ML20206J454

Testimony of RM Bimber Requesting Rescission of Onsite Waste Disposal Permit &/Or Advance Approval of Release of Dumpsite for Unrestricted Use at Time of Decommissioning

ML20206J454
Person / Time
Site:	Davis Besse
Issue date:	06/14/1986
From:	Bimber R AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20206J459	List: ML20206J454 ML20206J489
References
CON-#286-713 86-525-01-ML, 86-525-1-ML, ML, TAC-60875, NUDOCS 8606270174
Download: ML20206J454 (6)

Text

-

P s

\ '

T Testimony of R. M. Bimber, Chemist, '

June't3,1 6 prepared for the 4[

Davis-Besse Onsite Radwaste Disposal Hearing, U. S. Nuclear Regulatory Commission Docket No. 5 -346g'y., -3 Atomic Safety Licensing Board Panel No. 86-525-01-ML [

Y .3 ' mi Q ) ~

lDhs Testimony of R. M. Bimber: '

s '#'2.2hC%g((s b/ x 7 My timely, written rejected.

request to I thank the other participate in intervenors thi for giving "Eff" mw as this chance to testify. I will respond to most of the twenty concerns in Judge Hoyt's Order of May 29th, but first I should tell you who I am, and why I'm here.

I am an MS research chemist with more than thirty-five years es:p er i en c e in the chemical industry, including work with ion exchange resins, and with radiolsotope labelled pesticides, and t5eir migration with groundwater. As a part time volunteer working with Lake County government since 1973, and briefly as a paid consultant to PRC Voorhees, I helped write the Lake County Radiation Emergency Plan for response to accidents at the Perry Nuclear Power Plant. I have also been trained as Radiological Officer to aid the County Health District in such response.

I built my own home at 10471 Frouty Road, Painesville, Ohio 44077, in 1953. Now it is within the ten mile evacuation zone of the Perry Nuclear Power Plant, which is operated by the Cleveland Electric Illuminating Company. CEI was the majority owner and co-licensee of Davis-Besse, even before it joined Toledo Edison to form Centerior. Any onsite waste disposal allowed at Davis-Besse seems likely at Perry.

I, or a member of my family, may die from radioactive pollution from Davis-Besse, or Perry, because our household water comes through the Painesville City system from Lake Erie. This water is also used on our large vegetable garden. In addition, we eat fish at least once a week, and many of them come from Lake Erie.

Approval of this radwaste site would increase radioactive contamination of our food.

Approval of Toledo Edison's dump may have its maximum impact in she first decade after it is scheduled to be released for unrestricted use, perhaps thirty to fifty years from now. I do not want anyone injured or killed by radioactivity, fire, or toxic ha:ards from Davis-Besse's radioactive resins. Generations yet unborn cannot possibly speak here today. We want to pass on a more liveable world to them.

We ask Judge Hoyt to rescind the onsite waste disposal permit, and/or the advance approval of release of the dumpsite for unrestricted use at the time of decommissioning.

8606270174 860614 6 PDR ADOCK 05000 T

e A

i s

Judge Hoyt's twenty concerns and our responses follow:

1. What final location on the Davis-Besse site has been selected for waste burial' We wish to introduce the Final Environmental Statement related to the Construction of Davis-Besse (USAEC, 1973) into the Hearing File. On pages 3-24 and 3-26, Section,3.4.3 says all solid radioactive wastes will be packaged and shipped offsite for burial. Doesn't this represent a pledge by the licensees and the NRC that solid radioactive wastes will be handled that way?

It seems clear to us that no onsite burial should be permitted.

Davis-Besse is already allowed to dump 3000 times as much, ie, 5 Curies / year, of radioisotopes similar to those in the resins we are concerned with, directly into Lake Erie (FES-construction, page 3-21). Now it wt9ts to change the conditions of its construction permit, so it can dump solid radioactive waste near the Plant, and contaminate Lake Erie even more.

The Licensees may say the 8.5 millicuries in a five year accumulation of this waste is only 8.5 thousandths of a Curie.

But a Curie is an enormous, irrational unit; 37 billion nuclear disintegrations per second! The new SI system of measurement favors a more rational unit, the Becquerel, which is one disintegration per second. The 8.5 mil 11 curies estimated to be in each 5th year dredging is equal to 315 million Becquerels, which is 315 million ioni:ing radiations, or 315 million potentially cancer-causing bullets, per second. It would take 19 million machine guns firing 1000 rounds a minute to shoot as fast!

8.5 mil 11 curies does present a serious health ha:ard, for a long time.

The FES-construction says any accident with low-level drummed waste would not be expected to result in significant exposure of personnel (page 7-9, Section 7.2.3). Now Toledo Edison appears to be contradicting itself by requesting permission to avoid drumming the waste, and to dump it onsite to minimi:e exposures to their personnel. This seems to be an admission that 8.5 mil 11 curies can hurt people! The request should not be granted.

Nuclear workers are expected to tolerate more exposure than other people. Besides, they should be better informed and equipped to minimize both the intensity and duration of their exposures.

2.-9. represent information the licensees should have been required to provide before the NRC acted on their request. I'll comment on the 5th, then skip to the 10th.

1

5. What soil erosion from storms has been actually observed at or near the site?

We believe the words "from storms" unduly limit this question, and respectfully request that Judge Hoyt consider deleting them.

Gradual erosion from wind, water, frost heaving, or whatever,

Y 3

\

should be cause for concern. Also, erosion history may not reveal the future because ion exchange resins are generally smooth round particles, less dense than soil, and subject to frost heaving if not buried below the frostline depth. They are more easily eroded than normal soil.

10. L 11. appear to be asking for an estimate of the most probable values, corresponding to the maximum values sought in similar questions 13 & 14. We believe only the maximums have i regulatory significance, so have combined our responses.

12. What criteria will be used to decide whether resins will be buried on site or transported to a licensed burial site in the event that resins become contaminated at higher than expected levels?

We congratulate the Judge f or recognizing that a license without limits is a farce! There must be some contamination level, above which the resins must be packaged and stored for offsite disposal.

No such limit has been set. But, "D,ilution is not the solution to pollution," even though Davis-Besse has taken this approach in the settling basins. Ferhaps 8.5 millicuries and 34000 cubic feet should be applied as individual limits, to minimize the volume of waste. That is, there should be three limits: a maximum amount of i radioactivity to be contained in a given volume, total activity,

) and total volume.

13. What is the upper limit of radionuclide inventory which could exist on site after 30 years under the above criteria?

Since the Permit has already been granted, the NRC should be telling the Polluter, not asking! Based on the Federal Register of Oct. 9, 1985, a limit of 8.5 millicuries should be stated in the Permit. The actual inventory may exceed any limit in the permit because of undetected excursions, errors in sampling or measurement, or judgement, plus equipment failures, etc. And employees may deliberately exceed limits to benefit their employer because it is what their boss wants, or seems to want. (Remember the example of overpriced aircraft turbine blades at TRW?) No more than a specified amount of error, perhaps 25%, should be tolerated. Limits were imposed on both the volume and the activity of sandblasting wastes to be buried at the Qconee Nuclear Plant, as described in the Oct. 23, 1985 Federal Register, 50 FR 43043-5. Limits are needed here.

. It is hard to estimate the volume, and to determine the radioactivity of a sludge which is not uniform over the bottom of a settling basin. Also, the first accumulation of resins may not be typical. The plant has operated sporadically, far below design, so resins have accumulated slowly, giving more time for i radioactive decay and leaching from the settling basins. More l stress corrosion is likely as the reactor ages under neutron I bombardment. Judge Hoyt might ask whether the Licensee accepts the volume and activity in the Oct. 9, 1985 Federal Register as j

, 1 l

Y o

limits on its Permit (50 Fr 41265-7). If not, any higher limits they agree to should be used to estimate radiation exposures, and to reconsicer the Permit.

14 What is the estimated upper limit of dose to the whole body for an individual standing on the burial site that could exist after 70 years under the above criteria?.

Perhaps the part of the question after the word " individual" should be replaced by, "from the dumo after it is released for other use?". The number c4 periodic burials envisioned is not an exact number, nor is the time of closure. If the dump were to be promptly released for unrestricted use, it might be excavated, regraded, or disturbed in other ways which could effect exposures.

It seems necessary to assume no excavation of the site to estimate the dose limit. Deed restrictions to prevent this do not

, appear to have been considered. Nor does deeper earth cover over l the last burial; it might reduce the uoper limit of dose, and reduce the time interval required before other use, considerably.

If the land may be released, for unrestricted use, it becomes necessary to consider the possibility of people sleeping on the ground, perhaps even digging a " foxhole" for warmth in cold weather. The duration of such exposures might amount to half-time for three months per year for Scoutleaders, for example.

The largest exposures might occur to people living in a home built in the most recent waste, with regrading to unknowingly maximice the radiation exposure. These poor souls might also drink and bathe in well water from a shallow well, and eat home-grown produce and fish caught nearby. In this case, It might be necessary to consider the radioactivity in the total thickness of the waste, not just the top 10 centimeters, and full time, 8766 hour0.101 days <br />2.435 hours <br />0.0145 weeks <br />0.00334 months <br /> per year exposares, not just the 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year considered by the Licensee (Table 1 of 50 FR 41266, Oct. 9, 1985).

f The estimate in the Federal Register Notice was a gross I underestimate, for many reasons, which I will explain The radioactivity in more than a 10 centimeter (4") thickness of waste should be used in estimating the dose, for several reasons:

I a) All the isotopes in Table I of the Federal Register notice emit highly penetrating gamma radiation.

b) Ion exchange and groundwater movement may concentrate radioisotopes on the surface.*

c) The maximum thickness of the batches of wastes does not appear to be on record. When asked for this data, Richard Crouse, Vice President, Nuclear, of Toledo Edison, gave the minimum thickness as 2 to 5 feet, and said any thickness over one foot would not increase exposures (letter Serial No. 1065, dated July 30, 1994, at Attachment 1, page 3, fourth paragraph, line 4). That is not true, because gamma radiation is very penetrating, and because of migration of radioisotopes

, dI

!A  !

i to the surface, which will be explained shortly.

d) There does not appear to be anything to prevent the

! wastes being buried in a deep hole, and subsequent 1 burials placed on top of each preceding one, --like a stack of pancakes. Could there be any other reason for so thin a covering over each burial' I

* "b" may require explanation

The June 1986 National Geographic,

. pages 818-822 and 833, tells of using potassium fortalizers or  !

seawater to displace radioactive cesium from Bikini Atoll.

! Similarly, fertili:er used to establish turf or minerals in

{ groundwater movirg through the Davis-Besse Dump can displace '

! cesium. During dry periods, water can be drawn from great i depths, evaporated, and the -assorted radioisotopes- left behind as dust. The process is known as efflorescence. It can apply  ;

i to all the radioisotopes on the resin. The most familiar example i j may be deposits on masonry. It has been known to move water soluble degradation products of pesticides from depths below

]

, four feet to the surface, and leave normally crystalline

] materials as fine dust. At the Davis-Besse Dump, this could j s greatly increase the radiation ha:ard, and also present a j lung hazard, both of which seem to have been overlooked.)

}

j Since the nuclear industry likes to make any errors in the j direction of increased safety, we should assume all the activity l in a five foot (possible minimum) or greater thickness of waste is I concentrated at the surface, as loose dust which might be inhaled 1 l by children playing in the dirt on this (soon to be) unrestricted I area.

If the site is ever to be released for unrestricted use, exposures

]

of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> / year are ridiculous! . Full time is 8766 hours0.101 days <br />2.435 hours <br />0.0145 weeks <br />0.00334 months <br /> / year. ,

i It may be of some interest that the USEPA has assumed authorities l will maintain active institutional control of even low-level

radioactive waste disposal sites for 100 years after their

closurep see 48 FR 39563, August 31, 1983. Unless there are deed  ;

} restrictions on the site, --- for example, to prevent subdi vi si on ,

j excavation, or residential use, full time radiation exposures of l 8766 hr/yr should be assumed.

I The Licensee's estimate of 8.5 mil 11 curies, and the resulting i exposures may be low, but merely correcting two of their I

] assumptions shows the exposures would be unacceptable. Their {

estimated annual dose of 0.7 millirem should be multiplied by

] 15.2 to allow for the greater thickness of waste (5 feet in 152 j cm, not 10 cm), and by 87.66 to allow for full time exposure,

instead of Just 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year. This corrects the estimated i

exposures to 933 millirems / year. The Licensees claimed to have met l an acceptance criteria of 1 mr/yr. They cannot even meet the 25 i mr/yr limit for the entire radioactive waste management industry

{ (Federal Register for 9/19/85, which cites 40 CFR 191.03). Any thought of unrestricted use of the Dump, without a preliminary l radiation survey, should be squelched!

l i

6

\

15.-19. These are good Questions, which the Licensee should have been asked before the permit was granted. We suggest the following related questions which Judge Hoyt may want to asks a) Does the supposedly nonradioactive, major portion of the waste going into the settling basins contein small enough amounts of toxic heavy metals to pass the USEFA "EP Toxicity Test" (46 FR 35247, July 7, 1981)? (The licensees could be evading USEPA requirements by mixing it with a waste regulated by another agency.)

b) Are the resins, or other components of the total waste, flammable? (The resins are usually modified polystyrenes, and may present a serious, unrealized fire hazard if not mixed with incombustible meterial.)

20. Describe the Licensees plans for site management during operation, for marking the burial site, and for recordkeeping at the burial site.

We believe it is desiratie to impose deed restrictions on the dump site. We suggest it should not be subdivided, excavated, or used for residential purposes unless it is first surveyed for residual radiation and cleared by the appropriate health authorities. Such a survey might confirm the expected leaching away from the site.

It might also reveal problems in the form of unexpected kinds or j enounts of radicitatopes; NRC is considering adding 500 more radioisotopes to thase it already regulates (51 FR 1119, January 9, 1986).

We remind the Judge that the FES-Construction says the applicant will have to comrly with whatever regulations are in effect at the time of decommiz zioning (page 8-10, Section 8.3.1). The NRC was in error when it granted permission for release of the dump site for unrestricted future use (50 FR 41267, column 1, paragraph (1)).

We do not believe the Licensees requested such permission, or would have exLected to receive it, if they had.

The NRC recently renewed its request for the USEPA to take the lead in the area of developing guidelines for unrestricted release and possitie use of lands, facilities, equipment and materials having residual contamination (NRC News Release 86-27, dated March 14, 1986). EFA is preparing to assume jurisdiction; see l 51FR1455E, item 2690 (April 21, 1986).

% L A w l. A h Russell M. Bimber f3 e

& y[* 77'/' DwMg y

I ces Charles Barth, Esquire .

Docketing & Service Branch Jay E. Silberg, PC q /[Yb State of Ohio .

Toledo Coalition Western Reserve Alliance

._- - _ . - - -.