ML20149N046

NRC Staff Response to Interrogatories from TMI Alert/Sva.* Responds to Interrogatories Filed by TMI Alert/Sva on 880207.NRC Waived Requirement for Order from Presiding Officer Directing Discovery.Related Correspondence

ML20149N046
Person / Time
Site:	Three Mile Island
Issue date:	02/22/1988
From:	Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT
Shared Package
ML20149N047	List: ML20149N046 ML20149N054 ML20149N056 ML20149N061
References
CON-#188-5687 87-554-OLA, OLA, NUDOCS 8803010043
Download: ML20149N046 (34)

Text

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s SS 17 REl.AIED CORflESPONDEN.C!C

' DOCKETED USNFC February 22, 1988 UNITED STATES OF AMERICA 1B FEB 26 P3:14 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAkf7fr(gb ,f $dy,',

. B R A NJb.

In the Matter of )

)

GENFRAL PUBLIC UTILITIES )

NUCLEAR CORPORAT!ON, ET AL. ) Docket No. 50-320 OLA

) ASLBP No. 87-554-OLA (Three Mlle Island Nuclear ) (Disposal of Accident-Stetion, Unit 2) ) Generated Water)

NRC STAFF RESPONSE TO INTERROCATORIES FPOV TMIA/SVA

1. INTRODUCTION Tht: NRC staff (Staff) hereby responds to interrogatories filed by TMIA/SVA on February 7,1988. Although discovery against the Staff is on a different footing than discovery against other parties, II the Staff hu waived the requirement for an order from the presiding officer di-recting discovery in this instance and voluntarily responds to the interrogatories.

The Staff reserves the right to require compliance with 10 C.F.R. 6,2.720(h)(2)(l!) in the case of future discovery, if any, i

l

-1/ Pennsylvania Power and Light Company (Susquehanna Steam Electric Station , Units 1 and 2); ALAB-613, 12 NRC 317, 373 (1980);

10 C.F R. I 2.720(h)(2)(ll). l 8803010043 800222 4 PDR Q

ADOCK 05000M O PDR 4g(

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11. RESPONSES TO INTERROGATORIES General Interrocatory

1. State the name, present or last known address, present or last lenown employer, professional and educational qualifications for the follow-ing persons:

a. Those persons who formulated the EIS, Supplement i 2.

b. Those persons who attended any meeting (s) with the Li-censee "to discuss itent of infr,rmation provided, to seek new information from the Licensee that might be needed for an adeouate assessment," ($15 NUP.EG-0683, Supplement # 2 Final Report, June 1987, P.ix).

RESPONSE

a. Dr. Linde F. Munson, Evergreen innovations, Inc., 2323 Snohomish, Richland, Washington 99352. See attached professional quall-fications for additional requested information, Dr. William D. Travers, P.O. Box 311, Middletown, PA 17057.

See attached professional qualifications for additional requested a

information.

Dr. Michael T. Masnik, M.S. 13D16, USNRC, Washington, DC ,

I 2b555. See attached professional qualifications for additional requested '

1 information.  !

b. Same es above.

INTERROGATORY 1 Answer the following questions for sample (s) taken from the vari-ous locations of the accident generated water ( AGW).

a. State the date when samples were drawn.

t

b. Who drew the samples?

c. State the method of procurement of the samples,

d. Upon what basis was it determined by the Staff thit the sample (s) was representative of the tank from which it was sirawn?

e. How was the sample prepared for analysis?

f. Who undertook the analysis of the sample (s)?

. g. State the findings for all radionuclides expected in the water and indicate the lower level of detectability.

h. State the findings for all non-radioactive substances.

PESPONSE The NRC Staff carried out an analysis of one sample of accident-generated water ( AGV') . See response to interrogatory ato 2 for details regarding NRC sample acquisition and analysis. NPC Staff's informatior regarding samples obtained and analyzed by CPli are contained in letters and attachments from F. R. Standerfer (CPUN) to W. D. Travers (NRC) dated July 31, 1986, Octobcr 21, 1986, Febraury 3, 1987 and Febru-ary 18, 1927. Copies of the July 31, 1986 le'.ter have been served on SVA/TMIA, the Board and other parties. The February 3 and 18,1987 letters are reprinted in the PEIS Supplement No. 2. The October 21, 1986 letter from F. R. Standerfer, CPilH, to W. Travers, NPC, is in the public document rooms. For the samples analyzed by GPti, the Staff cann.st answer this interrocatory further. (Willien D. Travers)

INTERROGATORY 2 Concerning the "Final Results on Processed Water Testing" (Letter ,

dated January 11, 1988, Memorandum for W.D. Travers from D.J. Col- j lins) answer the following:

a. State the method by which the semple was obtained from the PWST 2.

b. Is this sample assumed to be representative of the total con-tents of the PWST 2? If "yes" answer the following: l State the basis for this assumption.

I.

c. Is this sample assumed to be representative of the 2.3 million gallons of AGW? If "yes" answer the following:

1. State the basis for this assumption and provide ,

documentation. l

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d. What were the findings for aj radionucludes expected to be present in the water?

.e. State the findings for all non-radioactive substances.

RESPONSE

. a. The sample was collected by GPUN personnel from the Processed Water Storage Tank #2 (PWST 2) from the tank sampling line which exits downstream from the recirculation pump, and upstream from the tank entry point. The PWST 2 sampiing was observed by an NRC inspector.

GPU Nuclear Sample Procedure 4212-CHM-3011.05, Revision 0, 5/23/84 was followed.

b. Yes. The tank was recirculated by pump for 4 days 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> at 250 gallons per minute. The volume pumped from, and returned to the tank, was more than 4 times the tank volume.

i. Recirculation mixing prior to sampling is assumed to provide a representative sample.  !

I

c. Yes. This tank has a capacity of nearly 465,000 gallons and is considered to be a large volume tank. The water has been treated by the Submerged Demineralizer System (SDS) and the EPICOP 11 demineralizer system, the same processing as has been given or will be used to treat the Accident Generated Water ( ACW). While some variations in' concentrations of radionucildes occurs among batches of AGW processed through SDS and EPICOR 11, the average concentrations resulting from this processing have not been significantly different.

i. Based on several years of experience with these processing systems the values obtained from sampling the PWST-2 are achievable for the balance of the ACW.

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d. The N RC's contractor laboratory's (Radiological and Environmental Sciences Laboratory (RESL) of the Department of Energy's Idaho Operations Office) findings were reported in the January 11e ,1988 Wtter for all radioisotopes analyzed. for in the sample.

e. Neither NRC nor RESL analyzed the sample for non-radioactive substances. (Travers)

INTERROGATORY 3 State the results of analysis of samples of water taken from the reactor co e and reactor building basement during the period when the reactor is being defueled and the water has contained its highest con-centration of: (a) boron, (b) hydrogen peroxide. Indicate:

a. results of sample analysis for both radioactive and non-radioactive substances for before and after Epicor ll/SDS processing.

b. method of procurement of sample

c. who procured the sample?

RESPONSE Analysis of a recent Reactor Coolant System sample are as follows

(Sample of February 8,1988)

Ag 110m (1.3E-3 uCl/mi Ce 144 < 2.0 E-3 uCl/mi Co 58 <1.8 E-4 uCl/mi Co 60 6.3 E-3 uCi/mi l Cs 134 1.7 E-3 uCl/mi '

Cs 137 1.1 E-1 uCl/ml Ru 106 ( 4.1 E-4 uCl/mi Sb 125 5.6 E-2 Cl/mi Fe_ 1.95 ppm Cl _

2.4 ppm NO 3- 0,30 ppm POg_ 0.29 ppm SO 4.25 ppm Dissolved O 12.9 ppm Cross Alpha 5.5 E-4 uCi/mi Gross Beta 1.3 uCl/ml Tritium 7.0 E-2 uCl/mi Sr-90 1.1 uCl/ ml j pH 7.55 2 l

Conductivity 4290 umho/cm l 4

1 l

l Turbidity 6.8 NTU l Bogon 5595 ppm  !

Na 1760 ppm ,

slo _y 31.5 ppm l F .085 ppm Total Organic Corban 12.7 ppm i Ag .30 ppm l Ni 2.6 ppm '

Cd 1.92 ppm

a. Representative analysis of recent SDS processing influent and l

effluent streams are as follows: (Samples of Batch S153, May 25-28, l I

1987) influent Sr-90 : 9.67 E-1 effluent Sr-90 : 5.8 E-3 l Influent Sb-125 : 4.13 E-2 effluent Sb-125 4.13 E-2 influent Cs-134 : 2.43 E-3 effluent Cs-134 : 1.93 E-5 )

Influent Cs-137 : 1.33 E-1 effit.ent Cs-137 : 4.8 E-4  !

Influent gross alpha : 1.05 E-4 effluent gross alpha : 7.27 E-5 l I

(all results are in uni'.s of uCl/ml) .

Analysis of recent EPICOP. processing influent and effluent streams are as I

follows: (Samples of Batch 395, January 17-18, 1988) l influent uCl/ml effluent uCl/mi i Gross Beta /Camma 2.4 6.5 E-3 Tritium 5.3 E-2 5.5 E-2 Co-58 4.9 E-4 7.7 E-7 Co-60 1.2 E-3 3.1 E-5 Sr-90 4 E-1 3.5 E-3 Ru-106 1.3 E-2 1.6 E-5 Ag-110m 5.2 E-3 6.6 E-6 Sb-125 6 E-3 8.3 E-5 Cs 134 2.5 E-2 1.9 E-5 Cs 137 1.6 1.1 E-3 Ce 144 6.7 E-3 1.3 E-5 gross alpha 8.2 E-6 4.6 E-6 pH 6.95 2 4.23 2 Conductivitv 788 umho/cm 11.2 umho/cm i Boron 3516 ppm 3546 ppm Sodium 280 ppm 0.1 ppm j The sample results listed above are generally representative. No correlation of the results to RCS boron or peroxide concentrations has been performed by the NRC Staff. The NRC does not have in itt

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possession a recent sample analysis for the water in the reactor building i basement.

b. Samples were collected by the licensee using the licensee's

- procedu res.

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c. All samples were collected and analyzed by the licensee's chemistry department. (Travers) i l

INTERROGATORY 4 .

l State the basis does the Staff determine that the concentration for 1 the isotopes - Actinium 227; Americium -241 & 242; Californium -249,

-250, 6 252; Curium 242, -243 -244, -245 and -246; Neptunium -237, Protractunium -231; Plutonium 238, -237, -239 and -242; Thorium 228 and -230 and Uranium -232, does not exceed 1% of the total radioactivity  !

In the AGW? l RESPONSE 3 l

The Staff has not stated that the concentration of these radio-nuclides does not exceed 1% of the radioactivity. The Staff has stated i that the environmental impact (dose) of the radionuclides other than the ,

"principal ones" (as defined on page 2.4 of Final Supplement 2) is less l l

than 1% of the environmental impact of the principal radionuclides.

However, from the results of the analysis of PWST 2 (see response 2 above) transuranics make up less than 1% of the total curie content of AGW as they do in Table 2.2 of Supplement No. 2 as well. (Linda F.

Munson)

INTERROGATORY 5 Provide documentation and water sample analysis to Indlcate that all the AGW will be processed by Epicor/SDS to provide the results indicated by GPU Nuclear listed in Table 2.2, EIS 6/87. Documentation should provide for results of full range of radionuclides expected to be present in the Ar.W.

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a. does the staff expect this same removal effectiveness for that water presently in the reactor core and elsewhere where the boron con-centration is higher? State the basis for this expectation.

b. at any time has the NRC found evidence that the Epicor I/SDS systems were not operating as efficiently as originally (1979) believed? If "yes" state:

• 1. when?

11. state the findings and subsequent water analysis lii . what steps were taken tn achieve the efficiency expected?

RESPONSE

The licensee's July 31, 1986 proposal to dispose of AGW indicates that AGW will be processed by EPICOR ll and SDS prior to evaporation. )

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a. The Staff exper.ts removal effectiveness to remain the same for the borated water in the reactor . coolant system and spent fuel pool .

Boron passes through the media in the first vessel, the media ir the l

following vessels is adjusted to remove modest arrounts of horon while l l

retaining the ability to remove radioisotopes.

b. No. The estimate given in NUREG-0591 was greater than 90%

l removal; this has been achieved. (Travers) l

~

INTERROGATORY 6 State the basis for the determination that: "The environmental impact from radionuclides other than the principal ones was determined to j be insignificant (i .e . less than 1%) relative tn the principal radio- '

nuclides". [EIS Final. 6/87 P2-4)

RESPONSE

in estimating the environmental impact (i.e. offsite dose) of evaporating ACW the NRC staff, using mathematical models, calculated dose for all of the radionuclides predicted to be contained in ACW. The whole boay dose from radionuclides other than the identified principal radionuclides was 'ound to be less than 1% of the total dose. (Munson)

.g.

INTERROGATORY 7 Did the NRC undertake its own analysis of the microorganisms present in the water to determine:

a. any pathogen problems?

b. the presence of those materials which would result from virus organisms?

c. Whether or not there ninht be any adverse effect of releasing these microorganisms into the environment by any of the disposal op-tions? If the answer is "yes" state:

1. Kindt of test (s) undertaken 11 . how the sample was procured lii . the results of these tests.

If the answer is "no" state:

Iv. Is the NPC relying on past experience or knowledge in dealing with these microorganisms? Indicate what this past experience or knowledne is to enable the NRC to r eke decisions about these microorganisms,

d. State the basis for your claim that boiling is expected to kill off any remaining microorganisms.

e. State the basis for your clain that the microorganisms would remain in the evaporator bottoms and be solidified. 1

f. Does the hydrogen peroxide added to the water "kill" or  !

"sterilize" the microorganisms?

g. Indicate how "killing" or "sterilizing" the microorganisms l would prevent column plugging of the SDS/Epicor systems. Provide the documentatien for this assumption. l l

RESPONSE

I a-c, i, il, 111. The NRC Staff did not undertake its own analysis of l 1

the microcrganisms present in the water.

c, iv. In preparing the information in Supplement 2 dealing with the microorganisms my knowledge of biology and physics was

• j supplemented by previous experience of my former coworkers with microorganism growth in reactor spent fuel poofs at the Hanford nuclear reservation, in those cases, periodic additions of hydrogen peroxide  !

successfully increased visibility and reduced filter plugging,

d. I stated that evaporative bolling is expected to kill mh,;roorganisms entering the evaporator. Boiling at 212 F {100CC) has been used as en acceptaole method of sterilization for centuries and

_jo.

effectively kills most life forms. The boiling point in the evaporator will be c6nsiderably above this temperature because of the bolling point elevation brought about by the presence of the dissolved boron. Hence, l* concluded that evaporation would be expected to kill the microorganisms.

e. Exposure to elevated temperatures result in a breakdown of cellular constituent of microorganisms -- cellular debris would either be ,

volatllized or remain in the evaporator bottoms. Those microorganisms that are resistant to elevated temperature could not exist as a vapor and therefore only a small fraction (those resistant to elevated temperature and contained in water droplets comprising the carryover fraction) would not be contained in the evaporator bottoms crd be solidified,

f. Hydrogen peroxide added to the AGW causes mortality of the microorganisms .

o. Column plugging is related to the concentration of microorganisms in the wate r . A reduction in the concentration of microorganisms lessens the likelihood of column plugging. (Munson) l l

i lNTERROGATORY 8 What is the Maximum Permissible Concentration (MPC) in Air Above background for:

a. restricted areas?

b. unrestricted areas? for all those radionuclides determined to exist in the water.

I, name the radionuclides which exreed the MPC for releas-es into the air and water for:

a. restricted areas

b. unrestricted areas i

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1

RESPONSE

a, b. See 10 C.F.R. Part 20 Appendix B tables 1 and 2 column 1.

i. None of the radionuclides contained in the AGW would exceed MPC limits for NRC staff evaluated disposal alternatives evaluated in PEIS (Travers)

Supplement 2 NUREG-0603.

INTERROGATORY 9 in determining the dose /rlsk from the release of tritium into the air by evaporation: ,

a. was the dose assumed to be from tritium oxide? or

b. was the dose assumed to be from tritium gas? State the basis for this assumption.

P.ESPONSE As stated in Section 2.2.1.1 and elsewhere in Supplement 2 the tritium in the accident water is considered to "in the chemical form of water with one of the nonradioactive hydrogen atoms replaced bv a tritium a tom " , that is HTO. All radiation dose calculations were made on this i basis. If the tritium were present as tritium oxide (T 0),

2 or tritium aas (T2), in the presence of a large quantity of stable water (H 2O), it would exchange so that most of it would be present as HTO. This assumption l of HTO was also used in calculating radiation doses. (Munson) I INTERROCATORY 10 In EIS 6/87 P. 7.5,17.1.11 the Staff stetes, "Although it is pos-sible to calculate the concentration of each particular radionuclide that will result in an ersumed 4-mrem dose, it could be misleading because l the dose from all radionuclider are mixed." State:

l a. Why it is misleading.

! b. When all radionuclides expected in the AGW are included, I v hat will be the resulting dose in mrem of disposal of the water by any i

! option? l

c. When considering the risk of exposure to radiation from any l of the disposal options, did the NRC consider the additional exposure l and other cdverse health implications from: l 1

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1. other sources of contaminants which might adversely affect the population within a 50 mile radius of TMl? If "yes" state the sources considered.

11. the adverse impact of post defueling monitored storaDe?

111 . operations at Unit I? -

FfESPONSE

a. The EPA limit is for the sum of doses from all radionuclides.

Listing a concentration limit for each of the isotopes separately might lead the casual reader to believe that each radionuclide might be present at ,

the lir.ted concentration without exceeding the EPA limit. This is. of course, false.

b. Table 5.1 (p. 5.2) of Final Supplement 2 lists the maximum expected radiation dose from all radienuclides listed in Table '2.2 (those listed as less than some value were assumed to be present at the listed value) for each of the disposal alternatives considered.

c. In calculating the radiation dose and converting dose to risk, as discussed in Section 5 of Supplement 2, other risk and other sources  !

of radiation exposure were not a fector. As stated in Supplement No. 2, the calculated risks are "incremental risk" (in addition to other risk").

See Sections 7.5.2 and 7.5.6 on pages 7.24 and 7.25. Concerns l l

regarding other risks and other sources of radiation were considered and l I

addressed in Section 7.5 of the Final Supplement 2. (Munson)

INTERROGATORY 11 2 Did the NP.C consider more recent references (than the 1903 re-port) for data on boron as recommended by EPA? [EIS 6/87, letter 28, P. A53). If "yes": State what new information the NRC considered. If "no": State the basis for rejecting the EPA's recommendailon.

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RESPONSE

Upon receipt of the EPA's letter, Dr. William Kirk, author of the comment, was contacted by Dr. Travers for information on background r'adiation measurements which were also referred to in the EPA's letter.

He reportedly volunteered to send the raciation measurements and also some more recent references to boron in the environment. When the data arrived from Dr. Kirk it contained only the background radiation data, in view of the schedule for the Final Supplement 2 the NP,C staff elected l to go ahead without addressing the comment.

Since that time some of the references listed in response to Request for Documents to the NRC, item 6 have been reviewed and have shown that the environmental impact of boron is reasonably well described in the I final supplement. Toxicity to additional species of fish, especially salt

! water fish, has been reported. (Munson)

INTERROGATORY 12 Ftate the highest concentration values for all the radlonuclides expected to be in the influent to the evaporator at any particular time?

Provide documentation to support this determinatien,

a. what form will each of the radionuclides take (e.g. solid,  ;

gas, dissolved in water)? '

i

RESPONSE

, The licersee's submission indimtes the concentration of the principal 4

contaminants in each of the current water storage locations and indicates

.I which water will receive additional treatment prior to evaporation. Any of the water for which retreatment is not planned might go directly to the l evaporator. The radionuclide concentrations in Table 2'. 2 of Final Supplement 2 can reasonably be considered a maximum in the retreated  ;

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l

-.--n . - - - - - - - - - - , - - - - ,,n

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water for all radionucIldes except tritium which will not be effected by lon exchange treatment. Values from the licensee's submission should be used for tritium.

• Y'Ith the exception of tritium, the physical and chemical form of the radionuclides has not been determined. Tritium is presumed to be present nr. water. Most of the others are probably dissolved. (Munson)

INTFPPOGATORY 13 Since the initial estimate of the inventory of the tritium and oth2r radioisotopes was made and utilized in the original EIS, has the NRC

. received additional and/or different estimates for the amount of radio-nuclides which might be present in the water? If "yes":

a. state any additional estimates of the inventory which were received, arri

b. from what agency or body were the estimates of the inventory received?

If "no":

a. explain the basis for rellance on the original estimate.

RESPONSE

Since publication of the original Programmatic Environmental Impact Statement (PElS, March 1981) on the TMI-2 cleanup, the NRC staff has received additional information on the quantity of radionuclides estimated in the accident generated water ( AGW). ,

e a. Additional information on AGW was received from GPUN in their submittal "Disposal of TMI-2 Water" (July 1980) and in two GPUN letters of February 3 and February 18, 1987 and are reproduced in Appendix A of PEIS Supplement 2. Information on the radionuclide content of AGW was also obtained via NRC analysis of an AGW sample (see response to interrogatory no. 2),

b. Additional Information, as stated otove, was obtained from GPUN and an NRC sponsored analysis of an AGW sample. (Travers)

INTERROCATORY 14 Di-J the NRC consider the effects which the estimated temperature of the core at the time of the accident might have on the contents of the water? If "yes":

a. state what these effects were and the basis for any assumptions.

RESPONSE

To determine the effect that the elevated core temperatures had on the contents of the water one would evaluate the results of analyses of the water. No assumptions regarding the results of such analysis were made. Rather, the results of analysis of the water were used to deter-mine what is in the water. (Munson)

INTERROCATORY 15 Name those chemicals or other solutions permitted by the NRC to be used by CPU Nuclear for any aspect of the clean-up.

a. Was an analysis undertaken of the effect of these additions on the Epicor II, SDS, Evaporator, or other methods of disposal, or the holding tanks of the ACW?

b. what were the results of any analysis undertaken? )

RESPONSE

The following is a list of those chemicals for which NRC approval l'

was sought and granted. It is not a comprehensive list of chemicals that may be used, as specific approval is not required in all uses of chemical reagents.

Diatomaceous Earth: a filter media primarily consisting of sille in a fine power form. It would be represented chemically as SiO '

2 Vendo Product 1182: a proprietary coagulating agent used to enhance the performance of the filters In the defueling water cleanup system. (t consists primarily of an organic polymer represented chemically as LC 5 "7"6 "'

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r 4

Vendor Product 1192: A proprietary cation coagulating agent used to enhance the performance of the filters in the defueling water

cleanup system. It consists primarily of an organic polymer represented ehemically as lC8 "16 "*

Hydrogen Peroxide: an oxidizing agent used to control biological contamination. It is represented chemically by the formula HO.2y HOUGHTO-SAFE-620: a hydraulle fluid used for operation of

certain defueling tools. It is a mixture of 40% . water, 401 glycol, l5%

polyolycol, and 5% additives.

Quintolubric 007: a hydraulic fluid used for operation of certain defueling tools. It consists primarily of 4 Methyl-2,4 pentanediol and Alkanolamide plus additives as emulsifiers, corrosion inhlbitors, and b,locides.

a. Results of laboratory tests to determine the effects of hydrocen peroxide and vendor product 1192 on EPICOR type resins and zeolites were submitted to the NRC for information.

b. The tests showed that hydrogen peroxide in concentrations up  !

to 100 ppm would have no deleterious effects on EPICOR type resins and t

zeolites and that vendor product 1192 would reduce the ion removal l

efficiency of the resins. (Travers)

INTERROCATORY 16

Name all those aspects of the clean-up which will require use of ,

l the water until Unit il is placed in Post-Defueling monitored storage. l l

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4. J

_ 17 - -

RESPONSE

The water will be used in piping system flushes, decontamination, 4

washing of fuel bearing canisters , and for shleiding and to bssure ,

adequate boration of the reactor coolant system and in pools in 'tbe reactor and fuel handlino building. (Travers)

INTERROGATORY 17 What chemicals or other solutions are expected to be used to com-plete cles.a-up of Unit ll to the point where it will be placed in post-Defueling monitored storage?

RESPONSE

The chemicals listed in response to interrogatory 15 are those which are expected to be used prior to the disposal of the AGW. (Travers) i i

j ET,ERROG ATORY 10 Even though the chemicals picked up by the water in the reactor buildino de r.ot become radioactive, did the NRC analyze the effect of these chemicals on the populatior<, upon release into the ervironment? If "yes" state:

a. the cuantitles and names of chemicals considered

b. the results of any studies

c. the basis for any conclusions, if "no": State the basis for the determination that there was no need to ,

cralyze the impact from ncn-radioactive substances. l RFSPONSE in preparing the PEIS Supplement 2 the NRC Staff did not identify additional chemical contaminants to the ACW, not evaluated in Supplement

( 2, which could result in en environmental hazard. (Travers)

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\ l INTEPROCATORY 19  ;

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a State the basis for the claim that these elements are removed by i

]

separation, filtration, and ion exchange processes. Indicate how the elements are detected and measured. Indicate how much of these ele-ments remain. [EIS 6/87 P. 7.7 6 7.5.2)

RESPONSE

in responding to this interrogatory I made several assumptions because of the imprecise nature of the question. I have assumed that "these elements" refers to chemicals, oil and grease discussed on the referenced page in Section 7.2.5 (not in Section 7.5.2 as indicated).

Hydrogen peroxide will largely be decomposed to water and oxynenated compounds formed - from microorganisms shcrtly after its introduction into the system. Excess will spontaneously degrade to water and oxycen which will not adversely effect ion exchange r.ystems , the evaporator or the environment.

Diatonaceous earth is an insoluble filter aid which is added specifically to be removed in subsequent filtration.

Coagulating agents are added to the water specifically because they attach to particulates and agglomerate them for more efficient removal.

Some coagulating agents, if present in excess, bond to lon exchange resins fouling them. The initial concentration is usually on the order of parts per million. The concentratien after filtration and ion exchange will be several orders of magnitude less.

Chenicals from the reactor building may include oil and grease, calcium, oxides of Iron, sulfates, and other trace constituents. Olis and grease in water are removed by both filters and ion exchange media.

Oxides of iron occur in soluble and insoluble forms. Insoluble forms are removed by filtration, while soluble forms aro lenic and would be removed by lon exchange resins. Some gelatanous forms of iron oxide which can form in basic solutions are removed by both filters and ion exchange media .

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_ ig .

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The Staff has no information on the licensee's program for measuring  ;

these chemicals. The NPDES permit, issued by the Commonwealth of Pennsylvania, requires the licensee to monitor oil and grease in effluents released to the river. (Munson)

INTEPROCATORY 20 State the name and amount of each chemical which has been deter-mined to vaporize in the evaporation option and state the basis for this determination.

a. state the name or amount of each chemical which would not be expected to vaporize. State the basis for this assumption. [EIS 6/87 P'.

7.7 9 7.2.5 Line 32].

RESPONSE

From my current knowledge of the chemicals that are likely to reach

! the evaporator, I do not believe that any contaminant which would reach the evaporator would vaporize into the environment with the possible exception of trace amounts of ammonia and other amines formed by the hydrogen peroxide oxidation of protein molecules. The quantity of these compounds will be small and they are not generally considered pollutants ,

at the possible concentrations. (Munson) l 1

INTFPP,0CATORY 21 1

EIS 6/87 7.15 7.31.11 state: ,

a. where eveporation in an open cycle has been practiced in the I nuclear industry other than at Maxey Flats i

b. from where did the water evaporated at Maxey Flats originate?

c. for how many years was this system in operation before being closed?  ;

RESPONSE

The Staff is not aware of other uses of open cycle operation from j evaporators. While evaporation of radioactive wasto streams is a common  !

i

practice in the nuclear Industry, the vapor is normally condensed and discharged to the river. Within the nuclear Industry there are numerous instances of open cycle evaporation from ponds, however i do not tonsider these to be relevant.

The water being evaporated at Maxey Flats is leachate from burial trenches. I do not know how long evaporation operations were conducted at Mexey Flats, nor whether they are still being conducted at Maxey Flats. (Munson)

. INTERROGATORY ??

EIS P. 3.6 3.1.1.2 state:

a. the maximum expected evaporation rate in gallons per minute

b. the basis for the assumption that "0.1% or less of the total particulate are routinely achieved". State the amount of total particulate in each location,

c. whether or not all non-tritium material was considered when determining the release rate.

RESPONSE

a. In NUREG-0683 Final Supplement 2 the Staff assumed a maximum feed rate of 20 gal / min.

b. NllREG-0017 Rev.1 (March 1985) provide NRC staff results of evaporator decontamination factors measured at several nuclear power plants and based on a generic review of nuclear industry data.

3 NUREG-0017 lists a decontamination factor of 10 (i.e. 0.1%) as the best reference for estimating evaporator operating performance.

c. All non-tritium material was considered. (Travers)

INTERROGATORY 23 State the basis for the assumption that the treatment to remove the micro-organisms and suspended solids are not expected to change the

predictions of the environmental impact associated with the various dis-posal options.

a. what is this treatment assumed to be?

b. has the Licensee applied for permission to use any particular treatment?

RESPONSE

The treatment includes 'the addition of hydrogen peroxide as a blocide, which decomposes to water and oxygen, filtration, and the addition of a coagulant which is removed by filtration or settling.

a. The treatment is a combination of-filtration, and the addition of a blocide and a coagulant. The treatment to destroy microoraanisms consists of hydrogen peroxide (an oxidant represented chemically as H22O ). Removal of suspended solids through filtration and settlina is enhanced by the addition of coagulating agents in the defueling water cleanup system,

b. The licensee submitted safety evaluations in support of its i request for NRC approval for the use of hydrogen peroxide and l 1

coac ulating agents in the reactor coolant system. (Michael T. Masnik)

INTERROG ATORY 211 j i

Whet is the radionuclide concentration in the evaporator bottoms I for all these radionuclides expected to be present in the water?

RESPONSE

The radionuclide content in the evaporator bottoms is expected to be approximately 1000 times the concentration in the feedwater for all radionuclides except tritium where it will be approximately equal to the concentration in the feedwater. The average feedwater concentration is listed in table 2.7 of Final Supplement 2. Results of the analysis of AGW are given in the licensee's submittal. (Munson) l

L INTERROGATORY 25 Was the dose to the maximally exposed individual from retention on-site of evaporator bottoms calculated taking account of all radio-nuclides present?

RESPONSE

The dose to the maximally exposed Individual (and the population) was calculated based on the radionuclide content of the water described in table 2.2 of Final Supplement 2. (Munson)

INTERROGATORY 26 is there expected to be a sediment remaining at the bottom of the holding tanks of the AGW? If "ves": i

a. what would this sediment contain and

b. does anv expected sediment become a part of the influent to the evaporator? State the basis for these determinations.

RESPONSE

The holding tanks have received only water that has been filtered and subjected to lon exchange. Any solid material in the tank would either have been in the tank prior to putting the water In, formed in the ,

tank, or entered the tank through the vent. There may be some sr5all amount of dirt from tank construction, some growth of microorganisms, but much less than in the reactor vessel where there is a source of light.

There may be some rust that has formed in the tank. There may be dust or other material that entered through the vent, but that is also expected to be a small quantity, if the tank liquids are fed, unfiltered to the I evaporator, this material would enter the evaporator and remain with the evaporator bottoms. (Munson)

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INTERROGATORY 27 Are there any atmospheric conditions which would affect the need to alter the feed rate to the evaporator? If "yes":

a. what are those conditions? '-

b. In what way(s) would it offect the feed rate?

RESPONSE

The only atmospheric conditions of which I am aware that would require alteration of the feed rate to the evaporator are the severe weather conditions and that would require shutdown as discussed in Secticn 7.3.1.1 on pages 7.12 and 7.13 of Final Supplement 2. (Munson) l INTERROGATORY 28 Will the operatcrs of the evaporator be subjected to NRC regula-tions and supervision?

RESPONSE

The licensee, who will be operating or responsible for the operation of the evaporator, will be subject to NRC regulations. The NRC will not supervise the ooeration of the evaporator but rather provide regulatory oversite including periodic inspection of the licensee's operation.

(Masnik) lNTERROCATORY 29 How often will the NRC inspect the evaporator operation?

RESPONSE

4 If onsite evaporation is approved, inspectors stationed at the TMl site will conduct inspections of evaporator operations throuahout the evaporation process. Inspectors based in NRC Region I may also carry a

out inspections of evaporator operations. The specific frequency of i

Inspections has not been determined at this time but will be designed to assure that licensee's actions conform to all NRC regulations. (Masnik)

(NTERROGATORY 30 .

Will the NRC undertake its own periodic analysis of the evaporator influent? If "yes" state:

a. how often

b. what is the threshold of radioactive contamination in the water above which operation of the evaporator will be made to cease?

RESPONSE

No. Operation of the evaporator will be limited by effluent relea'se limits established in the TMI-2 license. The TMI-2 effluent release limits are based on the dose criteria as set forth in 10 C.F.R. 50 Appendix 1.

The NRC will inspect and audit the licensee's operation to include procedures and results of influent water analysis. (Masnik)

INTERROCATORY 31 Has the NPC considered the corrosive potential which the addition of the chlorine to the water would have on all parts of:

a. Epicor il

b. SDS

c. evaporator. if "yes":

1. were tests undertaken? If "yes", explain the tests and results, if "no":

1. explain the basis for the assumption that no tests were needed li. identify past experiences and/or tests performed by the NRC on the use of moisture separators and vapor superheaters which would be used on the evaporator to insure that liquid droplets and dis- l solved components are not discharged with the vapor.

RESPONSE

The NRC is unaware of any chlorine additions to the water planned or actual. (Travers) )

INTERROGATORY 32 Will the evaporator be dismantled following disposal of the ACW and the resulting mass taken to a low level waste site?

RESPONSE

The ultimate disposition of the evaporator is not known by the NRC staff. However, it is likely that this equipment will be decontaminated and will not require disposal as low-level radioactive waste. (Tra /crs)

INTERROGATORY 33 -

Did the Staff consider the additional dose to the workers from pump failure, hose failures, and maintenance during evaporator use? If "no": State reasons for not considering dose. if "yes": What would be the dose?

RESPONSE

in preparing the occupational radiation dose estimates the dose from routine and special maintenance was considered. In many nuclear pit'nts evaporator maintenance is a significant source of occupational radiation exposure. I assumed that the evaporator would elcher be rew or decen-taminated before being brought on site. The eccidcnt-generated water, even when concentrated in the evaporator, is not expected to be a significant source of external radiation exposure to maintenance workers.

l Some internal exposure from tritium vapor is possible. The range of occupational exposure estimates given in Supplement 2 is sufficlint to l cover expected evaporator maintenance.

I did not, however, consider some sort of major failure type t'ccident such as a sudden and unexpected major leak while a large number of workers were present. The onsite and offsite impacts of sdch a event l l

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were considered to be bounded by the accidents discussed Ir Section 3.1.1.3 on pages 3.8 and 3.9 of Final Supplement 2. (Munson)

PNTERROGATORY 34 Explain the basis end provide Information for "release of 0.1% or less of total particulate are routinely achieved". [EIS 6/87 P 3.6] Does this refer to evaporators in an open cycle?

RESPONSE

See response to interrogatory 22b. This refers to evaporators in a closed cycle. (Travers)

INTERROGATORY 35 Upon what basis does the Staff assume that "there may be biological mechanisms that can repair damage caused by radiation at low  ;

doses and/or dose rates". [EIS 6/87 P 5.4, 5.2)  ;

RESPONSE  !

Repair of radiation damage has long been used to explain the fact that the effects of large doses of radiation are dependent on the rate at which the dose is received. For example a single dose of several hundred rem may be fatal within 30 days for a significant nercentage of a population of organisms. The same dose, spread out over a year or more

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may result in no apparent injury within the same period of time. This ]

phenomenon is discussed in nearly all texts on radiation biology and by the ICRP and others. A partial list of references is provided to Request for Documents to the NRC, item 10. (Munson) l INTERROGATORY 36 l l

Was the possible restart of Unit il a consideration in determining .

whether or not the AGW should be disposed?  !

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RESPONSE

The "possible restart" of TMI-2 was not a consideration in the NRC staff's determination that AGW should be disposed. The staff's conclusions and their bases are summarized fully in NUREG-0683 Supple-ment No. 2 (June 1987) (see p'6.1). (Travers)

It!TERROGATORY 37 If the water was to be stored in tanks on site would either the volume or curie content or range of radionuclides present in the water preclude resumption of operations of tJnit il?

RESPONSE

The NRC Staff has not evaluated the requirements for restart of Unit 2. (Masnik) 1 INTERROGATORY 38 When did the NRC last inspect those tanks holdina the accident generated water for corrosion?

a. did any of the tanks exhibit signs of corrosion? If so; 1 which ones?

11, what is their life expectancy?

RESPONSE

Visual examinations of water storage tank external surfaces are m6de regularly (at least once per month) by NRC inspectors. Detailed inspections for tank corrosion, including inside surfaces, have not been per formed,

a. No. (Travers) if4TERROGATORY 39 i

is there an alternative to venting the tanks to the atmosphere should the water remain stored in these tanks?

l

RESPONSE

'Y es . Alternatively a cover gas system (e.g. nitrogen) could be designed and constructed which could eliminate the need to vent the Storage tanks. (Travers)

INTERROCATORY 40 Has radioactive liquid waste been stored at any site regulated by the NRC or DOE? If "yes", state:

a. the volume and contents of water stored.

b. where was the site? -

c. how long was it stored in tanks? '

d. what were the consequences, if any?

e. did the tanks remain intact?

RESPONSE

I have no knowledge of the storage of liquid radioactive wastes at DOE sites. Various amounts of liquid radioactive wastes of varying curie content are stored for varying amounts of time at many NRC licensed facilities. All licensec' nuclear power stations have liquid radioactive waste processing systems that collect, store and process radioactive wastes for recycling to the reactor coolant system or for release to  ;

the environment. (Masnik) 1 INTERROCATORY 41 i l

in determining whether or not to dispose of this water, has the NRC relied on any past experiences of any utility or foreign government? If "yes" state:

a. where was this water located?

b. what was the experience upon which the NRC relied?

c. Is there evidence available showing adverse affects of disposing of such water? If "yes", what is the evidence?

l i

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RESPONSE

No. The bases for the NRC Staff's conclusion regarding disposal of AGW are detalled in NUREG-0683 Supplement No. 2 (June 1987). -(See p. <

e.1 for a summary of NRC Staff bases.) (Travers) l Ill. RESPONSE TO REQUEST FOR DOCUMENTS The following responses are provided to the TMIA/SVA request for documents.

REQUEST NO.1 Any notes, tapes, transcripts, or other documents ensuing from the meeting (s) between NRC and CPU Nuclear concerning disposal of the water [Els Pix, 6/87).

RESPONSE

I No notes , ta pes , transcripts or other documents resulting f%m meetings between the NRC Staff and contractors and GPU personnel concerning disposal of the water are available (,ther than those already on the docket.

REOUEST NO. 2 '

Documents pertaining to analysis of the water following processing I by Epicor ll/SDS. -;

RESPONSE

See attached documents entitled:

a. Data Report -

Reactor Coolant System Sample Results T PO/ TMI-122 Rev. 2, Dec. 1986. Project Planning and Analysis a Department CPUN.

b. GPUN RAS Sheets for Unit 2 RCS Samples 88-00429, 88-00820, 88-01198, P8-01466, 88-01754, 88-02030, 67-16004, 87-18909, 87-14256, i

87-15150.  !

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c. GPllN SDS Processing Batch Data for Unit 2, through Nos. S153 through S120.

d. CPUN EPICOR 11 Datch Reports 352 through 358.

e. GPilN EPICOR 11 Batch Reports 362 through 397. .

f. CPUl4 EPICOR ll Batch Reports 341 through 351.

g. Laboratory s .aets for NRC sample of ACW prepared by Radlological and Environmental Sciences Laboratory, Idaho Operations ,

Office, Sample 14185.

h. Additional SDS, RCS and EPICOR ll Ratch Reports (approximately 2 feet of material) from the period prior to 1985 are available for in-spection at the NRC TMl-2 site office.

)

REOUEST NO. 3 .

Documents pertaining to analysis of water samples drawn from the

.eactor core and reactor building basement prior to processing by Epicor  ;

l110DS.

4

RESPONSE

The Staff and its contractor have searched their files for documents

pertaining to this request and have found none.

REOUEST NO. 4 Documents pertaining to any analysis or tests related to the following:

a. microorganisms in the Accident Generated Water ( AGW) ,

. b. chemicals in the ACW.

RESPONSE

4 The Staff and its contractor have searched their files for documents pertaining to this request and have found none.

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4 l

REQUEST NO. 5 .

l Documents pertaining to the more recent (other than 1979) l estimates of the core inventory.

RESPONSE

See attached document entitled TMi-2 Isotopic Inventory Calculations "

l by Schnitzler and Briggs, 1985 EGSG Idaho, Inc. Prepared for the l

l USDOE under DOC Contract No. .DE-ACO7-761001570. Also see Characteriza-tion of Contamination in the TMI-2 Reactor Coolant System, by Cunnane and Nicolosi, November 1982, EPRI NP-2722. -

RECUEST NO. 6 Documents pertainino to the environmental impact caused by boron. ,

RESPONSF A copy of a recent computer literature search is attached, t

REQUEST NO. 7 Documents to provide evidence that non-radioactive substances will be rtmoved by separation, filtration and co-exchange processes.

RESPONSE

Response to this request can be found in standard technical literature (e.g., residential water softeners) available at any technical  !

l library. l REQUEST NO. 8 Documents showing that open cycle evaporation is practised in the nuclear Industry. ,

l i RESPONSE Pickard and Kirby, cited in Supplement No. 2 and supplied to the Public Document Rooms subsequent to issuance of the Draft document.  ;

r l REQUEST NO. 9 Documents pertaining to the results of any tests showing the effect l or corrosive agents on:

a. Epicor ll

b. SDS

c. Evaporator

RESPONSE

The Staff and its contractor have searched their files for documents l covered by this request and have found none.

REQUEST NO.10 Documents to support the assumption that there are biological mechanisms which can repair damage caused by radiation at low doses and/or dose rates. ,

i RESPONSE  !

I Standard texts on radiation biology contain this material and 'are available at technical libraries, f

-- Hall, E. J. 1978. Radiobiology for the Radioloalst. decond i Edition. Harper and Row, Inc., Hagerstown, Maryland. $10,00.

]

-- Prasad, K . N. 1974 Human Radiation Biology. Harper and l

Row, Inc., Hagerstown, Maryland i

! -- Johns, H. E., and J. R. Cunningham. 1974. The Physics of l Radiology. Charles C. Thomas Publisher, Springfield, Illinois.

International Commission on Radiation Units and Measurements.

1 1979. Quantitative Concepts and Dosimetry in Radiobiolooy. International Commicslon on Radiation Units and Measurements, Washington, D.C.

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--__ - - - - - _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ . ________-_____-___I

33

-- Rubin, P., and G. W. Casarett. 1986. Clinical Radiation Patholoay. Vol t, W. B. Saunders Company, Philadelphia, Pennsylvania.

E.

REOUEST NO.11 Documents related to th'e effectiveness of moisture separators and vapor superheaters on avaporators operating in an open cycle mode.

RESPONSE

This information is typleally supplied by equipment vendors and -

l i specific to a particular piece of equipment. The Staff and its contractor have searched their files for documents covered by this request and have found none.

l l i l REQUEST NO.12 i

Documents to provide evidence of the expected decontamination factor of the evaporator operating in an open cycle.

P.ES PONSE Copies of NRC NUREC-0017 Rev. 1 and NUREG/CR-1992 are attached, i

I l

REQUEST NO.13 I I

Documents to provide evidence that releases of .1% or less of the l total particulate will be achieved by the evaporation in an open cycle.

RESPONSE

See attLebed documents response 12 above.

REQUEST NO.14 Documents demonstrating the amount and components of:

a. total gases l

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34 _

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b. total particulate 4

c. total dissolved radionuclides in the ACW. .

RESPONSE

s See memoranda dated January 11, 1985 from D. J. Collins, NRC, to W. D. Travers, NRC, previously provided. Also, see licensee submittals dated July 31, 1986 February 3, 1987 and February 18, 1987. The February 3,1987 and February 18, 1987 letters are reprinted in the PEls Supplerrent 2.

Respectfully submitted,

• l i

j W. M ,

bP Colleen P. Woodhead Counsel for NRC Staff Dated at Rockville, Maryland this 22nd day of February,1988 i

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