ML12340A666

Official Exhibit - RIV000126-00-BD01 - in the Matter of: Entergy Nuclear Indian Point 2, LLC, and Entergy Indian Point 3, LLC, for a State Pollution Discharge Elimination System Permit Renewal and Modification,

ML12340A666
Person / Time
Site:	Indian Point
Issue date:	01/23/2012
From:	Entergy Nuclear Operations, Entergy Nuclear Indian Point 2, Entergy Nuclear Indian Point 3, Riverkeeper
To:	Atomic Safety and Licensing Board Panel, State of NY, Dept of Environmental Conservation
SECY RAS
References
RAS 22996, 50-247-LR, 50-286-LR, ASBLP 07-858-03-LR-BD01
Download: ML12340A666 (28)

Text

3895 Pages 3895-4125 STATE OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION In the Matter of:

Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC DEC No.:

3-5522-00011/00004 SPDES No.:

NY-0004472 For a State Pollution Discharge Elimination System Permit Renewal and Modification Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc.

DEC App. Nos.

3-5522-00011/00030 (IP2) 3-5522-00105/00031 Joint Application for CWA § 401 Water Quality Certification ARBITRATION BEFORE:

Daniel P. O'Connell, ALJ Maria E. Villa, ALJ NEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION 625 Broadway, 1st Floor Albany, New York 12233 January 23, 2012, 8:21 a.m.

---

Reporter:

Alan H. Brock, RDR, CRR ------

ahb@fabreporters.com www.fabreporters.com Farmer Arsenault Brock LLC 50 Congress Street, Suite 415, Boston, Mass. 02109 617.728.4404 fax 617.728.4408 RIV000126 Submitted: July 13, 2012 EXCERPT United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of:

Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #:

Identified:

Admitted:

Withdrawn:

Rejected:

Stricken:

Other:

RIV000126-00-BD01 10/15/2012 10/15/2012

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3972 examine and determine whether there's an area that would be prone to leakage, to your knowledge, would that be able to be prevented?

JUDGE VILLA:

Sorry, I didn't understand.

MS. BRANCATO:

Sorry.

I can rephrase.

Q.

You talked about water chemistry.

To your knowledge, are physical or visual inspections of the uninspected portion of the pool liner possible, to your knowledge?

A.

I can't say they're impossible.

I know they haven't been done yet with the technology that currently exists.

Q.

Thank you.

I'd like to ask a few questions about the Unit 1 spent-fuel pool, and if I could turn your attention to Entergy Exhibit 33, the GZA site investigation report.

A.

I have that.

Q.

In your direct testimony -- I'll take one step back -- on Page 9, Lines 11 and 12, you testified that the Indian Point spent-fuel pools are no longer an active source of radionuclides to the subsurface.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3973 A.

Page 9, what lines again?

Q.

Lines 11 through 12.

A.

Yes.

Q.

In the GZA report, on Page 113 --

A.

Of Page 113.

Q.

Now, in the first full paragraph -- the first full paragraph indicates that, quote, "From a contaminant plume perspective, these historic releases still represent an ongoing legacy source of strontium in the groundwater to the south side of Unit 1.

This is because strontium partitions from the water phase and adsorbs to solid materials, including subsurface soil and bedrock.

The strontium previously adsorbed to these subsurface materials then partitions back to and continues to contaminate the groundwater over time, even after the storm drain releases have been terminated," end quote.

To your knowledge, when this paragraph refers to "these historic releases," are those the releases from the Unit 1 spent-fuel pool?

A.

Yes.

Q.

I'd just like to get a better understanding

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3974 of this concept of partitioning.

Based on this statement in the GZA report, would it be accurate to say that strontium that's leaked from the Unit 1 spent-fuel pool that's been retained in the subsurface would continue to be released to the groundwater in the future?

A.

Yes.

Q.

And to your knowledge, is this a phenomenon that would continue during the proposed period of extended operation, meaning for a 20-year period?

A.

We would expect partitioning would, you know, continue at least into the renewal period.

Q.

And does GZA or anyone else, to your knowledge, measure how much contamination is partitioned into a solid form at any given time?

A.

We have not done that.

Q.

And like wise or similarly, do you monitor when the contamination partitions into liquid and releases to the groundwater?

A.

We monitor the groundwater and the radionuclide activities in the groundwater, and that gives us an indication that that may be going on.

Q.

At any given time are you measuring how

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3975 much contamination is partitioning to the groundwater?

A.

We are measuring how much contamination is in the groundwater.

Q.

Partitioning, as I understand it from this report, relates to the radionuclides collecting on the surface of structures; is that accurate?

If not, can you please explain your understanding of what that --

A.

Solid surfaces in general, they can be, you know, natural or anthropogenic.

Q.

And can contamination migrate into subsurface structures, to your knowledge?

MR. TRACH:

I'm going to object.

Can contamination migrate into subsurface structures?

I'm not sure I understand.

JUDGE VILLA:

I think we need to break it down a little bit.

I don't know what you mean by "subsurface structures" and "contamination."

If you're following the same line, I've lost the trail.

MS. BRANCATO:

Okay.

Q.

I think you just indicated that radionuclides can partition onto anthropogenic

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3976 and/or geological surfaces in the ground; is that correct?

A.

That's correct.

Q.

So what would be your understanding of anthropogenic sources?

A.

No, they'd be anthropogenic structures.

Q.

Anthropogenic substructures.

Could you describe what those could be?

A.

Concrete foundations.

Q.

Would it include pipes?

A.

Yes, it would adsorb to the surface of pipes, depending on the type of pipe.

Q.

What I was trying to gain an understanding of a few moments ago was whether particular radionuclides could migrate through the subsurface structures, like pipes, under the ground.

Are those radionuclides, to your knowledge, capable of moving into -- inside of a pipe, for example?

A.

If you have a solid pipe, I don't believe the radionuclide is going to move through the wall of that pipe.

Q.

Thank you.

This paragraph I read earlier from Page 113 of the GZA report talks about

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3977 strontium.

Does partitioning occur with other radionuclides that have been released from the Unit 1 spent-fuel pool?

A.

Yes.

Q.

And which radionuclides?

A.

Most radionuclides will partition.

And the one that I know has been released to some extent is cesium, which does partition.

Q.

Thank you.

And does nickel 63 partition, to your knowledge?

A.

I believe it does, but I don't know specifically.

Q.

On Page 23 of your rebuttal testimony --

A.

One second.

I have it.

Q.

On this page you discuss the north curtain drain sump and the sphere foundation drain sumps at Indian Point.

And on Lines 14 through 17 you indicate that these components still capture residual contamination.

Is that accurate?

A.

Let me read it.

Q.

Sure.

A.

Yes, these drains are still capturing

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3978 residual radionuclides.

Q.

So does that mean that the contamination is adsorbing to the structures?

A.

No.

I mean, it can adsorb to the structure, but --

I think you need to rephrase the question.

Q.

Sure.

I'm trying to get at whether partitioning applies to these structures.

Does the contamination partition to or from the north curtain drain or the sphere foundation drain sump?

A.

If there are radionuclides in the water, they can partition to the outside or inside of the pipe, depending on where that water ends up.

Q.

And so will residual contamination that's captured in the north curtain drain and the sphere foundation drain sump continue to be released into the environment in the future?

A.

Water that enters the drains containing radionuclides will be captured by those drains; and depending on which drain and which radionuclide, some of it will be released through a monitored pathway.

Other portions of it are taken out through

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 3979 treatment and disposed of -- I guess I don't know exactly where it's disposed of, but it's off-site.

Q.

Would any of that ever have the opportunity to enter back into the groundwater once it's in the drain or the sump?

A.

Once it's in the drain or the sump, it most likely goes through process, and then it's either disposed off-site, depending on the process, or it's released into the discharge canal.

From that point it's not likely to go into the groundwater.

Q.

Would contamination that you indicated could partition and adsorb to those structures, could those radionuclides go back into the groundwater?

A.

If it's radionuclides that are partitioning to the inside of the drain lines, then if it unpartitions -- i.e., comes back off -- it would then move into the water in the drain, and then from there it should move to process and not go to the groundwater.

Q.

Thank you.

If you could turn to Page 74 of the GZA report, Exhibit 33.

A.

I have 74.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4040 in the groundwater?

A.

It reduced it during that time period, yes.

Q.

Was this well pump test -- to your knowledge, this was designed to determine the feasibility of extraction or for some other purpose?

A.

To determine the feasibility and gather other parameters so that we could better evaluate it.

Q.

And would you agree that as of the time of the status report in 2006, based on this status report, that at this time extraction had been determined to be feasible?

JUDGE VILLA:

I'm sorry, when you say "at this time," do you mean at the time that exhibit --

MS. BRANCATO:

At the time of the status report, which was December 2006.

A.

It's feasible, but it has pros and cons.

Q.

I'm just trying to get a sense of when GZA determined that it could be done.

Would you agree that it was around this time frame?

A.

At this point -- by this point in time, we would be able to say that extraction of some type is

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4041 feasible.

Q.

Thank you.

And would extraction of the radiological contamination at Indian Point, would that result in less contamination existing in the groundwater?

A.

Yes.

Q.

And would extraction of the radiological contamination result in less contamination going into the Hudson River?

A.

Not necessarily.

Q.

Could extraction prevent contamination from reaching the river?

A.

It could prevent it from reaching the river through the groundwater pathway.

Q.

You testify on Page 38 of the rebuttal, Lines 8 to 9, that MNA is a correct strategy.

MR. TRACH:

What page?

MS. BRANCATO:

Page 38 of the rebuttal.

A.

Page 38?

Q.

Lines 8 to 9.

And here you testify that MNA is the correct strategy because active and identified sources of groundwater contamination have been eliminated or controlled.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4087 rapid or not.

Obviously, some things are much more difficult and take longer, and, you know....

Q.

Thank you.

I'd like to turn to a few questions about extraction at Indian Point.

A.

Which document are we going to?

Q.

I think right now it's to your testimony, on Page 41 of your rebuttal testimony.

A.

Okay, I have it.

Q.

As we discussed earlier, you would agree that pump tests were performed around the time period of 2006 to determine whether extraction would be feasible; is that correct?

A.

A pump test, yes.

Q.

Were there not tiered pump tests that occurred?

A.

There were multiple phases to the single overall pump test.

Q.

And you may have already testified to this, and if you did, you don't have to answer.

But you agree that extraction is feasible at Indian Point?

A.

Some level of extraction in certain locations is feasible.

Q.

To your knowledge, was there a particular

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4088 reason why extraction was not chosen as the remedial technology to apply to the site?

A.

There are lots of reasons.

We looked at multiple, you know, potential remedial technologies, and we balanced, you know, the advantages of the technology against the disadvantages.

And effectively we did that in this case, and we then, you know -- we presented the advantages and disadvantages as we saw them from a geohydrologic standpoint.

We presented that to Entergy as well as NRC, DEC.

And then those parties came to the conclusion of what was the appropriate remedial response.

Q.

But there was no technical reason why extraction could not have been implemented at Indian Point?

A.

It could have been implemented in that particular well; but in fact, there were some significant disadvantages, like it would move strontium from Unit 1 to Unit 2, which we did not think was something that we wanted to do.

Q.

And in your rebuttal testimony you indicate that a certain number of groundwater extraction

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4089 wells could be installed.

Would those be at different locations to account for that potential issue that you just identified about commingling?

A.

I'm not sure we specified in here how many wells.

But there are other -- in here we looked at different places where you could put in wells, wells could be put in.

And again, there would be a set of advantages and disadvantages that may be different depending on where these wells were put in.

So we did not have a formal proposal here.

We were just looking at is it feasible to put in wells and, you know, what are the pros and cons of those.

You know, we did not get as far, you know, in this location.

And here we're talking actually farther downgradient.

So we didn't get as far in that analysis.

But wells could be put in.

Q.

And you indicated there were concerns about drawing the contamination plumes together.

Did the plumes as they exist now commingle anyway?

A.

The plumes commingle in a specific area down near the river, but the previous questions were with respect to the pumping test that we ran, which was farther up, and there the plumes are not

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4090 commingled.

Q.

If the plumes toward the source of the contamination did commingle, how does that affect how extraction could be conducted?

Does it make it more dangerous?

Are there limitations?

I'm just trying to understand what the concern was.

A.

The major concern was you're going to move strontium to a place where it doesn't currently exist, and that means it's going to partition to those natural materials, and now you have it someplace where it otherwise wouldn't exist.

And that's certainly not one of the things you want to do.

Q.

But would you be withdrawing it from the environment at the same time?

A.

You would withdraw some of it, but other parts of it, large parts, would partition to the environment.

You have the solid materials where it wasn't before.

Q.

And would you be drawing it away from areas where it was and now it would not exist if you --

A.

It's unlikely that you would be able to move it from one place and then put it here.

What

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4091 would happen is, you would still have it in the original place, Unit 1, and you would pull it toward Unit 2, and then you would smear strontium through partitioning on all the geologic materials between Unit 1 and Unit 2.

And now you have a bigger area that's contaminated with strontium adsorbed to the solid materials -- which, again, is a disadvantage.

Q.

And if and when a full remediation of the Indian Point site ever occurs at the time of decommissioning the plant, if the strontium was drawn into different locations, as you've indicated, does that affect the way the cleanup is conducted?

I'm just trying to understand the disadvantages of drawing the contamination such that you could extract it, when, as you've indicated, the groundwater is not used for any purpose anyway.

MR. TRACH:

I'm going to object to questions about what is going to happen at decommissioning of the site.

JUDGE VILLA:

What's the relevance of that, Ms. Brancato?

MS. BRANCATO:

I'm just trying to understand the implications of employing an

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4092 extraction well where the pilot test took place, to get an understanding of how the strontium exists at the site and just how -- it just goes to the efficacy of extraction and feasibility.

JUDGE VILLA:

Let's move on.

Q.

And if extraction were to be implemented at Indian Point, do you have a position on where those wells would be sited?

A.

There are lots of different positions.

We have not investigated to come up with the optimal positions.

It depends on what the objectives are.

Q.

And could extraction wells be sited directly over the strontium plume such that it wouldn't have to shift and move and partition to other subsurface structures?

A.

That's potential.

We'd have to look at it.

But, you know, there may be structures in the way, et cetera.

Q.

And would you agree that siting extraction wells as close to a source of contamination is more effective than siting wells further away to a source?

MR. TRACH:

I'm going to object.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4093 Effective at what?

MS. BRANCATO:

Effective at extracting contamination.

A.

I have trouble with the word "effective."

It depends what the objective is.

It absolutely may not be the right place.

Q.

And to your knowledge, would siting extraction wells -- do you have a sense of where the optimal location would be in order to prevent migration to the Hudson River?

Would it be closest to the source of the contamination or closer to the river?

A.

With the specific objective of preventing radionuclides from getting to the river, it would be closer to the river.

Q.

And if extraction wells were sited closer to the river, that wouldn't draw the contamination closer to the river?

A.

In fact, that could be a downside, a disadvantage.

Q.

When you say "disadvantage," does that mean that that location could result in radionuclides still reaching the river?

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4094 A.

No, no.

You could put extraction wells in near the river to stop them from reaching the river; but that means you will still then potentially pull radionuclides that are farther upgradient down towards that area, depending on where the wells are -- which I think is what your question was.

Q.

Thank you.

As we've discussed and as you've testified to in your written testimony, the leaks -- the plumes were investigated in 2005; is that correct?

A.

That's when we started the investigation.

Q.

And it's now 2012.

Do you have an opinion about whether, given the fact that seven years have passed, would that affect the ability at all of extraction wells to completely prevent migration of contamination to the Hudson River?

A.

No.

Q.

And is it your position that extraction wells could completely prevent the migration of radionuclides to the Hudson River?

A.

Through the groundwater pathway, yes.

Q.

And could multiple extraction wells at different locations be effective at extracting the

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- CROSS RIVERKEEPER) 4095 radioactive elements from the groundwater?

A.

They could be effective.

Q.

And how much volume could an extraction well actually extract?

A.

It totally depends on the formation it's in, how the well's designed, how deep it is.

It could be any number -- there are too many variables.

Q.

On Pages 35 and 36 of your prefiled rebuttal --

A.

I have Page 35.

Q.

And here, on Pages 35 and 36, you testify about the adequacy of Entergy's aging management program for buried and underground piping and tanks for detecting and preventing future leaks at Indian Point.

Both you and Dr. Esselman are attributed to the testimony that's provided on these pages.

I would just like to understand the extent to which you informed this particular testimony.

A.

I think I've already addressed that, haven't I?

Q.

I'm trying to get a sense of it in particular relation to this testimony.

A.

Basically, Dr. Esselman and I do work

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- REDIRECT ENTERGY) 4097 don't.

So it's an added line of protection.

Q.

That's all I have.

Thank you, Mr.

Barvenik.

JUDGE VILLA:

Redirect?

MR. TRACH:

If we could have a brief moment with the witness.

JUDGE VILLA:

How about until 10 after.

MR. TRACH:

Thank you.

(Recess taken.)

JUDGE VILLA:

Let's go back on the record.

Before you start any redirect, Mr. Trach, I apologize:

Ms. Rotini, I always forget, any cross for this witness?

MS. ROTINI:

No, Your Honor.

JUDGE VILLA:

Judge O'Connell, any questions?

JUDGE O'CONNELL:

No, thank you.

JUDGE VILLA:

Mr. Trach.

MR. TRACH:

Thank you.

REDIRECT EXAMINATION BY MR. TRACH:

Q.

Mr. Barvenik, you were asked some questions about the north curtain drain associated with Unit

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- REDIRECT ENTERGY) 4098 1.

A.

Correct.

Q.

Can you just describe for the ALJ's what exactly the north curtain drain is?

A.

Certainly.

If I can maybe use this exhibit.

Q.

That's Entergy Exhibit 124?

A.

It's not on here.

Is it 124?

Q.

Yes.

A.

Okay.

Effectively, this is Unit 1 here.

This is the containment building, pool here, and then the chemical systems building is here.

Q.

Can you just -- sorry, we have to keep indicating here, because we won't be able to see you point in the transcript.

A.

I can actually draw a line where the north curtain drain goes.

I can draw it on the figure.

It's around the nuclear service building to the north and east.

Then it runs east along the north side of the vapor -- or the containment building, until it gets to the fuel pools.

And then it runs along the north side of the fuel pools proceeding east, until it gets to the east side of the chemical

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- REDIRECT ENTERGY) 4099 systems building, and then runs along the east side of the chemical systems building, proceeding south, until it gets about to the middle of that building.

And then the south curtain drain does exactly the same thing, except on the other side.

JUDGE VILLA:

Can you just mark it with NCD?

THE WITNESS:

Yes.

Done.

Q.

Thank you.

A.

So that is the location of the north curtain drain.

And the north curtain drain is termed a foundation drain.

It has corrugated --

perforated pipe with crushed stone around it.

It's laid at the very bottom of the foundation.

It's meant to collect water that comes in from, you know, outside the foundation.

And if water leaks through the foundation, it can also collect that.

And then it basically picks that water up, transports it to the nuclear service building, where it then moves inside, proceeding east.

And then it gets into the containment building at that point by pipe.

Then it goes to a treatment system that is located inside the containment building,

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- REDIRECT ENTERGY) 4100 where that water is treated.

And then from there it goes to discharge in the discharge canal.

JUDGE VILLA:

So it's a French drain, essentially, on the outside?

THE WITNESS:

I wouldn't use the word "French drain," but you could use that.

It's really a foundation drain.

It's built a little differently, but effectively does the same thing.

It collects all the water around here at that elevation or above, and then it directs it towards treatment and then discharges as a monitored discharge.

JUDGE VILLA:

Thanks.

MR. SANZA:

Your Honor, could we be furnished with a copy of that?

JUDGE VILLA:

I'm going to make color copies for everybody and send them out.

MR. SANZA:

Thank you.

Q.

So is it safe to say that the water that's collected in the north curtain drain and then sent to processing, that's not water that's discharged to groundwater?

A.

No.

That water is taken from groundwater

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- REDIRECT ENTERGY) 4101 and discharged through process to the discharge canal.

Q.

A couple of the exhibits that you were shown earlier, including the exhibit referencing the levels of tritium found in Storm Drain A 2 from wash-out, referred to elevated levels of tritium.

When you see reference to an elevated level of tritium, either in your report or in an Entergy document, what does that term "elevated levels" mean to you?

A.

"Elevated" primarily means levels that are bigger than we expect, and typically that would then be bigger than trigger levels that we've set based on past experience with the site.

So that we look at those trigger levels -- we have a very good understanding of the site, and when we see a level above those trigger levels set based on that understanding, then it causes us to take a look and see why that is, quote-unquote, "elevated."

Q.

And there was a lot of discussion about those elevated levels of tritium in storm drains.

Now, do the storm drains release to groundwater?

A.

Generally no, the storm drains release to

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- REDIRECT ENTERGY) 4102 the discharge canal in general.

Q.

And those are monitored releases?

A.

And those are monitored releases.

Q.

You were asked some questions at the beginning of your testimony about some of the quality control on the radionuclide testing.

A.

Yes.

Q.

Do you recall that?

A.

Yes, I do.

Q.

Are there any processes in place that give you -- other than the QA/QC that GZA does that you described earlier, that give you confidence in the accuracy of the testing results?

A.

Absolutely.

The most important one is that there are split samples taken by both the New York DEC and the NRC, and those samples are tested in different labs, and then we compare the results of the lab that we use versus the lab that DEC uses versus the lab that NRC uses, and we find that those levels all match.

And that gives us an extremely high degree of confidence that the levels are correct.

Q.

Now, you were asked some questions about

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (MATTHEW BARVENIK -- RECROSS RIVERKEEPER) 4106 Q.

You indicate in addition the water that's collected in the north curtain drain is sent for treatment, or goes to be treated?

A.

Yes, it does.

Q.

So does that mean that strontium is removed from it?

A.

It removes some of the strontium, yeah.

Q.

But not all of the strontium?

A.

No treatment technologies typically remove all of the material that you're trying to take out.

There are various levels of efficiency that you can achieve.

Q.

And does the water that's collected in the north curtain drain contain tritium?

A.

It has some tritium -- not very much, but it has some.

Q.

And is it your understanding that tritium can't be removed from water?

A.

It's not typically removed.

It's very difficult.

Q.

And you indicated that after treatment, the water is then discharged to the discharge canal?

A.

As a monitored discharge, yes.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 PROCEEDINGS 4107 Q.

So the radionuclides that collected and were not able to be removed through treatment go to the discharge canal and then to the Hudson River?

A.

Yes.

Q.

Thank you.

Nothing further.

Thank you.

JUDGE VILLA:

Anything else for this witness?

Judge O'Connell, anything?

JUDGE O'CONNELL:

No, thank you.

JUDGE VILLA:

Thank you very much, sir.

You're excused.

We need to take up a couple of exhibits.

And also, Mr. Little kindly pointed out there's an issue --

Sir, you better stay there, because you may have to make a correction in your testimony.

Looking at Page 17 of the direct, there's a reference to Exhibit 46 that's on Line 22.

Mr. Little pointed out that either the date is wrong or the correct reference would be to Exhibit 8.

Exhibit 46 is a document that's dated May 9th of 2008.

I don't know if you need a minute, Mr. Trach, to take a look.

MR. TRACH:

No, Your Honor.

We put in