again, if you wish we can go into some of the
54 eb9 details of his comments. If not, we can leave*it at that.
2 CHAIRMAN HENDRIE: Does somebody want~- There is
-. 3 4
at least a summary write-up in the Staff's response to comments by the Susquehannah.Valley Alliance in.the papers that are here 5 before*the Commission. Does anybody want to pursue some of 6 those?
7 COMMISSIONER GILINSKY: The principal immediate 8 alternative would be to store the water in the various tanks 9 that are available, presumably principally in TMI l .*
10 MR. VOLLMER: I'm sorry, the alternative for using -
11 COMMISSIONER GILINSKY: To using EPICOR if it
\
12 shouldn't operate as expected.
- ~ 13 MR. VOLLMER: I believe :that that really is about 14 the only real alternative. I don't believe that *putting it 15 in the reactor building or construction of high integrity tanks 16 at this point is really an alternative. I think that is the 17 only alternative.
18 MR. SNYDER: Actually by doing the. laboratory scale
- 19 testing with a.proven technology, unless there is something 20 unique here that none of us know anything about, I donlt see 21 any reason why it shouldn't work. We' re going to do it on a *
- 22 23 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
- 24 Ace-Federal Reporters, Inc.
25 hardly a new process~
COMMISSIONER BRADFORD: When are they goin*g to do
55
-eblO that?
2 MR. COLLINS: That work has been on-going and that's
-. 3 4
what I was referring to earlier, that the resul tS'.' o.f thai: would certainly be documented.
5 COMMISSIONER BRADFORD: Bernie put i t in the future 6 and I was having trouble seeing when i t would be done between 7 now and the weekend.
8 MR. SNYDER: I'm sorry.
9 CHAIRMAN HENDRIE: Another one of those frantic 10 Friday afternoons, Peter.
11 Are there other questions?
12 (No response.)
13 Bernie?*
14 MR. SNYDER: No, sir. I think they've covered 15 everything that we raised plus the major comments- that the out-16 side raised very well.
17 . CHAIRMAN HENDRIE: Steve?
18 MR. EILPERIN: No further comments, I think they've 19 covered.it pretty well.
20 CHAIRMAN HENDRIE: Len?
21 MR. BICKIE: NOthing further,
- 22 23 CHAIRMAN HENDRIE:
- I would note that the Commission' discussion with the Staff here today, as well as the discussion
- 24 Ace-Federal Reporters, Inc.
25 the other day, in part have covered various aspects of the environmental assessment, in some ways supplementing it and
0 56 bll supplementing it.
l Ii 2 It seems.**to me .that the papers before *the* Commission, as well as the discussion here in the form of. the transcript.
3 4 of the meeting might usefully be appended to the environmental 5 assessment so that when people ask whai materials-were before 6 the Commission and considered in whatever decision we may make 7 here by way of. having in hand an adequate .assessment of en-8 vironmental effects of any o.f our decisions, I think they ought 9 to have clearly before them that all of this material and 10 discussion.:was in fact a part of that process.
11 So with your agreement I will direct that we waive 12 the customary rule about use of transcripts for tnis meeting
- 13 14 15 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 16 9th response to the comments?
17 CHAIRMAN JENDRIE: Just so.
i8 (Continuing) -- should be appended to the environ-19 mental assessment.
20 MR. BICKWIT: I think you might vote that, 21 Mr *. Chairman.
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57 2wb/agbl COMMISSIONER BRADE-ORD: *.You're not suggesting 2
including the transcript of the two meetings with the environ-3 mental assessment.
4 MR. BICKWIT:* As part of the. administrative record 5
leading to that, assuming that that becomes the basis. for the-6 your negative declaration.
7 CHAIRMAN HENDRIE: At the moment we have a.rule tha 8
says that transcripts are not available as parts of a record 9
of that kind. And it seems to me in this case, because of 10 some substantive discussion in addition to that record that has 11 gone on here, tnat it would be.useful, and counsel has 12 recommended tha.t a transcript of this. meeting kept and the
- 13 14 15 past one be made a part of that record.
COMMISSIONER BRADFORD: Let's see, the published document calle c1::the environmental assessment, then 16 MR. BICKWIT: All you would publish wb.uld be your 17 negative declaration, if you felt the* assessment was adequate 18 for that purpose. That is the only legally required document i9 to publish.
20 I think this is the equivalent of just as an 21 administrative hearing is deemed to modify the Environmental 22 Impact Statement.* So here, too, your discussions would b.~::-.
23 deemed to modify the environmental assessment. And in toto 24 Ace-Federal Reporters, Inc. that would be the basis for whatever decision you might reach.
25
- So far the environmental assessment serves two
58
./agb2 purposes: it's obviously helping you make your decision on 2
how you want to handle EPICOR and it also forms the basis for 3
- a negative declaration. It certainly, I think, would be i.in the 4
public interest to tell the ,public part of the basis for your 5
5.230 decision was certainly this discussion. -
6 CHAIRMAN HENDRIE: _And the one at the previous -
7 meeting of the same time and on.the same subject.
8 Well I would propose that the transcripts -- that 9
the normal rule on transcripts be suspended for -the purpose 10 of allowing these two transcripts to become a part of the, 11 what should I call it.* the record, the administrative record 12 in this matter. And I will call for those in favor
- 13 COMMISSIONER KENNEDY: Aye.
14 CHAIRMAN HENDRIE: Aye.
15 COMMISSIONER BRADFORD:_ Let me raise another 16 question. I don't think I have any objection to this, but 17 what seems peculiar to me at the moment is we have not yet 18 made a decision about it.
19 MR. BICKWIT: That's right. As I stated it, you 20 would do-this only if you came to the conclusion that you wante 21 to issue a negative declaration
- 22 COMMISSIONER BRADFORD: That's what was perplexing 23 me, I would think we would make that decision first .
24 Ace-Federal Reporters, Inc. CHAIRMAN HENDRIE: I thought it would be useful 25 to include the material to make it clear that we propose to
li' 59 wwagb3 include the material in the record at this point. This is a 2
public meeting of the Commission on the subject, and it seemed 3
- to me that one might do it, might preferably do it that way~
4
'>I Now, I ~on' t regard this as 'prejudicing 'the sub-5 sequent determination which will have to* -ride on the merits and 6
the votes of the Commissioners as they may *come out.
7 COMMISSIONER AHEARNE: Are you saying that if we*
8 make a negative declaration, that i t be include.a, and if we 9
don't then the motion is moot?
10 MR. BICKWIT: That's right.
11 CHAIRMAN HENDRIE: In a practical way, that's how 12 it turns out.
13 Let me ask for aye's again.
14 COMMISSIONER AHEARNE: Aye.
15 COMMISSIONER KENNEDY: Aye.
16 COMMISSIONER BRADFORD: I'll abstain until after 17 we've made a decision on the negative*aeclaration.
18 COMMISSIONER GILINSKY: I think you ought to take 19 i t in the opposite order.
20 CHAIRMAN HENDRIE: So you would abstain pending that 21 COMMISSIONER_ GILIN$KY:; Ye.$._ -
22 CHAIRMAN HENDRIE: All right. The motion is 23 carried on a*three-to-two abstention,*three for,.two abstentiol 24 Ace-Federal Reporters, Inc.
basis.
25 And I think unless anybody else has other business
60 wj{agb4 that we :ought: to transact* here, I think we ought to get on and
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2 hear the advice of our legal staffs in closed session.
3 Thank you very much .
4 (Whereupon; at 2:47 p.m., the meeting of the -
5 Commissioners was adjourned.)
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