ML22230A135

Tran-M790928: Public Meeting Discussion of Radioactively Contaminated Water at TMI & Related Subject

ML22230A135
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Issue date:	09/28/1979
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• Rf GINA ~-.

NUCLEAR REGULATOR Y COMMlSSlON IN THE MATTER OF:

PUBLIC MEETING DISCUSSION OF RADIOACTIVELY CONTAMINATED WATER AT TMI & RELATED SUBJECT Pl ace - Washington, D. C.

Date - Friday, 28 September 1979 Pages 1-59 Telephone:

(202) 3.47-3700 ACE - FEDERAL REPORTERS, Il~C:

Offici,al Reporters 444 North Capitol Street

• Washington, D.C. 20001 NATlONWI0E COVERAGE- 0AllY

CR7409 1 DIS CLAI!-'.!E R This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on Friday, 28 September 1979 in the Conunissions's offices at 1717 H Street, N. W., Washington, D. C. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.

The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters dis-cussed. Expressions of opinion in this transcript do not*necessarily reflect final determinations or beliefs. No pleading or other paper may be filed with the Comrnission in any proceeding as the result of or addressed-to any statement or argument contained herein, except as the Commission may authorize.

CR7409 2 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3

PUBLIC MEETING 4

DISCUSSION OF RADIOACTIVELY CONTAMINATED 5

WATER AT TMI & RELATED SUBJECT 6

7 8

Room 1130 9 1717 H Street, N. W.

0

• Nashi'r1.gton, D. C.

10 Friday, 28 September 1979 11 The Commission met, pursuant to notice, at 2:35 p.m.

12 BEFORE:

13 VICTOR GILINSKY, Commissioner, Presiding 14 RICHARDT. KENNEDY, Commissioner 15 PETER A. BRADFORD, Commissioner 16 JOHN F. AHEAR...~E, Commissioner 17 PRESENT:

18 Messrs. Bickwit, Case, Collins, Snyder, Stello, and 19 Vollmer.

20 21

- 22 23 24

. Ace-Federal Repo"ers, Inc.

25

i

~409 .0 I

• I 3 DH gsh COMMISSIONER GILINSKY (presiding). We"re met here 2 to rec.e.i ve a .bri.efing on the subject of radioactively 3 contaminated water in Three Mile Island and its related 4 subjects.

5 Before we get into that, the commission will have 6 to vote to hold this mEeting on less than one week"s notice.

7 Supposing. we vote to do that.

8 (A chorus of ayes.)

9 COMMISSIONER GILINSKY: Will you lead the briefing?

10 I"d like to mention a few points that I'd like you to cover.

11 I hope you" 11 go over the amounts and types of radioactively 12 contaminated water, where they"re located at Three Mile 13 Island, the. various problems that we..1re facing in continued 14 storage of such water, the options for continued .future 15 storage, the status of the various clean-up efforts, and the 16 prospects and opportunities for future clean-up efforts.

17 As you know, we,.ve recei.ved a letter on the subject 18 from our -senate oversight committee. One of the i:oints that 19 was raised in that letter is that storage is diminishing, the 20 remaining storage capacity, and a figure of 40 days, which 21 I had not earlier heard mentioned, is the amount of time that 22 is left before current storage facilities are used up.

23 r want you to address that.

24 Another point raised is .the heal th phy.sics program.

25 I would like you to go into that.

I i7409.0I .2 4 DH gsh So with that, would you please -

2 COMMISSIONER AHEARNE: Victor, in the presentation 3 which I imagine will be yours, plus som~ of your colleagues 4 with NRR, I imagine that you will also then address the 5 current status of the environmental statement that was out 6 for public comment on EPICOR, which, as I recall, had come 7 to the commission for review and I think is the basis for 8 the 40 days.

9 I think that's the estimate that~s presented in l0 that.

ll (At 2:39 p.m., Commissioner Bradford leaves the room) l2 COMMISSIONER AHEARNE: Also, there have been a l3 number of discussions with yourself and Commissioner Bradford 14 and myself on this health physics problem, summarizing 15 sort of the ongoing pressure that we have been placing upon 16 TMI.

17 MR. STELLO: Okay. What I propose to do is to take 18 the i-s-sues .. in *the approximate order that you've given them.

19 I'll take the health physics issues as a separate issue and 20 I~ll cover that last. And I~ll ask Dick Vollmer to start 21 by covering the issues. in the approximate sequence.

22 But I suggest maybe it would be useful to start with 23 the last one, the current status of so many of the elements, 24 the current status of the environmental statement, what our 25 plans are.

7409.01 .3 5 DH gsh MR. VOLLMER: Okay. As far as the status of EPICOR, 2 the public comment period was over on September 19th, and as 3 a result of the public comment period, we received 38 4 comments, 35 of which were not particularly substantive from 5 the technical point of view, but rather addressed concern 6 with potential clean-up disposal of water and radioactive 7 gasses.

8 More substantive comments were received through a 9 letter from the City of Lancaster, through a lengthy comment 10 from the Susquehanna Valley Alliance, and from the JI Commonwealth of Pennsylvania.

12 The City of Lancaster and the Susquehanna Valley 13 Alliance basically were opposed to the use of EPICOR to 14 decontaminate water. They made a number of technical and 15 legal comments on that.

16 We are preparing an evaluation of comments on these 17 and are prepared to discuss them with the commission on l'8 October 4th. -The Commonweal th of Pennsylvania had a few 19 technical comments which we will address.

20 Their basic bottom line, however, was that they 21 t eel it was the correct thing to do to get on with the use of 22 EPICOR to decontaminate the auxiliary building water.

23 The staff,. I think as a result of review of the 24 comments and the intervening activities that have taken place 25 would basicaily have the same concerns that we expressed to

7409.01 .4 6 DH gsh the commission before the May 25th statement that we feel 2 it's important to immobilize the activity contained in the 3 water at this time.

4 It still represents a source of operator exposure 5 and the current --

6 COMMISSIONER KENNEDY: Are we talking about the 7 water in the containment building or the aux building?

8 MR. VOLLMER: We're only talking at this time about 9 the water in the auxiliary building, which is addressed in the 10 EPIC0R assessment.

11 I'll go now to the aux building, since that's 12 direc.tly associated with the use of EPIC0R, the aux building.

13 MR. CASE: The tanks -in the aux building.

14 MR. VOLLMER: Right, okay. In the auxiliary building

~

15 there are roughly 3.00, 000 gallons of contaminated water.

16 The activity levels associated with those are as high as 17 about 35 microcuries per milliliter of Cesium 137. The

-18 viodine.-.a-c,ti:v-ityta:t this-,poi'n,t i-n time is almost negligible l9 i n a 11 parts of the f a c i l i t y because of the ha l f-1 i f e of 20 iodine.

21 Some of the tanks in the auxiliary building have 22 activities as low as about one microcurie per milliliter 23 of cesium.

24 Now, the auxiliary building has a couple of sources 25 of contaminated leakage into it. There is some leakage from

'7409. 0 I

• 5 7 DH gsh the reactor purification and make-up system which, as you 2 know, is part of the primary system that goes out into the 3 auxiliary building from the containment building. There is 4 some leakage, pump leakage and valve leakage, which provides 5 an additional source of contaminated water in the auxiliary 6 building.

7 COMMISSIONER GILINSKY: What is the rate of that 8 leakage?

9 MR. VOLLMER: The rate of the leakage in the auxiliary 10 building *

. JI COMMISSIONER GILINSKY: Oh, I see. It"s in the 12 auxiliary building. But itJs to the auxiliary building tanks.

13 MR. VOLLMER: In the auxiliary building tanks. It"s l4 on the -0rder of* a I ,200 gallons per day.

15 Most of that comes f rem -- not from the primary 16 system, but from, for example, leakage from the pumps that 17 are used to supply containment cooling water.

l8 And SO* ,,this ts::'.:g.en.er:a l'Ly non-radioactive water, 19 but it's collected in sumps. It does pick up contamination 20 through the floor drains and then it is immediately put in 21 tanks.

22 But the co.llection of* that water represents a major 23 source of activity~ And, of course, in order to keep the 24 reactor building maintained at a negative pressure, which it 25 has b.een since the accident, it's important to keep the

7409 .0 I

• 6 8 DH gsh reactor building as cool as possible.

2 And so, one of the criteria that we"ve imposed 3 that whenever the reactor building gets close to being a 4 pressure equal to atmospheric, they have to keep pushing it 5 down to maintain its sub-atmospheric.

6 So by doing that, they"re going to add leakage into 7 the auxiliary building by virtue of those pump seals, which is 8 the normal o~currence.

9 COMMISSIONER GI LINSKY: What is the capacity of the 10 tanks in the auxiliary building?

11 MR. VOLLMER: The capacity of the tanks in the 12 auxiliary building is roughly 300,000 gallons. In addition, 13 the tank farm which was .installed after the accident in the 14 spent fuel pool of the fuel handling building contains 15 l 10,000 gallons and is also about full.

I6 Bas i ca 11 y , a s I " v e s a i d --

17 COMMISSIONER KENNEDY: About full, meaning 18 > MR.

0 VOLLJ,,fER: ,We 11, . we *have a capacity for about 19 30 or so more days. It"s di1ficult to address it exactly 20 because the leakage. rate varies. But we project the average 21 leakage that has occurred in the last seven days, you have 22 about 30 or so, 35 perhaps, days more available tankage in 23 the ~uxiliary building, plus the tank farm.

24 At that point in time, the Unit 2 tankage would be 25 essentially full and additional tankage in the Unit 2 would

17409.01

• 7 9 DH gsh not be available.

2 At that pciint in time, if the processing of the 3 water by EPICOR system had not proceeded, then the only 4 COMMISSIONER KENNEDY: What's the process? I 5 understand that. What's the process rate in EPICOR 2?

6 MR. VOLLMER: The process rate in EPICOR 2 would be 7 in excess of 10,000 gallons a day. It-'s nominally 20 GPM.

8 But when we correct-for things which we're expecting, 9 10,000 or more gallons per day.

10 (At 2:47 p.m., Commission Bradford enters the room)

JI MR. CASE: There is available tankage in Unit 1.

12 MR. VOLLMER: I will get to that. There is a 13 substantial additional tankage available in Unit. 1 which we 14 have tried, as you know, from the Unit 1 order that we've 15 prepared, the commission prepared, we've been trying to keep 16 Unit I and Unit 2 separate. But indeed, that is the same 17 type of. package* available in Unit I that you have in Unit 2.

18 .J3asic:,.a.l,ly;,- 2-50:,000 or,,so, _gallons will *be available.

I9 Those tanks are generally free.

20 COMMISSIONER GILINSKY: They're interconnected, or 21 can they be?

22 MR. VOLLMER: There are connections by which that 23 water could be pumped over to Unit I, yes.

24 COMMISSIONER KENNEDY: Out of the existing tanks or 25 independently of them?

7409. 0 I

• 8 10 DH gsh MR. VOLLMER: Out of the existing tanks.

2 COMMISSIONER AHEARNE: These are basically the same.

3 points that were made in the a sse ssmen t.

4 MR. VOLLMER: Yes, sir, they are.

5 COMMISSIONER AHEARNE: In the EPICOR assessment.

6 MR. STELLO: Dick, you can also pump directly from 7 the sumps, directly over to Unit 1. You don't have to take 8 them through the tanks, do you?

9 MR. VOLLMER: I believe there are connections where 10 You could take it from the sumps, yes. But for staging and II things o.f that nature, we generally would like to put staging 12 tanks so that you know what w~'re dealing with before you 13 start pumping it over.

14 C0MMI.SS I ONER GI LINSKY: So, in a sense, there is I 0 15 times .as much capacity in the Unit I complex as there is 16 left at this point in the Unit 2 complex.

17 MR. VOLLMER: ThatJs correct.

18 COMMISSIONER AHEARNE: Also, the point that I was 19 trying to make which Dick has clarified is that these were 20 the points that were made in the EPIC0R assessment when it 21 went out.

22 As you recall, one of the reasons that they 23 originally came into the proposal as to why it was necessary 24 to address that issue --

25 MR. VOLLMER: I think the po in ts that were made in

7409. 0 I

• 9 I1 DH gsh the assessment on the general conditions of things have really 2 not changed. The leaka9e rates are not higher. Activities 3 are generally not higher or lower. And the same incentive 4 for processing the water now existed then and still exists, 5 and it's even getting more urgent in the sense that if it 6 does have to be pumped into Unit 1, we have created, then, 7 additional sources of sxposure and additional contamination 8 throughout the facility.

9 COMMISSIONER AHEARNE: But the urgency is of that 10 kind, is it not? It's not a question of off-site releases.

II MR. VOLLMER: That's right. The urgency would be 12 one primarily of operator exposure and contamination of the 13 facility.

14 Well, definitely, the public health and safety 15 as an issue I don't think has changed. The only public health 16 and safety issue that existed at the time that we wrote the 17 EPICOR assessment was that there was a certain amount of 18 o tf ~g-assi'n"g of the liquid, radioactive liquid waste. And 19 the off-gassing, particuarly xenon and iodines, diminished 20 significantly because of the decay time that takes place.

21 For example, in the whole TMI-2 facility there is 22 probably no more than a curie or so of iodine and comparable 23 amounts of xenon.

24 So the public's problem from the off-gassing I 25 think has diminished significantly.

7409. 0 t

• 10 12 DH gsh Now one item - unless you have additional questions.

2 .COMMI.SSIONER AHEARNE: Just one other question, I 3 think.

4 Were you to start running EPICOR, what is the 5 period of time between when you had the decision to start and 6 when you could actually reach this 10,000 gallons per day?

7 MR. VOLLMER: I think once it's lined up, it could 8 be accomplished in a matter of a few days.

9 COMMISSIONER AHEARNE: How long does that line up --

10 you say once it's lined up.

11 MR. VOLLMER: I think in a matter of a few days, 12 the processing could start. We have undergone an extensive 13 evaluation of the qualifications of the operators for use of 14 that system. We've done an extensive review of procedures, as 15 WBll as a general review of the facility itself.

16 Those have been very carefully addressed because of 17 the significance of the processing and the public concerns of 18 that.

19 MR. CASE: There is more training to be done or 20 n_eeded in some of -the operators.

21 MR. VOLLMER: That s true. We weren't as of last 22 week totally satisfied with the training of all the 23 operations people there, and I can report more comprehensively 24 on that aspect on October 4th.

25 I might add one thing. As far as the status of

7409.01. J 1 13 DH gsh EPICOR, the use of the facility itself because of the 2 segragati.on of certain liquid wastes in the tanks and the 3 auxiliary building, one could start processing a lower 4 contamination of waste first. But it was felt necessary to 5 get- some capacity in the system.

6 And there's some concern about processing the 7 higher level waste. I dont' think that there is, indeed, 8 a technical reason to delay processing of the higher level 9 waste, but there is the segregation of the contaminated levels 10 in the auxiliary.building.

J 1 So one does have a choice of testing the system 12 out with liquid wastes of lesser contamination.

13 COMMISSIONER AHEARNE: If, again, the decision were

- 14 I5 16 to be made to use EPICOR, given that there has not been an address yet of what would be done with the water after the EPICOR system was run, what would be done with the water?

17 MR. VOLLMER: The only thing that could be done with 18 the water would be sending it, Unit I.

19 COMMISSIONER AHEARNE: So the decontaminated water 20 would be going to Unit 1 versus, in this case, the contaminated 21 water.

22 MR. VOLLMER: In any event, the water will be stored 23 because we have not done an assessment of the disposal of 24 the water, the decontaminated water.

25 The licensee has indicated that he was going to send

7409. 0 I

• 1 2 14 DH gsh us his evaluation and assessment of the options and the 2 recommended course.

3 1~ e have no t ye t r e c e i v e d th at

• 4 COMMISSIONER AHEARNE: But in either event, as far as 5 you can see, we'll really end up being Unit tanks that 6 will be receiving the water. And the issue is which kind of 7 water ain't going to be discarded?

8 MR. VOLLMER: Some of the decontaminated water could 9 be stored in the EPIC0R building itself. There are tanks 10 that could probably be used to store the decontaminated water.

11 But either way --

12 COMMISSIONER AHEARNE: Have you considered 13 evaporation of that water?

14 MR. VOLLMER: Of the decontaminated?

15 COMMISSIONER AHEARNE: Uh huh.

16 MR. VOLLMER: No, we have not considered the options 17 of disposal that we discussed with the commission before 18 because we we re waiting for the envi ronrnen tal ass e ssrnen t of 19 the licensee.

20 COMMISSIONER AHEARNE: That will be one of the 21 alternatives that will be looked at?

22 MR. VOLLMER: Yes

• 23 COMMISSIONER KENNEDY: When do we expect to receive 24 it?

25 MR. VOLLMER: I understood we were to receive it this

7409.01.13 15 DH gsh week. Whether it's eminent or not; I can't answer right now.

2 But I believe it is.

- 3 4

5 One thing I might mention is that one of the major points made in the comments received from the City of Lancaster and the Susquehanna Valley Alliance were legal 6 questions. I don't know if OGC would like to address those 7 or not. But basically, they felt that this particular 8 a.ssessment was not in compliance with NEPA because it was 9 not a comprehensive assessment of all of the decontamination IO and recovery operations.

11 That's something that the staff would not be 12 prepared to address October 4th.

13 I trust the legal staff will.

- 14 15 16 17

~ 18 d

19 20 21 22 23 24 25

CR 7409 HOFFMAN 16 t-2 mte 1 COMMISSIONER AHEARNE: The technical staff will not 2 be addressing this?

3 MR. VOLLMER: The technical staff will not be 4 addressing*this.

5 COMMISSIONER GILINSKY: Could you continue your

~ inventory of.the various types of contaminated water?

7 MR. VOLLMER: Yes. Basically, could I go on to the a reactor building?*

9 COMMISSIONER GILINSKY: *Sure.

10 MR. VOLLMER: The reactor building water has an

. 11 approximately 600,000-gallon inventory. That water resides 12 in the bottom of the reactor building and its activity is of 13 the order of 175 microcuries per milliliter of cesium 137, 14 which is the dominant isotope as_ far as activity is concerned, 15 although there are a number of other isotopes, cesium and 16 tritium, et cetera. But the dominant isotope is that of 17 cesium.

18 The leakage into the reactor building is at a rate

• 19 of about* 500 gallons pet day, that leakage rate mming 20 primarily from reactor coolant pump seals and things of that 21 nature. The pumps themselves are not on, but *there's still 22 a slight leakage to the seals.

23 COMMISSIONER GILINSKY: What was that leakage number 24 again?

Ace-Federal Reporters, Inc.

25 MR. VOLLMER: About 500 gallons per day.

I.

mte 2 17 Now, in order to raise the water level a foot in 2 the reactor building, it would take roughly 100,000 gallons, 3 and so we I re* talking about a fairly imperceptible increase in 4 *1evel in the containment building itself.

5 COMMISSIONER GILINSKY: How high is the water in 6 the containment building?

7 MR. VOLLMER: How hot?

8 COMMISSIONER GILINSKY: High.

9 MR. VOLLMER: Oh. It's about seven and a half feet 10 or so.

11 Now, that water is, again, just sitting there.

12 There's no current valve operators or electrical equipment or 13 anything that is inddanger of being shorted out by that 14 water. As you know, we did make some valve manipulations some 15 months ago to protect against the non-availability of key

. 16 valves in the event the water level did get too high. But at 17 this point, the stability of the situation in the reactor 18 building appears to be the same for qui'te a long-term period.

19 COMMISSIONER GILINSKY: What is the risk of that 20 water leaving? Is there any pathway for it to get out of the 21 containment?

22 MR. VOLLMER: The containment, of course, is sealed.

23 There are isolation valves in the containment, and the valves 24 on the side can prevent that water from going out into the Ace-Federal Reporters, Inc.

25 auxiliary building around, and the system's leak integrity

mte 3 18 has been checked. So there should be no leakage path of water 2 outside the reactor building.

3 COMMISSIONER GILINSKY: The next category, I suppose, 4 is the primary .coolant system.

5 MR. VOLLMER: The last category, yes, is the 6 primary coolant system. That's about 80,000 gallons, and its 7 activity is on the order of 100 microcuries per milliliter of 8 cesium and several rundred microcuries per milliliter of 9 strontium isotopes.

10 The difference particularly in that water and other 11 water, because of the high strontium activity, provides a 12 higher potential exposure problem, and has created some beta

- 13 14 15 exposure problems in trying to fix leaks in valves.

COMMISSIONER AHEARNE:

leaking into the containment?

That's the one, also, that is 16 MR. VOLLMER: That is the type of water that's 17 leaking into the containment through the seals, yes.

18 The primary system, the purification and makeup 19 ,system, . the leakage there pretty much can't be corrected.

20 It's fairly low. But it has a very high activity area. I 21 don't think at this time it would be prudent for the operators

- 22 23 24 to try to correct any of those leakage paths that exist.

They . did cor.rect leakage paths of the valves going in and trying to check pumps and things like that.

Ace-Federal Reporters, Inc.

25 COMMISSIONER BRADFORD: Why is there much difference

mte 4 19

.in this type of.activity between water in the containment and 2 the primary system?

3 MR. VOLL.MER: Primarily, because of the times that 4 the activity had gotten into the bottom of the reactor 5 building. Reactor building water, a great deal of that is 6 undoubtedly water that came from the primary system, but also 7 probably water that came from the fan-cooled system, which 8 was basically noncontaminated water, but appeared to be a 9 significant leakage path at one time.

10 At the time the level of water in the reactor 11 building was increasing, those secondary leakage paths were 12 pretty well shut down, so that the only source of leakage

- 13 14 15 that appears to exist*in the reactor building now is that of the primary coolant.

So, initially the activity in the reactor building 16 basement water was that which was coming from the reactor 17 coolant system fresh from the accident. And as time went on, 18 the activity level in the primary coolant system diminished

. 19 because of decay, because it was being diluted by makeup.

20 COMMISSIONER BRADFORD: What about the strontium?

21 MR. VOLLMER: The strontium appears to have 22 increased in time in the reactor building water, undoubtedly 23 ~ecause of the leachability of strontium with respect to other 24 isotopes over the course of the long contact of primary Ace-Federal Reporters, Inc.

25 coolant system water circulating over the exposed fuel. I

mte 5 20 1 don't have .at this point in time a good time history.

2 COMMISSIONER BRADFORD: What's puzzling me is that 3 there is more strontium relative to cesium in the primary 4 cooling loop than there is in the containment building.

5 MR. VOLLMER: Okay. What I was trying to say is, 6 it appears that isotopes, ::for example,* cesium, iodine, which 7 are more highly volatile, came out in the early phases of the 8 accident. and were put into the containment building water early 9 on. Less volatile isotopes like ,strontium apparently have 10 leached out of the fuel rods over the long period of time 11 that they've been exposed to the primary coolant.

12 COMMISSIONER AHEARNE: The. letter that we. got quoted 13 Harold as talking about the possibility of having to sneak a 14 path to develop containment. Would you care to comment on 15 what sneak path that might be?

16 COMMISSIONER KENNEDY: Before you do, could you read 17 us what Harold said?

18 COMMISSIONER GILINSKY: He isn't here because he's 19 in.North Carolina, right?

20 MR. CASE: I'm afraid it might take me a few minutes.

21 COMMISSIONER AHEARNE: I'll just kind of skim through 22 it.

23 COMM*IS,SIONER ,GILINS'KY: Well, while people are 24 skimming through documents, I wonder if you could go back to Ace-Federal Reporters, Inc.

25 the question of the additional capacity that exists for

rote 6 21 storing some of this water. The place where capacity may 2 run short is in the auxiliary building rather than the con-3 tainment.

4 MR. VOLLMER: Yes.

5 COMMISSIONER GILINSKY: It's the question of dealing 6 with water that's in the tanks in the auxiliary building?

7 MR. VOLLMER: That's correct.

8 COMMISSIONER GILINSKY: It raises the matter of C, 9 additional capacity. Now, we spoke **of*-* the tanks in Unit 1.

10 Are there any other tanks that are available, mobile tanks 11 or tanks that could be brought on. site? Are there any plans 12 for anything of the sort?

13 MR. VOLLMER: There are a number of tanks on site.

14 However, I don't think we're in a position to say how long 15 it would take to put those into a configuration that we would 16 feel comfortable putting contaminated water into them. I 17 think before we would do something like that, the tankage 18 itself would have to be assured of integrity, we would have to 19 put them or build something whereby, if they did leak, that 20 contaminated water was prevented from going into the ground.

21 Thirdly, we would have to put in a piping which would get 22 water into the tanks which we ~ould feel fairly certain would

23. do the job *without leakage.

24 So I wouldn't want to speculate how long that would Ace-Federal Reporters, Inc.

25 take.

mte 7 22 COMMISSIONER GILINSKY: So principally, it's the 2 tanks in Unit 1 that are the excess capacity at this point in 3 time?

4 MR. VOLLMER: The excess capacity would be primarily, 5 yes, the tanks in Unit 1.

6 CO~..MISSIONER AHEARNE: But they are the type of 7 tanks --

8 MR. VOLLMER: They are the same type of tanks that 9 we' re -currently stori.ng the,,*wat:er in.

10 COMMISSIONER AHEARNE: So as far as the concerns 1*1 that you just expressed about checking it for the need for 12 additional, you don't have those concerns, do you?

13 MR. VOLLMER: We don't have those concerns for the 14 integrity of the Unit 1 tanks. They're in the Unit 1 15 auxiliary building, so they have the same safeguards built 16 into them that the Unit 2 tankage has.

17 COMMISSIONER GILINSKY: Could you also tell us 18 something about the status of cleanup efforts for the water in 19 the containment and the primary coolant system. The system 20 you referred to, the EPICOR system, would clean up water 21 that is now in the auxiliary building tanks. What about the 22 other water?

23 MR. VOLLM-ER: The licensee has had a couple of 24 architect-engineers or decontamination experts review the

. Ace-Federal Reporters, Inc.

25 best ways of decontaminating the primary system water and

rote 8 23 1 the reactor building water. As I understand it, they looked 2 at both demineralization and evaporation possibilities. And 3

we have not yet received from them any formal plan or program 4 for decontamination of .that water.

5 I do believe that, from what we know now of the 6 water in the reactor building itself, that it would appear 7 that a system, the type of EPICOR, or even EPICOR II, would 8 be capable of processing that water. Whether that's what the 9 licensee opts to do or not, we do not yet know. He has not 10 asked for our review of his programs yet.

11 COMMISSIONER AHEARNE: It is correct that, until we 12 have gone through a process, that he can't take any action?

13 MR. VOLLMER: That's correct.

14 COMMISSIONER GILINSKY: At any rate, that 1 s now in 15 the planning stage.

16 MR. VOLLMER: That's in the licensee planning stage, 17 yes, sir. We have not been asked to review his plans for 18 that. He has not submitted his plans for that to the 19 Commission yet.

20 COMMISSIONER AHEARNE: After he submits it, what do 21 we have to do?

22 MR. VOLLMER: After he submits those plans, we would 23 do a safety and environmental assessment, I think~: It's 24 s:imilar to what we did for the processing of the auxiliary Ace-Federal Reporters, Inc.

25 building water. Again, I don't know whether his plans for

mte 9 24

. processing that water include disposal alternatives, either.

2 COMMISSIONER AHEARNE: But to reiterate the point I 3 just made, until we have reached a final position he can't 4 do anything with that, is that cmrrect?

5 MR. VOLLMER: That's correct.

6 COMMISSIONER GILINSKY: Mr. Case, would you care to 7 *respond to Mr. Kennedy's question?

8 MR. CASE: The questioner is Mr. Grome, who asked 9 this question: Would y6ri feel there is any urgency to that 10 need, that is, the need to reprocess the water in the contain-ll ment building? Would you feel uncomfortable if, in one year, 12 two years, three years passed, and the plant, with a very high

- 13 14 15 inventory of curies and the potential for release persisted with no cleanup activity?

Mr. Denton: No, I would not feel very comfortable 16 with letting it go like that. I think as long as there is 17 radioactive material disbursed in the containment, there might 18 be sneak_ paths that develop in the containment that result in 19 release to the environment, which should be foreclosed. So 20 I don't see the need to rush into it. Neither would I be 21 satisfied with an inordinate procrastination. It's an awful 22 lot of activity in that 700,000 gallons of water, and we are

,23 depend,ing on contai-nment to confine it.

24 COMMISSIONER KENNEDY: For my help, could you go Ace-Federal Reporters, Inc.

25 back and read the last part of that again, something about,

mte 10 25 while I would not see the need to rush into it.

2 MR. CASE: So I don't see the need to rush into it.

3 Neither would I be satisfied with inordinate procrastination.

4 COMMISSIONER KENNEDY: Thank you.

5 MR. VOLLMER: Okay. Now, to respond to your 6 question, sir.

7 CO.IYf..MISSIONER AHEARNE: The question, it was, it 8 started out two or three years; is that correct?

9 MR. CASE: Yes.

10 COMMISSIONER .ZlliEARNE: One year, two years, three 11 years. Okay.

12 MR. VOLLMER: I don't see any sneak paths. We have 13 looked for that particular potential and we have further 14 requested the licensee to give us a program for sampling the 15 ground water around the containment building. And we have not 16 received yet the licensee's program for this. The reactor 17 building is several feet thick, of course, and we don't feel 18 the water is leaking out.

19 we feel the sampling of ground water is appropriate.

20 We've also looked into the question of whether or not, if 21 there were leakage, is there likely to be a significant source 22 of contamination of the river,. and the hydrologists, who also

• 23 did the:review of the plant for spills of rad waste tanks as 24 part of our original safety assessment, tell us that it would Ace-.Federal Reporters, Inc.

25 take an extended period of time, :rronths, before any

mte 11 26 contaminated water could get out into potable water *sources.

2 COr--'.iMISSIONER AHEARNE: But you don't*at the moment 3 see anything?

4 MR. VOLLMER: We do not see any reason to be 5 concerned. That sampling, putting in well points for sampling 6 of that water, we think is just an extra step to take.

7 COMMISSIONER AHEARNE: To clarify, Dick, Harold had 8 .been asked, would he be comfortable at one, two, or three years 9 and he said,*no, certainly not. You wouldn't be comfortable 10 if one, two or three years went on, would you?

11 COMMISSIONER KENNEDY: I don't think that's what 12 Harold said.

13 Let me come back and have Harold's answer again be 14 put into the record. I don't think we ought to put words in 15 Harold's mouth. And if we're going to change what Harold 16 said, we'll let Harold do that.

17 COMMISSIONER AHEARNE: All right. Let me ask the

18. question, though: Would you be comfortable if one, two or 19 three years went by and nothing had been done?

20 MR. VOLLMER: Well, no, I wouldn't. But not because 21 I think there's a potential for contamination of the river 22 or something is there. I don't believe the integrity of the 23 <system is adequa*te. <But again, we have *large amounts of 24 relatively mobile activity, and I think that all due steps Ace-Federal Reporters, Inc.

25 should be taken.

rote 12 27 Let's see. I guess we've sort of covered the options 2 for continued storage. I think really t*he option is either 3 process*through EPICOR and store the decontaminated water or 4 start using Unit 1 tankage. I guess the third option clearly 5 would be to install new tanks. But again, I would want a 6 careful review of that type of process before.

7 COMMISSIONER KENNEDY: Are my mathematics correct 8 that if you used Unit 1 tanks, that at the current rate 9 those tanks would then, be f i.11.ed ,.in about a year?

10 MR. VOLLMER: That's about correct.

11 COMMISSIONER AHEARNE: So the sense I'm getting is 12 that, at least as far as what you've told us, it's not dis-13 similar to what you told us before and what was in the assess-14 ment on EPICOR. There is no real new information.

15 MR. VOLLMER: I don't believe that there's any new 16 information, except we're a little closer to running out of 17 room. That's all.

18 COMMISSIONER AHEARNE: Running out of room without 19 using TMI-1 tanks.

20 MR.** SNYDER: Dick, isn't there some recycling* of 21 the water to feed back?

22 MR. VOLLMER: John Collins mentions the disposal

23. of water.

24 COMMISSIONER GILINSKY: Use the microphone, please, Ace-Federal Reporters, Inc*

. 25 Mr. Collins.

rnte 13 28 MR. COLLINS: I apologize for being late. But the 2 problerns_that you have in using water are two things. At the 3 present time, of ~ou~se, we're trying to empty the storage 4 tanks f ram Unit 1, to -furth_er examine it. So that water has 5 to go someplace. Some of tihat water would go into the leak 6 tanks in Unit 1.

7 The additional problem is that if we start trans-8 ferring water from Unit 2 to Unit 1, it'-s going to be very 9

• hard" ,to, prove, *to the-'.public**tha t -you have not contaminated 10 that system, and then you're discharging water from Unit 2, e-2 11 which the order says we're not permitted to do.

12 13 14 15

- 16 17 18 19 20 21 22 23 24 Ace-Federal Reporters, Inc.

25

29 7409 03 0 I pv DAV Recognize you"re going to get the piping systems 2 .c.ontaminated, and then you"re going to have a problem trying 3 to prove you didn"t discharge water from Unit 2.

4 COMMISSIONER AHEARNE: You mean if at such time we 5 were-discharging water from Unit I?

6 MR. COLLINS: You"re discharging from Unit I right 7 now.

8 MR. WlLLMER: John"s saying allowing continuous 9 processing of Unit I water through EPICOR. Of course, there 10 are several sources of leakage in Unit 1.

1I MR. OlLLINS: If you remember, Commissioner, that 12 was part of the problem that we had with the 40,000 gallons,

• 13 was the discharge. That was contaminated from a tank that 14 contained Unit 2*water.

15 COMMISSIONER GILINSKY: I guess I didn"t entirely 16 follow that. Are there not tanks in Unit which are not 17 leaking?

18 MR *. COLLINS: jt"s not the fact that it"s 19 leaking. It"s the transfer piping system from Unit 2 to 20 Unit 1 is going to get contaminated, and it~s that same 21 interconnecting piping thatJs processing water in Unit for 22 discharge out to the Susquehanna. It"s all the same 23 internal piping system.

24 MR. CASE: We"re under a commission mandate not to 25 discharge water from Unit 2. But John is saying if you

30 7409 03 02 pv DAV transfer clean water from Unit 2 to Unit l, it has some 2 speck of activity from Unit 2 in getting into Unit l. That 3 might preclude dis~harges from Unit I.

4 C0MMISS I0.NER KENNEDY: Because discharges would go 5 through the same piping through which the Unit 2 water was 6 processed.

7 MR. COLLINS: That's correct.

8 MR. CASE: He'-s not discussing a public-safety 9 problem.

10 COMMISSIONER GILINSKY: But the fact is if we need Jl the -tank capacity, it's there. Is that not right?

12 MR. CASE: That's correct.

13 MR. COLLINS: That's correct. If you assume, 14 though,. that Met Ed would not remove the water from the 15 borated water storage tank, then you have sufficient 16 capacity for a number of months. But if they empty out the 17 borated water storage tanks four or five hundred thousand

.,J,8 **gallons, -you',ve *eaten up*a lot of that capacity in Unit l.

I9 MR. VOLLMER: Iha t water would have to be 20 processed. If it was disposed of, it would have to be 21 processed.

22 COMMISSIONER KENNEDY: At what rate are we now 23 discharging from Unit 1, approximately?

24 MR. OlLLINS: Well, from the plant water itself, 25 not including industrial waste treatment systems, we're

31 7409 03 03 pv DAV probably two tankfuls a week, about 10-20,-000 gallons a 2 week.

3 COMMISSIONER KENNEDY: If this problem arose in 4 the contamination of that piping and therefore a question if 5 that could be discharged, we could. then be filling those 6 tanks at the rate of 10-20,000 gallons a week in Unit 1?

7" MR. COLLINS: - That's right. If you were not 8 permitted to discharge.

9 COMMISSIONER KENNEDY: Which would further reduce 10 the amount of storage capacity. And i f we're not talking

.11 about additional year" s capacity 12 MR. COLLINS: Iha t would sti 11 be right, 13 absolutely right.

14 COMMISSIONER AHEARNE: John, what is your estimate 15 of the capacity?

16 MR. COLLINS: In Unit 2?

17 COMMISSIONER AHEARNE: In Unit l.

18 ,'.MR. COLLINS: In-*Unit l at *the present time it"s 19 approximately 225,000 gallons, assuming that you use the 20 blEed tanks.

21 COMMISSIONER AHEARNE: Now, John, what is your 22 conclusion as to the availability of Unit 1 tanks if we 23 reach that point? Do we have to put water in?

24 MR. COLLINS: The tanks are certainly available, 25 but I question whether we really want to transfer the Unit 2

32 7409 03 04 pv DAV water over there and then have the potential for either 2 . leaki3_ge from the ,piping syste,ms and transfer of 3 contamin~tion of the tanks from Unit 1. And then we're 4 faced with.the problem of trying to assure that we did not 5 violate the commission order or the City of Lancaster" s 6 petition.

7 I don "t think that it should be considered as the 8 viable option.

9 COMMISSIONER AHEARNE: I am having di.fficulty 10 finding the link. Are you saying that it would not be a 11 viable option because it would then put you managing that 12 operation in a situation where your options would be now 13 narrowed, or do you see it as being a health and safety 14 problem?

15 MR. COLLINS: No, I don-'t see it as being a health 16 and safety problem. Absolutely not.

17 COMMISSIONER KENNEDY: Is there a point at which 18 it b~comes a health and safety problem if, in fact, as has 19 earlier been suggested and as Harold, I think, in his own 20 statement suggested, as time goes on without any treatment, 21~ the likelihood of it becoming a health and safety problem 22 ,eventually begins to increase? Is that true?

23 MR. COLLINS: I certainly wouldn-'t deny that. It 24 is. I .think that-'s a true statement, yes.

25 COMMISSIONER KENNEDY: Therefore, if we foreclose

,p

33 7409 03 05 pv DAV opti.ons for dealing with it, you enhance the likelihood of 2 it .becoming .a heal th and safety problem. in some way.

3 MR

• CO LL INS: Yes , s i r.

4 COMMISSIONER GILINSKY: But I would like to 5 understand the basic point, which is, to me, if for one 6 reason or another EPICOR does no_t operate over the next 7 month or two, for whatever reason -- legal or mechanical or 8 technical -- is that capacity available for additional 9 storage in Unit l?

10 MR. aJLLINS: .Part of that capacity would be JI available. Part of it.

12 COMMISSIONER GILINSKY: And what is your estimate 13 of that capacity?

14 MR.* COLLINS: About 50 percent of that._

15 COMMISSIONER GILINSKY: Of what?

16 MR. COLLINS: Of Unit l capacity would be 17 available to transfer water from Unit 2.

18 COMMISSIONER GILINSKY: Which is 50 percent of the 19 200-some-o.dd thousand gallons?

20 MR. COLLINS: Yes.

21 COMMISSIONER AHEARNE: You're saying at Least 22 100,000 gallons?

23 MR. COLLINS: Sure.

24 COMMISSIONER GI LINSKY: Why do you say J 1 50 25 percent"?

34 7409 03 06 pv DAV MR. COLLINS: The licensee can begin to empty his 2 borated water storage tank. At the same time he's emptying, 3 he can be processing the water through his evaporation 4 system in Unit 1. So he does have a treatment system to 5 handle that water so that he can slowly begin to handle that 6 water through that system and make available then one of 7 those lead tanks, 85,000 gallons, just to hold the water 8 from Unit 2.

9 COMMISSIONER GI LINSKY: And is it absolutely 10 essential to empty the borated water?

11 MR. COLLINS: He must empty it to do further 12 examination of the piping system on that system.

13 MR. CASE: It.J's a necessary step.

14 COMMISSIONER GILINSKY: Yes. But if we decided 15 .that we n.eeded that capacity for storage of auxiliary 16 building water for whatever reason, then that could be 17 delayed; couldn't it?

l8 MR. VOLLMER: Yes.

19 COMMISSIONER GILINSKY: I am not asking you 20 whether it.J's a wise thing to do or whether we ought to do 21 it. I am just trying to understand what the capacity is.

22

• MR. COLLINS: It certainly could be delayed.

23 COMMISSIONER KENNEDY: Would, if required as an 24 order, is that it?

25 MR. COLLINS: I think it would take a very strong

7409 03 07 pv DAV recommendation.

2 COMMISSIONER KENNEDY: No, just technically, what 3 would it require to do it?

4 MR *. STELLO: I think it would re qui re. it.

5 MR. BICKWIT: But it is not consistent with the 6 l ic-ensee-' s license.

7 MR. STELLO: You're prohibiting him from doing 8 something he is -not riow prohibited from doing. I think 9 generally that requires an order to somehow modify his 10 license, to remove that restriction.

l1 COMMISSIONER AHEARNE: A further clarification:

12 if such a step were taken to prevent him from processing the 13 borated water, that in itself is or is not a health and 1_4 safety. problem?

15 MR

• CASE: I t i s no t .

16 C0MMISSI0NER*GILINSKY: We're not deciding here 17 which way to go. I think the answer to a simple question 18 -about how ,much capacity there* was in the most extreme 19 circumstance --

20 MR. COLLINS: I think the other thing you ought to 21 recognize, you ought to start transferring some of the 22 high-activity water from the auxiliary building in Unit 2 to 23 Unit I. Now you've created a situation where the radiation 24 levels in Unit l are going to come up, o+/-fering then a 25 potential for increasing exposure to the operators in Unit

36 7409 03 08 pv DAV 1*

2 COMMISSIONER GILINSKY: I understand.

3 *.Okay, thank you.

4 MR. VOLLMER: Does that wrap it up on the water?

5 MR. SNYDER: I have a question. Isn/t some of the 6 treated w~ter used as makeup for the primary system thatJs 7 leaking? It isn't all a gain situation. There is some net 8 recycling.

9 (At 3:25,.Commissioner Bradford leaves room.)

10 MR. VOLLMER: There could be. But the processing JI of the water has not yet been allowed.

12 MR. SNYDER: I understand that.

13 MR. VOLLMER: And the disposition of the processed 14 water initially would just be put in tanks and the licensee 15 would decide what he wanted to do with it. But indeed, some 16 of that could be used as makeup. That is one option.

17 MR. SNYDER: Is that the 500 gallons per day that 18 you mentioned .earlier?

19 MR. VOLLMER: On that order, yes.

20 MR. SNYDER: You said you isolated the nonprimary 21 system leaks into the containment~

22 MR. V<1LLMER: 500 gallons per day was the estimate 23 of the leakage into the reactor building, most of which will 24 be from the prima"ry system.

25 MR. SNYDER: That water comes from someplace.

37 7409 03 09 pv DAV MR. VOLLMER: It"s made up. Right.

2 COMMISSIONER GILINSKY: Could I ask one more 3 question on your clean-up plans. You said that the licensee 4 is considering plans for dealing with the water in the 5 containment. Are they also looking at that primary coolant 6 water?

7 MR. VOLLMER: Yes, sir.

8 COMMISSIONER GI LINSKY: Do we expect to see 9 something on this sometime soon?

1O MR *. VOLLMER: I believe they were preparing 11 some thing for us by the end of the month.

12 MR. COLLINS: That"s been delayed. I think it 13 will be sometime in October, at least.

14 COMMISSIONER GILINSKY: Would that cover b.oth of 15 those categories of water?

16 MRe VOLLMER: Yes.

17 MR. COLLINS: Yes; it would.

18 *ccJMMISSIONER GILINSKY: Okay.

19 If there are no further que*stions on the water, 20 perhaps we* ought to hear about the he.al th physics program.

21 MR. STELLO: Okay. We have been following the 22 heal th physics program for some time, even before the 23 accident began. Let me say the bottom line is we're not yet 24.. satisfied that the heal th physic.s program that they have on 25 site is adequate. Let me also suggest that the bottom line

38 7409 03 I0 pv DAV on this issue is *the health and safety of the operators.

2 That" s. principally the Lssue ,,we"re looking at, the adequacy 3 of the program to deal with the workers on the site.

4 There have been a number of over-exposures for 5 which there appears to have been one type or another of a 6 breakdown within the health physics program.

7 COMMISSIONER AHEARNE: Now, your reason for 8 stating it that way, Vic, is your conc~ntration on your Y concern is this on site?

10 MR. STEUO: If you look at the letters that have 11 gone back and forth betw_een us* and the licensee on this 12 matter, you"ll -see that the primary concern in those letters 13 have dealt with the system of the heal th physics program 14 i tseli wi tn regard to dealing with in-plant protection.

15 COMMISSIONER AHEARNE: .. And as far as people 16 outside the plant?

I 7 MR. STEUO: With respect to the health and safety 18 nf the public, we don"t see any major weaknesses or problems 19 that suggest an inadequacy in that regard. That clearly is 20 the primary focus of what our people are worried about 21 there; that is, if there"s anything that goes on that 22 suggests that there is an inadequate procedure or something 23 inadequate in the program, we are clearly looking over our 24 shoulder all the time. That"s clearly our primary focus, 25 but tha~~s not what_ we perceive as the major problem.

39 740903 11 pv DAV COMMISSIONER KENNEDY: Could you help me by 2

• i-d,ent,ifyi-ng *the approximate date of the NRC report ref erred 3 to in the letter we received from the oversight committee by 4 one E. R. Neely and J. R. White? It says the company is not 5 able to effectively administer the radiation program. When 6

• was that?

7 MR. STELLO: That le.tter is dated August I.

8 COMMISSIONER KENNEDY: '79.

9 MR. STELLO: 1979.

10 Let me go on with a very quick summary. We're

.11 continuing to ask the licensee, and he is committed to a 12 number of improvements in his program. We have a very large 13 health physics program at the site and will continue to have

.e 14 it. Initially, when we got there; we were dealing clearly 15 with an accident and an emergency situation. In fact, our 16 health physics program augmented his. We were actually 17 doing some of the surveys and monitoring ourselves with our rs own instruments and our own pBoplB.

19 COMMISSIONER KENNEDY: That's norma.lly expected in 20 .such circumstance.

21 MR. STEUO: I am not the least bit surprised that 22 we did that. It was the proper thing to do. And in fact, I 23 think we have to be a little bit better prepared to do it 24 even better in the future.

25 So, we have moved, up to now, clearly away from

40 7409 03 12 pv DAV that emergency situation, and they're clearly Looking to go 2 to the long-term program.

3 Another thing that we are looking at is putting 4 together a blue-ribbon panel to take a step back and take 5 another look at the health physics program, both from the 6 point of view of what we do and from the point of view of 7 what the licensee is doing, because we are clearly dealing 8 with an issue that we've never had any experience with 9

• before in dealing with an accident, an amount of radioactive 10 material in the plant, like we are now. We've got some 11 isotopes. that are there now that are different from the 12 iso~opes that we have there under normal operation.

13 What we're going to try to do is to get a team of 14 some of our best health physicists, both from within the NRC 15 itself, and we're looking very hard to get some people from 16 the laboratories outside of our system also to work with the 17 team. And we hope to have that pretty well lined up as to

,I 8 ,w. .ho is goi'ng to ,be on the team,* by the end of next week.

19 I think Harold committed we'd be doing this, in 20 his testimo~y up at Harrisburg some weeks ago.

21 I think it~s a good idea to take a step back and 22 Look at dealing with the situation at Three Mile Island 23 longer term and getting yet another independent thought, 24

• another independent look at this particular issue. I don~t 25 see and have not had any recommendations made to.me that

41 7409 03 13 pv DAV there is any major health and safety problem from the point 2 o.f View o.f 'the* pt1bl i c. But clearly, our people are very 3 concerned and are not yet satisfied that the on~site health 4 physics program has moved to the point where we're f.eeling 5 comf-0rtable with it.

6 COMMISSIONER GILINSKY: Why hasn't the program 7 improved to the point where it would satisfy us? What do 8 . you see as the source of the trouble?

9 MR. STELLO: Well, I .will ask someone to get into 10 the outstanding issues. They can summarize the issues that JI the licensee has yet to address and approximate dates by 12 which he.,s going to do* them. I don,,.t wish to suggest that 13 what I am tryini to say is to avoid the detailsi but I am 14 trying to get to the bottom line.

15 The bottom line is the focus of all of this has 16 been on the in-plant. You will see when we go through and I 7 listen to some of these details that that's the issue. I 18 would not like to leave the impression that there is 19 something inadequate there in the health and safety of the 20 public. We're committed to make sure that that's the case.

21 We're augmenting our heal th physics program up there as 22 necessary, and will continue to augment it as necessary to 23 make sure that that indeed stays just that way.

24 This is especially so when you start to look at 25 the future, and if they start to get to the point where

42 7409 03 14 pv DAV we're going into this processing the water and processing a 2 lot of the contaminated water in the building with the 3 .EPICOR, if we..,re starting to make containment entries, as 4 some of these other programs come into place where they need 5 to do that, we're going to make certain that the program 6 that exists and if need be, it will be a program that 7 consists of us augmenting as necessary whatever'5 there to 8 assure that their overall health physics program remains 9 adequate.

10 I am convinced that*over the long haul it will be 11 the case, but it is an unusual situation, clearly, we're 12 dealing with. We're bringing a lot of new people, outside 13

• their own Drganization, to talk about this.

14 COMMISSIONER KENNEDY: Excuse me. Is the licensee 15 now in compliance with the requirements of his license, tech 16 specs, license conditions, and everything else, in this 17 field?

18 COMMISSIONER AHEARNE: Existing tech specs aren't 19 written for_a reactor in the state that it..,s in.

20 COMMISSIONER KENNEDY: First, let..,s answer that 21 question.

22 MR. STELLO: They clearly have had problems with 23 their violations of existing- requirements. You had an 24 over-exposure. If you have an over'""exposure of an 25 individual, that..,s a violation of our regulations, clearly.

43 7409 03 1 5 pv DAV You need to measure that,* however, against the background 2 which you're working ~ith, which is very unusual. This 3 clearly isn't a routine activity.

4 So, in terms of the procedures that they had in 5 place, we're not satisfied with that. We want more because 6 more is needed to deal with the situation.

,., 7 COMMISSIONER KENNEDY: But before the situation

,j 8 arose, if there were some reason to suggest that the 9 situations had weaknesses of substantial nature?

10 MR

• STELLO : Ye s

• 11 COMMISSIONER KENNEDY: To what extent have those 12 been corrected? In oth~r words, where are we as compared 13 with where we were?

14 15 16 17 18 19 20 21 22 23 24 25

44 7409 04 01 kapDAV -MR. STELLO: May I .suggest_* that Jim Sniezek go 2 Jbr.ol,l,ghaod.. ?ll.mmarize the o.utstc3.nding issµes*, what they are 3 and what the .schedule is for resolutions and then answer 4 __ - that question.

5 COMMISSIONER GI LINSKY: - Let me al so ask whether 6 -the conterns about the training of the technicians who

_7 operated EPICOR are rel~ted to .Health Physics matters?

8 MR. -VOLLMER: Those were addressed strictly from

9. the operability of the system and knowledge of procedures 1O for the EPICCJR. system* specifically. The use of that would 11 - need the Health Physics expert_ise, *so the problems there 12 would overlap the EPICOR.

- 13 - COMMISSIONER AHEARNE: But those weren't 14 spe.cif i cally the' kinds of - concerns -- -

15

• MR. SNIEZEK:

• There are six basic areas where we 16 saw a concern regarding their in-plant Health Physics 17 program and p~otection-of the plant workers. I just

-_ ---1,8 **-mentioned* the s1x*:--areasiand I' talked briefly about each of 19 them.

20- The overall organization ~nd.responsibilities and 2.1 - the Health Physics functions is one area; the QA program 22 for Health Physics was another area; the .control of high 23 radiation areas; -the evaluation of airborne activities 24 _ results,-we had ~ome ~roble~s in th~t area; th~ respiratory 25 protection program; and the bioassay program.

45 409 04 02 kapDAV .*Now, on* the. _first one* that I am going to talk 2 about, the organtzatsions ,and responsibilities; the basic 3 pro bl ems

• that we

• saw up* the re *were wtth *;this condition that 4 eiisted. Subsequerit to the Unit 2.accident, a different 5 situation existed* and they had to* define the functional 6 .areas and who *was* responsible for what.* That was not done 7 . promptly and* that consequ*ently caused some problems. The 8 1ndi viduals responsible for* the various areas, the lines of 9 .responsibility and authority, have not been defined. That 1.0 i.ncludes - there are dual portions, overlapping Unit and 11 Unit 2 -- who is.responsible for them? .How does it all tie I2 together?

13 Now, . they* have thus far .completed the definition 14 of functional areas.in the responsibilities for the 15 tune tional areas. 0he of the things that is remaining to be 16 ,done is really tying together a little tighter the overall 17 *coordination betw.een Unit I and 2 and the overall

.. -.18  : ,,,re*s*J::)Onsibility* ,.ford.the "'He*aJ*th* Physics program. Who is 19 *. calling the shots. on the. total program at Three Mile Island?

~0

• In conjunctioh With the question that ~as asked of 21 Mr. VoJ.lmer about operator training, .Health Physics 22 *training is a part :of* this overall effort -that"s going on.

23 In f~ct~ the typical specifications, revisions to 24 the technical specification, will be referencing of a

• 25 radLation protection plan which includes* the training

,,tJ

46 7409 04 03 kap0AV related to radiological protection activities. And this 2 plan will be reviewed by the NRC before it is implemented by 3 the l ic en see. But we do not have that for review yet. I

4. don't have a firm date for when that plan will be submitted 5 for review, but it is scheduled for very near term.

6 MR. COLLINS: It was supposed to be submitted to 7 us this afternoon.

8 MRe SNIEZEK: Okay.

9 COMMISSIONER AHEARNE: Jim, when I had started 10 earlier, I mentioned something about pressing TMI. What I 11 meant was that my understanding was that I&E had been having 12 a consistent interaction with the management down there to 13 try and get these improvements. You've been working on this 14 for some months; haven't you?

15 MR *. SNIEZEK: -Yes, we've had at Least five 16 . management meetings. There was an i.mmediate *action letter 17 with the licensee where he committed to these specific 18 i-ssue*s* and'*im*pro.v*ernents -that<were *to be* made. I'm sure 19 Mr. Collins can attest to, there/sat least -- what? --

20 WEekly meetings with site management on these i.ssues, and as 21 anything is identified, immediately we mEet with the people 22 to determine their steps toward corrective actions.

23 MR. STELLO: Did you mean to say we issue an 24 immediate action letter?

25 MR. SNIEZEK: It was the revers~. They came to us

47 7409 04 04 kapOAV wi.th .the. specific commitments in these areas that were to be

,2 .a.dore ssed.

3. MR. STELLO: Okay. Let's get that cl ear. We were

• 4 prepared- to issue an immediate .action letter if we didn't 5 get the commitments *. We received.the commitments and 6 therefore did not. That's the question. Is that*true?

7 MR~ SNIEZEK:. That is true. That is-exactly what 8 happened.

S,i The second basic area in the quality assurance 10 program, we saw that they had *no systematic manner of

. .J 1 . overviewing what was going on, -independently of the people 12 - doing* the *work. One of the things .that we saw as _necessary 13 was the licensee on a.very frequeht basis would come in and

- 14 15 16 overview the effectiveness of the program. they were implementing, verify that the* problems that were identified were fo I lowed up on . and resolved. They had no. systematic 17 program in existence to do. that.

-1'8 Subsequent-'**t-o*our**df\s*cLi,s;sfon-s and meetings with 19 -_ them they initiated a quality assurance pr9gram on September 20 10th. - We have not sBen,the initial audit resulti yet, but 21 the. QA program. that the described -to. be implemented, met. our 22 satisfaction, and we'll be looking at those results as they 23 develop, and how e+/-fective it is.

- 24 25

• The control *of_ .high radiation area.

problems with the key tontrol, where there was unauthorized

• we saw

48 7409 04 05 kapDAV access into high radiation areas, there was not effective 2 control, and identification of new high radiation areas, 3 which goes into the survey question -- how adequate were 4 there surveys and evaluations of what existed in the 5 facility? It existed because people were going into areas 6 where they did not expect high radiation and they were 7 running into.high radiation.

8 COMMISSIONER KENNEDY: There were, in fact, some 9 overexposures at the site?

10 MR. SNIEZEK: There were some overexposures that JI resulted from that.

12 COMMISSIONER GILINSKY: Can you tell us something 13 about how many overexposures, and when?

14 MR. SNIEZEK: The number, as I recall, the whole 15 body overexposures, I believe there were four whole body 16 overexposures, and as I reca.ll they were early on in the 17 accident. There is, _I believe*- John might have it six 1*8 -:peop'l*e on -e*:xtremi*ty-,or *skin overexposures, and there is an 19 evaluation --

20 COMMISSIONER GILINSKY: Did these take place in 21 the first few days?

22 MR. SNIEZEK: The extremities and the skin took 23 place several w.eeks after the onset of the accident.

- 24 25 MR. STEUO:

August some time.

No, no, several weeks ago. It was in

49 7409 04 06 kapDAV MR

• CO LL INS : The f i r s t t hr e e --

2 MR. SNIEZEK: Oh, yes, yes, that-'s right. And we 3 have not completed our investigation on that aspect, to get 4 to.the bottom of the exact cause and the degree of 5 ove:rexposure. 1'/e had some preliminary results which we have 6 to investigate fu:rther to confirm that those are the true 7 values.

8 I believe that was the extent of the overexposures 9 that we have had there. But we are continuing to take a 10 hard look at it.

_I 1 COMMISSIONER GI LINSKY: Do you have a summary 12 listing of those, that you could provide us at some later 13 point?

14 MR. SNIEZEK: Sure. As of September 10th, the 15 NRC, we revieweq the new procedures, the new procedures for 16 control of high radiation areas, access to high radiation 17 areas. We were doing the surveys and we found that they had 18 good procedures *in place. There has b.een some continuing.

19 problem on implementation, especially as related to key 20 control. So as we identify the problems, we~re correcting 21 the spot problems and we~re continuing in this area to 22 follow up, to make sure we keep improvements on the 23 tightening up of their key control procedures at the site.

24 COMMISSIONER AHEARNE: As I recall, in some of the 25 earlier reviews, not only yours but also the consultants'

50 7409 04 07 kapDAV reviews for the company, part of the problem they had 2 identif.ied was poor education of personnel, leading to not 3 following the procedures. As I recall, at a number of 4 sites, the I&E inspectors say there has been lack of 5 following the procedures. You say here that you have 6 reviewed their procedures. How about your confidence that 7 they'll follow the procedures?

8 MR. SNIEZEK: Like I say, we are having 9 implementation problems right now. This is an issue that we 10 have to keep working on. We're not satisfied with the 11 implementation yet. That is one of our ongoing concerns for 12 the protection of the workers.

13 The fourth major area was evaluation of airborne 14 activity results. And here*we found that because of the 15 unique circtimstances after the accident, the licensee was 16 receiving beta exposures and beta in the air,that he had not 17 expected to s.ee. They were not up to speed on anticipating 18 the prob! ems that ,they* would find. They have implemented a 19 temporary procedure as of September 4 for evaluation of the 20 beta in the atmosphere, as coming up with beta-gamma 21 ratios. And the final procedure is to be issued by October 22 7. They have implemented the temporary procedure, and again 23 are evaluating implementation. It's a good procedure. We

- 24 25 have to evaluate the effectiveness of the implementation of the proc.edure so that we have enough information to say that

51 7409 04 08 kapOAV they/re doing a good job.

2 The respiratory protection program. Here again,

- 3 4

5 this is tied somewhat into the beta that they were experiencing in the ariborne activity, which they didn/t anticipate, and they had to improve their techniques for 6 analyzing the isotopes and the airborne activity. There are 7 techniques for calculating the stay time. There are 8 procedures for testing, taking care of the respirators 9 themselves, and as of 9/24, we have reviewed the procedures 10 and found they have good procedures i~ place. The 11 implementation is scheduled for October 7th, going through 12 their training programs with people now so that they 13 understand them. They/re scheduled to have them implemented 14 by October 7th.

15 Again, we/11 have to follow up on the 16 implementation to make sure that it is, in fact, effective.

17 The .last area we had major concerns over were.the bioassay 18 programs. **That ties in with the respiratory protection, 19 and their calculation of airborne activity at the plant.

20 They are upgrading their bioassay p~ogram to bring it in 21 line with Regulatory Guide 8.15 ANSI standards pertaining to 22 - bioassay programs. This ,is the whole body counting and the 23 urinalysis aspect of action levels, whether they should be 24 doing urinalysis, whole body counting, it/s scheduled to be 25 submitted to us for review by October 10th. So that program

52 7409 04 09

• kapDAV isn't fully underway yet.

2 Those are the key areas, and about where we stand

• - 3 4

5 on those key areas where we have major concerns.

problems to?

COMMISSIONER GILINSKY: What do you attribute the Lack of competence of the individuals involved 6 in the program, or improper, inadequate direction, or what?

7 MR. SNIEZEi<: I would attribute it to one of the 8 f_irst things that we mentioned, the overall responsibility

'-) and defining of who's responsible for.what, and being caught 10 unawares of potential problems that could exist. That's 11 what I would attribute it to, not the basic technical 12 expertise of the people heading up the program.

13 COMMISSIONER AHEARNE: But if you track back, 14 though, from not only your own*- that is, I&EJs -- reviews, 15 as well as the NUS review done for the company, that has to 16 call into question basic competence. You .say that you don't 17 have 18 '*MR.* SflIEZEK: I really do not know what the major 19 contributing factor is. It-'s probably a combination of --

20 MR. STELLO: Perhaps commitment.

21 COMMISSIONER GILINSKY: Is the management 22 sufficiently committed?

23 MR. STEUO: I think I put my finger on that. But 24 When you look at what's there now, I think you know the 25 significant dimensions of trying to deal with that question

53 7409 04 10 kapOAV today. If you have had an accident, you have got an awful 2 lot of things to deal.with. You are dealing with a 3 difficult problem for which you don't draw on a great deal 4 of experience. So we have a dimension that's been added to 5 this program which makes elements of this now much more 6 important and -difficult in terms of worker protection than 7 i t' s b e en i n the pa st *

• 8 COMMISSIONER AHEARNE: But if I go back and look 9 at -- just.over the last two months, take July. In the 10 middle of July when that first interchange of letters 11 between I&E and Met Ed o~curred -- here's what we've come in 12 to do. The sense I get as I look at that and the beginning 13 of August letters and the middle of August letters and your 14 latest reports including today, is that it's taking much --

15 now, I don't kno0 whether the original dates committed to 16 were realistic or not, but it seems to be taking much longer 17 to get to an acceptable stage on those steps than the 18 original agreements were, even the modified agrsements.

lY MR. STELLO: That's the point I was trying to deal 20 with. And try to ask yourself how fast things ought to move 21 now. I guess I tend to be impatient. I always want them to 22 move a lot faster than they do. But I have to be realistic, 23 and take a step back, and add that dimension that the 24 accident in that environment, and those demands placed on 25 that same system -- and ask if that could be a significant

,-r. 54 7409 04 l I kapDAV contributor. My judgment is, it is. I don"t know how to 2 separate that out.

3 COMMISSIONER GILINSKY: They"re obviously in a 4 much more demanding situation than the typical licensee 5 finds himself in.

6 MR. STELLO: Very much so. And I think that is 7 what adds this difficulty in making this move as fast as we 8 want it.

9 COMMISSIONER AHEARNE: But are you saying that you 10 are satisfied with their progress?

II .MR. STELLO: No. I guess I like everything faster 12 than I get it as a general matter, so I am never really

. 13 h~ppy with what I get unless it"s right away

• 14 COMMISSIONER GILINSKY: You"re pressing them to 15 improve.

16 MR. STELLO: How much faster can we reasonably 17 expect this to move? I don"t know how to answer that 18 question. I don"t know how to say, Are they moving as fast 19 as they can reasonably move, because we"re moving into an 20 area we"ve never been in before, and I don"t know the answer 21 to the question. I know when I was up at the site I was 22

• very impatient with the* progress that was being made, but 23 then when I realistically stepped back and took a look at 24 what has been a.ccomplished in the environment that"s there, 25 I think it"s a remarkable achievement. And I think maybe in

55 1409 04 12 kapOAV a few months when we do step back and recognize what we've 2 been dealing with 3 COMMISSIONER KENNEDY: If that is. true.

4 MR. STELLO: If it indeed is true.

5 COMMISSION ER KENNEDY: Now, if that is true, then 6 I come back to your point about commitment. I don't see how 7 they have achieved this remarkable achievement without a 8 pretty high level of commitment.

9 MR. STELLO: The answer -- when I use the word 10 commitment, management commitment was prior to the 11 accident. The NUS report came out and now I say, no matter 12 what the commitment is there, I have a dimension I've 13 added that deals with the real environment and the real 14 accident. You need to take that into account in trying to

. 15 ask yourself, Are we trying to get things moving faster than 16

• you reasonably can?

17 I know I always want it faster but then when I 18 left .there I took a step back and I looked at what has been 19 accomplished. I think that indeed, it's qUite remarkable.

20 An awful lot was done in a short time under very, very 21 difficult conditions.

22 COMMISSIONER AHEARNE: Is there now a single 23 person from the company side who's in charge of all of the

-- 24 25 Health Physics programs?

MR. SNIEZEK: I must refer that to John. I don't

56 7409 04 13 kapDAV think there is at this i:oint.

2 MR. COLLINS: There is no one single individual 3 responsible for the Health Physics program because of the 4 nature of their organization. Realizing that Unit 2 is in a 5 recovery mode~ Unit 1 is in a restart mode, they have split 6 their organization.

7 Now, with regard to station procedures, things 8 like dosimetry programs, air analysis programs, bioassay 9 programs, there is an individual assigned that 10 responsibility, but Unit 1 still still has .their Health 11 Physics program, Unit 2 has their Heath Physics program.

12 There's no one person up at th~ top, in a block, outside of 13 Bob Arnold.

- 14 15 16 COMMISSIONER AHEARNE: Is there a single person who is in charge of Unit 2' s Health Physics progr_am?

MR. COLLINS: Yes. There's one radiation 17 protection supervisor for Unit 2 and.one radiation 18 protection supervisor for Unit l.

19 COMMISSIONER AHEARNE: It .does have adequate 20 management control authority for all aspect of at least Unit 21 2's Health Physics program?

22 MR. COLLINS: Well, I think that that's been a 23 weakness, and I think it's bsen. a slow progression, over the 24 last couple of months, in trying to get a thorough

25. management commitment to make sure that the Health Physics

57 7409 04 14 kapDAV program stays on an upward keel. I think Vic would agree, 2 too, that immediately following the accident, management 3 attention. was directed at putting that reactor in a safe 4 position. Now, we're in a mode where management has to 5 recommi~ themselves and get the expertise that~s required, 6 get the necessary equipment in here that's required, train 7 the people because you're living in a different environment 8 now.

9 I think that's what really hurt us with regard to 10 the last six exposures. They should not have o.ccurred. But J\ 11 recognize that your nuclide distribution changed on you i

12 dramatically. The licensee did not expect to see the high 13 energy betas that we encountered. Normally, in an operating 14 reactor you don't see that type of concentration. Normally, 15 if you take care of your beta exposure or your gamma 16 exposure, and you put protective clothing on the people, you 17 take care of the be ta, but . that"' s not the case here.

18 19 20 21 22 23

- 24 25

CR 7409 58 HOFFMAN t-5 mte 1 COMMISSIONER AHEARNE: From the way you answered, 2 though, John, I would conclude that there is still some concern 3 on whether that Unit 2 health physics supervisor does have 4 adequate control over the health physics program.

5 MR. COLLINS: There's some concern on my part that 6 he exercises it. He may .have it on a piece of paper func-7 tionally that responsibility, but if he exercised it and 8 whether his management supports him, supports his role, I 9 *don't think that-we hav-e ,had ,a long .enough time to evaluate.

10 I don't think any of us up there are going to be satisfied 11 with the program until we are assured and they demonstrate 12 that we can back off from our intense surveillance on the

- 13 14 15 health physics program, and we haven't done that yet.

MR. SNIEZEK: That's the one area that we haven't addressed,* that tying together at the top. Right now it's 16 tied together at what may be too high a level, and that's the 17 area where we're looking at it very intensely to see if 18 improvement can be made by a closer tie together right at the 19 top.

20 COMMISSIONER GILINSKY: Does that pretty well 21 complete your presentation?

- 22 23 24 MR- STELLO: Yes.

COMMISSIONER GILINSKY: You will, of course, be preparing a response to the Senate Cornrni ttee, and the Ace-Federal Reporters, Inc.

25 Commission would like to see a report on the subjects.

mte 2 59 COMMISSIONER KENNEDY: When can we expect that draft 2 response?

3 MR. CASE: Monday morning.

4 COMMISSIONER AHEARNE: Vic, you're not the only one 5 that wants it right away. We need it, too .

. 6 MR. STELLO: Monday's not very far away.

7 COMMISSIONER GILINSI<Y: Very well. Thank you very 8 much.

e-5 9 (Whereupon, at 4:00 p.m., the hearing was adjourned.)

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