ML20091Q569
ML20091Q569 | |
Person / Time | |
---|---|
Site: | Limerick ![]() |
Issue date: | 06/12/1984 |
From: | Bartram B, Daebeler G, Guarino C, Kaiser G, Levine S, Schmidt E, Toblin A, Waller R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
To: | |
Shared Package | |
ML20091Q564 | List: |
References | |
NUDOCS 8406140098 | |
Download: ML20091Q569 (47) | |
Text
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UNITED STATES OF AMERIC.**
DOC KETEn NUCLEAR REGULATORY COMISSION Before the Atomic Safety and Licensing BMd JUN 13 Pl2:02 In the Matter of ) 0FFKE O! $Etst.1 00Ciu.IiNG & SEWu Philadelphia Electric Company (Limerick Generating Station,
) DocketNos.50-3b (,[/2h
) 50-353 Units 1 and 2)
TESTIMONY OF B.W. BARTRI.M, G.F. DAEBELER, C.F. GUARINO, G.D. KAISER S. LEVINE, E.R. SCHMIDT, A.L. TOBLIN, R. WALLER RELATING TO CONTENTION CITY-15 Contention City 15, as admitted by the Atomic Safety and Licensing Board, reads as follows:
The DES does not adequately analyze the Contamination
that could occur to nearby liquid pathways, and the City's water supplies sourced therefrom, as a result of precipitation after a release. A reasoned decision as to environmental impacts cannot be made without a site specific analysis of such a scenario.
The DES addresses at great length releases to ground-water (DES at 5-34 el m .), but gives only a cursory and conclustery discussion of contamination of open water (DES at 5-33). This issue is of crucial-concern here as the two major water bodies at and near the facility are the City's only water supplies. The City also has open reservoirs within its boundaries which could be contaminated through precipitation. For an issue of such great importance, insufficient I consideration has been given here. The mandate of NEPA to take a hard look at environmental consequences has been ignored.
INTRODUCTION AND
SUMMARY
B.W. Bartram 1. The purpose of this testimony is to estimate the public G.P. Daebeler risk associated with the contamination of the City of a
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G.D. Kaiser ' Philadelphia's (" City") drinking water af ter a severe acci-
- 8. Levine . dent at the Limerick Generating Station. A probabilistic E.R. Schmidt treatment of the levels of contamination of the drinking 1-A.L. Toblih water is also provided.
I
~
a.W. Bertram 2. =This testimony considers the deposition of airborne radio-
- G.F. Daebeler 4 - nuclides onto the Schuylkill and Delaware watersheds and G.D. Kaiser - predicts Complementary Cumulative Distribution Functions S. Levine (CCDFs) of the concentration of.those radionuclides that >
E.R. Schmidt are the most important contributors to the longer term
-A.L. Toblin contamination of water supplies, strontium and cesium.
This is accomplished using a computer model that was '-
originally developed for use at Indian. Point (Ref. l_,
. Appl. Exh. 153; Ref 2, Appl. Exh. 154). This testimony considers dry deposition as well as the " rainout" scenario postulated by the contention. CCDFs of the con-centration of strontium and cesium are~ calculated for drinking water supplies taken'from the Delaware'and Schuylkill Rivers.- The probability that these rivers g
will be contaminated above the Pennsylvania Emergency
(-
Management Agency's (PBIA) Protective Action Guides (PAGs) is shown to be very small. The probability of j- contamination of the drinking water supplies as a result of direct deposition onto the raw water basins or other e open reservoir at the City's water treatment facilities is also discussed.. It is shown that the contamination of drinking water after reactor accidents as a result of f
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6
. atmospherically deposited radionuclides or as a result of
-direct deposition onto the raw water basins or other open reservoirs is a small contributor to risk compared with
-l 1 the risk arising from the airborne pathways and therefore may be properly neglected in terms of overall risk 1-considerations.
l' .
B.W; Bertram 3.- This testimony also contains in the context of an envi-
.G.F. Daebeler ronmental impact evaluation some general discussion of
-C.F.=Guarino- countermeasures that could'be considered in both the G.D'. Raiser short and long term in the extremely unlikely event'that water j.
S. Levine in the rivers or raw, in-process, or finished water E.R. Schmidt- were to be contaminated above PEMA's PAGs. It should be Toblin
~
, A .L. clear, however,.that the Applicant believes that its R.~ Waller- evaluation demonstrates that the probability and risk associated with this pathway is so small~that specific planning considerations are not required; in any event this testimony does not purport to consider the emergency planning requirements of 10 CFR part 50 Appendix E, or NUREG-0654.
DESCRIPTION OF MODEL
_B.W. Bartram .4. The model used in the preparation of this testimony has G.F. Daebeler- the following parts; (1) calculation of the amount of G.D. Raiser radioactive material deposited in each watershed (i.e.,
3
S. Levine- Schuylkill'and Delaware) for each combination of fission E.R. Schmidt product source term, weather sequence and wind direction, A.L. Toblip using CRAC2; (2) calculation of the consequent time de-I
- pendent concentrations of cadioactive strontium and cesium in the City drinking water supplies; (3) relating the drinking water concentrations to population doser (4) repetition of the calculations for different wind direc-tions, weather sequences and fission product source terms in order to compile CCDFs of radionuclide concentrations in water and CCDFs of population dose. The analysis focuses on strontium and cesium because, by virtue of .
their potentially large release quantities, relatively long radiological half lives, and recognized radio-toxicity, they dominate the long term contamination of ingestion pathways (Ref. 2, Appl. Exh. 154; Ref. 3, Appl.
Exh. 155) . WASH-1400 also considered strontium and cesium as the principal contributors to long-term doses received via the ingestion pathways (see WASH-1400 Appendix VI,
- p. 8-22, Ref. 4_, Appl. ' Exh. 156) .- However, when consider-ing population doses arising from the drinking of con-taminated water in the short term (e.g. , one month) , con-133 sideration is given to other radionuclides, such as 7 131
- and I as discussed in paragraph 18 below.
G.D. Kaiser 5. The amount of radioactive material initially deposited S. Levine on the two watersheds is calculated by the CRAC2 E.R. Schmidt code, using the methods and assumptions described in j Chapter 10 and Appendix F of the Severe Accident Risk 4
r
Assessment-(SARA) to calculate the point estimate CCDFs.
1 For each weather sequence and source term, CRAC2 cal- >!
. I culates tho' activity of each radionuclide deposited on ll.. .
i
, the ground in Curles per square meter, as a function of distance from.the reactor. This information, together with information on the plume width as a function of dis-tance downwind, is used by the LIQPATH code.
~
l G.D.: Kaiser 6. The LIQPATH code is a modification by NUS of the code I'
.E.R. Schmidt; IPRES that was used at the Indian Point Hearings (Ref. 1, A.L.'.Toblin Appl. Exh.153; Ref. 2, Appl. Exh.154) . LIQPATH takes the ,
~
deposited levels of radioactivity provided by CRAC2 and calculates the total amount of strontium and cesium that'
~ is 6eposited in the Schuylkill or Delaware watershed.
This'is done in the code by essentially overlaying the plume footprint on a map of the watershed and integrating the deposited activity over that part of the plume that lies within the watershed. It should be noted that the
. deposition'in the watershed also includes that directly deposited in the river.
B.W. Bartram ~7. Once the total amount of each radionuclide that has been G.D. Kaiser deposited within each watershed has been calculated,-the E.R. Schmidt LIQPATH code predicts the subsequent temporal' variation j' A.L. Toblin of the concentration of each radionuclide in the City of Philadelphia drinking water. Physical phenomena which L-l' 5.
s
- o
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-influence these concentrations include radioactive decay,
~
. run-off, erosion, ground water transport, sediment scaveng-ing enroute and possible removal of radionuclides by the water treatment system itself and are empirically treated I
as discussed below.
B.W. Bartram 8. The' LIQPATH code contains an empirical correlation that G.D. Kaiser. relates the quantity of a radionuclide deposited in the A.L. Toblin watershed to the subsequent concentration in City drinking water. This correlation, which is described in detail in
, Appendix 1, is based on the analysis by Codell (Ref. 2, Appl. Exh.154), which correlated the measured rate of --
fallout of 90Sr from atomic bomb tests with meacured concentrations of 90Sr in New York City tapwater over a period of about twenty years. This correlation is shown
. in Figure 1, which is reproduced from Codell's work.
Within LIQPATH, this correlation is described by an empirical expression that contains a number of parameters (see pp 12 and 19 of Ref. 2, Appl. Exh. 154) that are determined by fitting the data as described in Appendix 1.
B.W. Bartram
- 9. A correlation similar to that given for New York City G.D. Kaiser drinking water is applicable to any watershed and A.L. Toblin any radionuclide, although the numerical values of the
- parameters may change. The appropriate parameters for a l
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given watershed can be calculated given a data base consisting of the salient variables (in this case deposition rate and drinking water concentrations) . The parameters I in' the correlation can then be adjusted so that a best i
fit of the data base is obtained. This parametric adjustment has been made in the calculations described herein.
B.W. Bartram 10. With-regard to data on which to base the correlation G.D. Kaiser- parameters, e long term, continuous monthly record A.L. Toblin of fallout rate is available as a function of latitude
~
(Refs. 5, 6 and 2, Appl. Exh. 157,158 and 159) and has been used in~the calculations described in this testimony.
By far the best available data on tapwater concentrations is that for New York City, for which there is.a nearly con-tinuous, monthly data base of 90Sr from 1954 through late
- 1981, and a seventeen-year data base of 137C s (Ref. 8, Appl. Exh. 160) . This New York City tapwater concentra-
-tion data base is unique. For the Schuylkill and
' Delaware Rivers, limited data are available from a number of sources.' The Department of Health, Education, and Welfare (NEN: Ref. 9, Appl. Exh.161) measured quarterly 90S r concentrations in the Delaware and Schuylkill Rivers at Philadelphia (and other rivers such as the Susque-hanna) sporadically .from the third quarter ,of 1959 through the third quarter of 1967. The Philadelphia I
7 I
.-- - - - . - . .~
Electric' Company (PBCo; Ref. H , Appl. Exh. 162) took-90 Sr measurements in the Schuylkill River in the vicinity of Limerick between June 1971 and October 1977. The
',_ Environmental Protection Agency (EPAr Ref.11, Appl. Exh.163). has taken infrequent 90Sr measurements in-the Delaware River at Trenton, New Jersey (as well as t-other rivers such as the Susquehanna) since 1976. A sin-
[ gle 90Sr measurement on May 8, 1979 was' taken'for the City of Philadelphia Water Department from finished water at each of its three major plants as well as from one distribution point. The results of this single measure-ment appear to be high when compared with the concurrent --
EPA readings and internally inconsistent (the concentra-tion at the distribution point is greater than at any of the plants).
B.W. Bartram 11. _ Figure 2 shows the comparability of the concentrations in G.D. Kaiser the Schuylkill, Delaware, and New York City tapwater.
A.L. Toblin The Susquehanna River data indicate similar comparability.
This is expected for the following reasons; o The deposition (fallout) rate is latitude dependent (Ref. 7, Appl. Exh.159); these watersheds are at
.similar latitudes (i.e., the quantities of 90Sr and 137C s falling on each watershed per unit area are approximately equal) .
i e
L _
, l
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s o The watershed dynamics (e.g., removal rates) in i
response to deposition is expected to be similar for these northeast United States sites, which have similar values for rainfall, run-off and sediment 1-yield (i.e., the' fractions of the total 90Sr removed over a given time are equal, Ref. ,1_2_, Appl. Exh.164) .
t-H o The flow rates per unit watershed area are approximately equal for these systems, (Ref.13, Appl. Exh.165) .
-B.W. Bartram 12. In order to extend the limited Schuylkill and Delaware ,
G.D.' Kaiser River radionuclide water concentration data bases (to '-
A.L. Tcblin obtain a long continuous record which can be used to find the appropriate . coefficients of the equations in Appen-dix 1), the 1959 through 1967 HEN data for each river were correlated with the New York City tapwater concen- ,
trations. Since the range of HEN concentrations is much k f, larger that that of the other measurement programs,- -
.the HEN correlations ~were applied to the 28 years
)(5 of New York City data-to simulate a 28-year monthly C\c data base for each of the Delaware and Schuylkill Rivers
,i at Philadelphia. This data base was then used to find '1 the appropriate parameters in the expression relating ,
initial deposition to concentrations in each of the Philadelphia rivers. Details are given in Appendix 1.
L'
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9
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- 13. It is important to note.that the New York City tapwater
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G.D. Kair,er data have been correlated with the Schuylkill and
-A.L. Toblin Delaware river water data. This approach can be used ;
i
'I~ becauae'the New York City water has minimal treatment.
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There may be a furt.her reduction in the predicted Dela- !
)' %[.4,- tare and Schuylkill drinking water concentrations to
- c . . ,
allow for some removal of strontium and cesium by the
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D, ,
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Philadelphia water treatment system (Ref. _1_4, Appl.
'~* Exh. 166). However, it is not expected that the system as
- presently operated will significantly reduce strontium r: (Ir 1, ( '}
and cesium concentrations between the river and the e drinking water and no credit has been taken for such s ,
'i- removal.
B.W.~Bartram 14. As noted in paragraph 7, the expression relating the
,. U 1 .
, G. D. Kais;. amount of each radiotiuclide,dpposited in the watershed 4 ' 's _ Y,,
'I A.In Toblin to the subsequent tararster concentrations encapsulates s% .
.q)3theimportantphysicalprocessesthatoccurastheradio-g), f(t ; \
% t
$f ,
,j ,nuclide is transported from the watershed to the tap-l'ip'- ,
( tiater. Other calculations carried out by the LIQPATH
,P J ' code are straightforward. These include taking the input data file from CRAC2 anPcalculating the total amount of
'(
each radionuclide deposited in the watershed for each combination of source term and weather sequence, as
,' described in paragraph 6.,'The calculation of drinking
- j[ '{lI water concentrati ns<Im repeated,for each combination of s
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weather sequence, wind direction and source term. The output of these calculations is the CCDF of concentra-tions in tapwater, as described below.
l I
PUBLIC RISK - WHOLE BODY DOSE B.W. Bartram 15. The consumption of drinking water containing radio-G.D. Kaiser nuclides from a postulated accidental airborne telease S.- Levine' from LGS would result in radiological doses to the E.R. Schmidt population of Philadelphia. The method used to calculate A.L. Toblin these doses from the calculated concentrations in river water and the calculated concentrations arising from .
direct deposition onto raw water basins or other open water bodies at the City's water treatment works is described below. Doses resulting from water used outside the body make a very small contribution to total exposure and thus are no* considered further here.
'16.-
~
B.W. Bartram First, the formelas given in A;pendix 1 for the time G.D. Kaiser dependent concentrations of strontium and cesium in the A.L. Toblin- river water were used; the nuclides Cs, Cs, ' Sr and 'Sr were included. The population was assumed to consume this water for fifty years and the resulting pop-ulation doses calculated in accordance with the methods
! outlined in NRC Regulatory Guide 1.109 as implemented in t
l' 11
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the LADTAP II computer code (Ref, M, Appl. Exh.167; Ref. M , Appl. Exh. 168) . An exception to the methods of Regulatory Guide-1.109 was the use of ingestion dose con- '
version faci.crs as given in WASH 1400 (Ref. 4, Appl.
t Exh. 156, p. 8-24) so as to be consistent with the analy-sis of ingestion pathways given in SARA. The Regulatory Guide 1.109 conversion factors are based on recommenda-tions of the International Commission on Radiological i
Protection, Publication 2,1957 (ICRP 2), whereas the f WASH-1400 conversion factors are much closer to the more
- recent recommendations of ICRP 30.
B.W. Bartram 17. _ The LADTAP II methodology was applied separately to the G.F. Daebeler Delaware and Schuylkill rivers and to each ff.ssion pro-C.F. Guarino duct source term, since the proportions of strontium and G.D. Raiser cesium differ between the two rivers and between differ-S. Levine ont source terms. It is likely that the Schuylkill would E.R. Schmidt be more heavily contaminated than the Delaware (see para-A.L. Toblin graph 21). According to the City, in an emergency, the
'R. Waller Baxter plant, which takes water from the Delaware, can supply the City's entire needs with the exception of the g Belmont High Service District and the Roxborough High Service District, which represents about 21 mgd out of the City's total needs of 324 mgd; or about 7 percent.
(Ref. E , Appl. Exh. 169, and Ref. M , Appl. Exh. 170).
Therefore,.it was assumed that 7 percent of the City's population would be supplied by the Schuylkill and 93 percent by the Delaware.
12
B.W. Bartram 18. With the assumptions given in paragraphs 16 and 17, it is
)
i G.D. Kaiser straightforward to calculate a CCDF of population dose '
A.L. Toblin starting from the initial probabilistic treatment of con- 1 l
, centrations of radionuclides in the river water. Since the calculations were done on the basis of strontium and cesium, this CCDF represents the chronic or long term contribution to the population dose, with regard to the contribution of other more short-lived radionuclides, such as radiciodine, a simplified calculation was made as follows. For each source term, weather sequence and winds direction, the isotopes of iodine deposited on the .
Schuylkill or Delaware watersheds ws.'e assumed to pass into the rivers immediately at a rate approximately fifty times that of Strontium. This factor of fifty is a bounding factor, as approximately 2 percent of the Strontium is expected to pass directly into the river (Ref. 12; Appl. Exh. 164) . The population of Philadelphia was assumed to consume this water and the resulting increment in population dose was calculated using the methods of LADTAP II. In this way, the CCDF calculated for strontium and cesium was modified to include iodine.
B.W. Bartram 19. A further potential source of radiation dose would be the G.F. Daeheler consumption of water from the City's treatment works that C.F. Guarino might be contaminated by direct deposition (dry or wet) 13
G.D. Kaiser on raw water or finished water basins. In practice, much S. Levine: or all of this contaminated water could be bypassed, dis-E.R. Schmidt charged to the river or sewers, or flushed through fire I
A.L. Toblia hydrants (see paragraph 30) . For the purposes of-this R. Waller calculation, however, it is assumed that all of the con-taminated water is processed through the City's distribu-tion system at the usual rate of consumption. Again, the LA."., RAP II methodology was used to calculate population doses arising from the consumption of this water. When combined with the probabilistic distribution of concen-trations in water calculated by LIQPATH, a CCDF of ,
population dose results, which was combined with the CCDF ~
described in paragraph 18 to give an overall CCDF of population dose to the people of Philadelphia. This CCDF is shown in Figure 3.
B.W. Bartram 20. The area under this CCDF is 0.65 man-rem per reactor year, G.F. Daebeler which is made up of 0.02 man-rem per reactor year from C.F. Guarino the consumption of water contaminated by direct deposition
~G.D. Kaiser into the system, - 0.16 man-rem per reactor year from E.R. Schmidt strontium and cesium deposited on the watershed -snd 0.47 A.L. Toblin man-rem per reactor year from the iodine deposited on the R. Waller watershed. This figure of 0.65 man-rem per reactor year is l to be compared with 70 man-res per reactor year to the people of Philadelphia from the airborne pathway as considered in SARA. Note that the population dose via the water
(
14 l
I-l
i i
1 pathway has been derived with many fewer assumptions i i
about countermeasures than that via the atmospheric path-ways in CRAC2, protective actions such as interdiction of
.g.
milk and decontamination of land are routinely assumed.
As described below, countermeasures are possible in the liquid pathway case which could give further reduction in risk. Overall, it is concluded that the public risk via
~
the water pathway is a small fraction of that via the atmospheric pathway. This conclusion is in agreement with that of other authors (Ref. 3, Appl. Exh.155i .
CONCENTRATIONS IN TAPWATER - RESULTS B.W. Bartram 21. Fiqure 4 displays the complementary cumulative distribu-G.D. Kaiser tion function (CCDP) of the concentration of Sr in S. Levine drinking water obtained from the Schuylkill, averaged over E.R. Schmidt the first month and averaged over the first year, and then A.L. Toblin at 1 month, 6 months, and 5 years after the initial deposition. Figure 5 provides the same information for the Delaware River. These curves give the frequency with which the corresponding concentration is equalled or exceeded. It is. apparent that the concentration of ' Sr during the first month is considerably higher than that at later times (the average over the first month is given, since the parameters in the empirical correlation cannot predict in greater detail than the original data, which is 15
averaged on a monthly basis). After 1 month, the con-centration in the river declines slowly.
,. B.W. Bartram 22. In order to judge the significance of the concentrations l
G.D. Kaiser it is necessary to compare them with Federal or State S. Levine Guidelines. The Federal Government has published E.R. Schmidt standards for normal releases in 10CFR20 Appen-A.L. Toblin dix B and the values for 90Sr, 137Cs, 134Cs, 133I and 131 I I t are reproduced in Table 1. The Commonwealth of Pennsylvania Emergency Management Agency (PEMA) has published Protective Action Guides (PAGs) (Ref. M , Appl. _
Exh. 171)which are also reproduced in Table 1. P11MA's PAGiB*
are based on the USEPA National Interim Drinking Water Regulations, EPA-570/9-76-003, Appendix B; see also 40 CFR 141.16. As can be seen from Table 1, PEMA has two sets of PAGs which are applicable to the situation being considered. For uncontrolled discharges to surface water, and in circumstances where the water supply is influenced by contaminated run-off and fallout, the USEPA Appendix B concentrations multiplied by 12 will apply. This assumes that the exposure time will not exceed one year. The associated dose commitment to any organ is 50 arem.
Second, PEMA states that, for acute crisis conditions where no other water supply is available and the duration-
,: is less than thirty days, the average concentration may t
l reach 1,000 times the USEPA Appendi2: B concentrations.-
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16 j.
The associated dose commitment to any organ is 330 mrem.
For accidents affecting Philadelphia drinking water, the PEMA standards have been assumed to apply.
I I ,
l B.W. Bertram 23. Returning to Figures 4 (Schuylkill) and 5 (Delaware), l
- G. D. - Kaiser since ' Sr is principally considered as c contributor to S. _L. ine the long term accumulation of radiation dose, the most 90 E.R. Schmidt appropriate PEMA guide for comparison with Sr concentra-A.L. Toblin tions is that for. circumstances in which the water supply is influenced by contaminated run-off and fall-out, i.e.
96 pCi/1 averaged over 12 months. The probability that .
the Schuylkill will be contaminated above this guide is I
-one in 300,000 per reactor year, and the probability that .j
~
' the Delaware will be contaminsted above this guide is one in 7 Eillion per reactor year. '
0 B.W. Bartram 24. The above probabilities have been obtained by assuming G.D. Kaiser that-no preventive' actions take place. As discussed in S. Levine paragraph 34 preventative measures which could sub-
. E.R.' Schmidt- stantially reduce the long term impact of ' Sr are i
A.L. Toblin possible. Assuming that such procedures could be implemented in one month, the probability of exceeding the PEMA one year limit in the subsequent year would be in the range of one in 2-1/2 million to one in 17 million l per reactor year for the Schuylkill and about one in a hundred million to less than one in a billion per reactor l:
17 i
I-
year for the Delaware. It should be noted that, as indicated in paragraph 20, even if the countermeasura are not taken, the man-rem contribution is a small fraction of that from other pathways.
B.W. Bartram 25. The discussion given in paragraphs 23 and 24 shows that G.D. Kaiser the probability that there will be long term contamina-S. Levine tioni of the Delaware even in the absence of protective E.R. Schmidt actions.is quite small, and that the probability that A.L. Toblin such contamination could not be dealt with using available techniques is vanishingly small (one in a .
hundred million per reactor year or less). For the Schuylkill, the corresponding probabilities are about a factor of thirty higher, but even so the implementation of reasonable countermeasures reduces the probability of exceeding the PEMA long term guide to one in seventeen l million per reactor year. Thus, there is a very small probability that long term interdiction of the Schuylkill would be required, and a vanishingly small probability that long term interdiction of the Delaware would be required. Note that the calculations show that there is less than one chance in a billion per reactor year that either the Schuylkill or Delaware will be contaminated above PEMA one year PAGs by radiocesium.
18
B.W. Bartram 26. In the short term, the PENA one-month PAG (8000pci/1 of JG.D. Kaiser Sr) applies. For ' Sr alone, the probability of l
S. Levine exceeding this limit is about once chance in 3 million l ;
I E.R. Schmidt per reactor year in the Schuylkill and less than one A.L. Toblin chance in a billion per year for the Delaware. However, the one month average is complicated by the t?.ut that other radionuclides, such as 131 I, cannot be neglected; it is expected that the radioiodines will bs significant (perhaps dominant) contributors to the dose (330 mrem in one month) that is the basis for PEMA's PAG. The calculation of the rate at which iodine, deposited on a watershed, leaches into the river is not as well --
understood as for strontium. Therefore, a detailed quantitative analysis is not possible. However, using 4 the model for ' iodine concentration averaged over the first month, as described in paragraph 18, the iodine would determine if the PEMA short-term PAGs were exceeded. There would be a chance of about one in a hundred thousand per reactor year that the PEMA short-term PAGs might be exceeded in the Schuylkill River, and about one in a hundred and fif ty thousand that they might be l exceeded in the Delaware River. These are upper bound probabilities and, furthermore, take no account of the possibility of countermeasures (see paragraph 30) .
19 w ,w---g e +---rwwee ..,,,.r -- m ---,---e p- , pg e - 4 + y .
--9 ----y---c w
DEPOSITION ON WATER BASINS AND RESERVOIRS 1
B.W. Bartram 27. 'The problem described above is one of long term i
G.F.Daebe[er contamination of the rivers as a result of C.F..Guarino deposition of long lived radionuclides such as G.D. - Kaiser strontium and cesium on the watershr... A short term S. Levine problem may exist if radionuclides are deposited directly
-E.R. .
Schmidt onto the surface of the raw water basins at Baxter, Queen A.L. Toblin Lane and Belmont or the filtered water reservoir at East A. Waller Park. (The Oak Lane and half of the East Park filtered water reser airs are protected by floating covers with provisions to drain rain water to the sewers so that the - -
i filtered water would not be contaminated.) CCDFs of instantaneous ' Sr, Cs and I concentration in these reservoirs are shown in Figures 6 and 7. Note that all
.taee plants and the ' reservoirs are so close together ;
(compared to a typical plume width) that they have essentially the same CCDF'and would be contaminated at the same time.
.. ?B.W. Bartram 28. As noted the concentrations given in Figures 6 and 7 are i
G.D. Daebeler instantaneous values in the raw water in the basins. If
' C.F. 1 Guarino this water were to be processed (without removal of any G.D. Kaiser radioactivity) and distributed at the normal rate the l-l S. Levine contaminated water would be all gone after approximately l'
E.R. Schmidt 3 days. The 30 day average concentration would therefore L -
.t..L. Toblin be one tenth of that given in Figures 6 and 7. The -r l
l -R. Waller likelihood that the PEMA 30 day PAG will be exceeded is l'
i 20 l.
1
- _ _ . _ _ _ . . . _ _ . ~ _ - . _ . . , . . _ . . . - . . - _ _ . _ - _ . . _ _ _ . . _ , , , _ . . _ _ . . . - . _ _ _ _ , _ , _ _ _ . _ . _ . - - . . _ _ . . . - . --
. . 'therefore approximately one chance in a million per 131 reactor year based on I. As described in paragraph 30 countermeasures based on available techniques are pos-l sible in this unlikely event. Again as noted in para-i graph 20 the risk from contaminated water is small compared to that from other pathways.
POSSIBLE COUNTERMEASURES
.B.W. Bartram- 29.. The preceeding testimony shows that the risk resulting
.G.F. Daebeler from the contamination of the City of Philadelphia water C.F. Guarino- supply is a small fraction of the risk frca other .,
G.D. Kaiser. pathways. In making this assessment the only action
~
S. Levine assumed to be -taken was to maximize the use of Delaware E.R. Schmidt River water. No credit was taken for countermeasures to
-A.L. Toblin-Leither prevent the use of contaminated water or to remove R. Waller, activity from the water. The following section discusses, in general,-possibly counter measures in order to place some perspectives on the risks involved. This discussion centers on short and intermediate term measures.
- 30. Countermeasures could be implemented in the unlikely event of an accident resulting in contamination of either-the Schuylkill or Delaware River water sources or
-treatment plants, depending upon the nature and severity of the contamination. For those occurrences which result in the early contamination of a water supply in excess of 21
i e.
the PEMA 30 day PAG, the interdiction of that source would be possible with replacement water provided from g the other sources, albeit with some usage restrictions I '
i likely. Direct deposition into the uncovered portion of the East Park Reservoir can be accommodated by isolating and bypassing this reservoir. Direct deposition in a raw water basin would be most readily accommodated by
- bypassing the basin and processing raw water without the
. pre-sedimentation provided by the raw water basins. The contaminated water could also be returned to the river or flushed from the system using, for example, fire ;
L hydrants. It should be noted that the water system has covered filtered water- storage facilities with i
-approximately two days supply of water (at normal usage rate) which would not be contaminated and could continue to be used. In addition, if the water to local areas is y
excessively contaminated, distribution of clean drinking water by trucks is possible wh'ile continuing to use.the normal. water supply for other purposes, f
l-
! E.R. Schmidt 31. At lower contamination levels involving watershed deposi-l l
.A.L. Toblin tion which are likely to persist for more extended C.F. Guarino. periods of time, the affected water source would require I!
R. Waller some modifications in the water. treatment processes to provide reductions in the finished water concentrations.
l 22 .
. .- . . _ , - - _ _ . - - - . . . . . - ~ . . . . . . . ~ - _ , - - ~ ~ . . . _ _ _ _ _ _ _ _ _ . _ _ _ . . - - - . - - - - - -
The treatment processes currently in use (Ref.14,, Appl.
Exh. 166) includes i
I o Pre-sedimentation of some suspended matter in the raw water.
o Chlorination to destroy taste and odor causing materials and for control of bacteria.
o Chemical addition of carbon or sodium chlorite for taste and odor control, lime for pH control, and alum ,
or-ferric chloride as flocculants.
~o Flocculation and sedimentation to remove suspended
? impurities, o Sand filtration to remove remaining suspended 46 impurities.
E.R. Schmidt 32. Extensive research on removal of various fission products A.L. Toblin from water was conducted from the early 1950s to the mid
_ C.F. Guarino 1960s largely as'a result of concern about fallout from-A. Naller; atmospheric weapons testing during that period (Ref. 20, Appl. ' Exh.172) . As a result of that research, the decontamination factor provided by the current treatment processes can be anticipated to be no more than 2 (i.e.,
23
~
50% removal) for total radioactivity, and less than that for dissolved strontium, cesium and iodine. As stated in paragraph 13 no credit was taken for any removal in the
-I t'reatment process.
s
. E.R.Schmidt 33.- Modifications to the current treatment process are t
A.L. Toblin feasible which could achieve reductions in the concentra-4 C.F. Guarino tion of certain nuclides by factors of from 5 to 10.
A. Waller The addition of activated carbon with the other chemicals
" prior to' flocculation gives a decontamination factor for iodine of from 4-to 5 (Ref. M , Appl. Exh. 172, .
Table 8.3). Adding a layer of activated carbon to the surfaces of the sand filters would provide additional decontamination, perhaps by a factor of 2, for a total DF for radioiodine of from 8 to 10.
- E.R. Schmidt 34. Dissolved strontium can be effectively removed by A.L.'Toblin _the use of a line-soda softening process normally
- C.F.-Guarino employed to remove dissolved calcium and magnesium
- A. Waller carbonates and sulfates from "hard" water, due to the chemical similarity between magnesium, calcium and strontium (all are Group I 1 elements) . Decontamination I; factors'of from 5 to 10 can be obtained by co-precipita-tion in an initial softening step with dosages of soda ash (sodium carbonate) in excess of those indicated by
[ stoichiometric requirements alone. " Repeated-precipita-L tion", in which a small quantity of calcium is added and 24 i-
removed provides an equal decontamination factor in each
~
step. Thus, a second step in which a DF of between 5 and 10 is obsained, would produce an overall process DF of r between 25 and 100 (Ref. 20,, Appl. Exh. 172) . If it were necessacy to provide this second stage of processing S
without constructing a major plant addition, the affected plant could be operated as two sequential process lines.
L That is, the treated effluent from one half of the plant would be returned to the rapid mixing' stage of the other
. half to provide the second stage of treatment. This would, of course, also reduce the throughput capacity of .
the affected plant by half and would probably require -
additional pumping capacity.
l CONCLUSION B.W. Bartram 35. The contribution to the public risk via the drinking
' G.F. Daebeler water pathway is small relative to that predicted
.C.F. Guarino for the City of Philadelphia via the airborne path-G.D. Kaiser- ways. The probability that there will be long term con-90 S. Levine tamination of the Delaware River by Sr and 137Cs even in the absence of protective measures is small, and
~
E.R. Schmidt A.L. Toblin the probability that such contamination could not be
'A.-Waller dealt with using available techniques, is vanishingly small (one in a hundred million per reactor year or less). For the Schuylkill River, the corresponding 25
probabilities are higher, but even so the implementation, of reasonable countermeasures reduces the probability of exceeding the PEMA long term guide to one in seventeen j million per reactor year. Thus, there is a very small probability that long term interdiction of the Schuylkill River would be required, and a vanishingly small prob-ability that long term interdiction of the Delaware River would be required. The probability that short term concentrations in excess of the PEMA one month PAG might occur has also been shown to be small. If the raw and finished water basins were to be contaminated by direct
-deposition, the probability tht the PEMA short term PAGs '-
would be exceeded is small and the resulting contribution to public risk is small. Countermeasures to reduce or.
eliminate this source of risk are possible.
- n l-i-
i L
l l
26 f
L_i
e.
c _
APPENDIX 1 1
DISCUSSION OF THE EXPAESSION RELATING THE RATE OF DEPOSITION OF A RADIONUCLIDE I-ONTO ' A WATERSHED TO THE TEMPORAL VARIATION OF ITS CONCENTRATIOK IN TAPWATER B.W.'Bartram 1. An integral part of the model described in the foregoing G.D. Kaiser testimony relates the transient concentrations of radio-
~ A. Tbblin strontium -(and radiocesium) in drinking water to the time history of the deposition of these nuclides. The
. relationship calculates the quantity of a radionuclide .
accumulated on land in a watershed by functionally relating the rate at which the nuclide is accumulated to
.both the rate at which it is deposited and its removal rate. The drinking water concentration is'then considered to have components related to the immediate deposition rate (e.g., direct deposition on the water surface) and the quantity of nuclide on the watershed
'. (e.g. , erosion) .' Each of'the functional relationships contain coefficients so that mathematical equations describing these relationships can be written. The i
L:. following equations are taken from Codell's work (Ref. 2, Appl. Exh. 154 p. 12) and are applicable to any watershed and any radionuclide, although the a fficients may
-changer 27 i.-
, ..... . - , - - , . - , . . _,_.sm,. -
. . . . . . , , - - - _ , ~ , - _ _ - _ - - -. . - - , _ _ _ , . , _ . . . - - . - - - - - , - - - , -
n.
dM g = AR (1-ky ) .- (g + A 2.I M (1)
.' h
- 1. -C=k AR + Mk 3 2
~ where M. is the accumulated activity of a radionuclide on land in the watershed, which is available for transport to surface water, Curies C is the surfact- water concentration, curies / liter A is' the area of the watershed, m2 2
R - is the rate of fallout, curies /(yr-m )
.k y is the fraction.of the affected watershed covered by open .
water-e 2
k is the coefficient relating the rate of fallout .to 2
- surface water c'oncentration, yr/ liter l
k - 'is the coefficient relating available accumulated fallout 3
on land to surface water concentration, liter" l
l k is the radiological' decay rate, yr-1
, 28 l
4 2
is the effective loss of available fallout from land due
~'
-l to all causes other than radiological, yr , l
.I !
l t l.
B.W..Bartram 2. For the case of an instantaneous deposition of an amount l 2
G.D.' Kaiser. 5 Curies /m of a radionuclide within a watershed of A. Toblin area A, the solution to equation 1 is C = 6A k 3 Il-N1 ) exp (- (k + ) t) (2) at time t years af ter the deposition takes place; t should exceed the averaging period for the data on which
[
the correlation is based, in this caso one month.' The
- average tap water concentration over time t is given by C= 2 + k3 (1-ky) (1-exp(-( + )t))/ ( +A)2 ) (3) l EB.W.'Bartram .3. As noted in the testimony at paragraph 14, the parameters G.D.~ Kaiser in eqs. (1) through (3) were obtained af ter first correlating New York City tapwater data on radiostrontium
~
.A.~Toblin l
i.. with HEW data on radiostrontium concentrations in the p.
i Schuylkill and Delaware rivers. Figure 2 shows how i
- closely the Delaware and Schuylkill data track the New l; York City data. Figures 8 and 9 show these correlations.
I. Table 2 gives the values of these parameters for l
radiostrontium and radiocesium, the radionuclides of l
interest for long term contamination of the water l supplies.
29
15 e
- 4. The correlation analysis leading to the coefficients for radiocesium was performed in a manner similar to that for i radiostrontium. Deposition rates for 137Cs were found by 1
i proportioning the 90Sr rates by the ratio of 137C s to 90 Sr concentrations in surface air. This ratio (1.8) was found to be practically constant with time (implying equal deposition velocities for these nuclides) (Ref. 2J.,
Appl. Exh. 173). New York City tapwater concentrations 137 for - Cs are shown in Figure 2. It can be seen that these concentrations track the corresponding 903 ,
concentrations quite well, albeit at a much lower level.
The ratio of Cs to ' Sr concentrations in New York
City water (0.10) were applied to the derived Delaware 90 and Schuylkill rivers Sr concentration data bases in 1
order to obtain the Cs concentration data bases needed to find the radiocesium coefficients of Table 2.
l 30
'.' i References ,
J
- 1. - Direct' Testimony of Richard Codell before the Atomic Safety and Licensing Board Concerning Commission Question 1, presenting an analysis 8
, . of thh risk posed by contamination of the Hudson River, reservoirs and other' bodies of-water that could be caused by severe accidental radionuclide releases at the Indian Point Nuclear Power Plant.
- 2. Richard B. Codell, 1984. Potential Contamination of Surface Water Supplies by Atmospheric Releases from Nuclear Plants, Health Physics, to
'tur published.
- 3. J. C. Helton, A. B.-Muller and A. Bayer, Contamination of Surface Water Bodies af ter Reactor Accidents by the Erosion of Atmospherically -
Deposited Radionuclides, Health Physics, to be published. .
- 4. U.S.~ Nuclear Regulatory Commission,'1975. Calculation of Reactor Accident Consequences - Appendix VI of Reactor Safety Study, WASH-1400
~ (NUREG - 75/014) , Washington, D.C.
- 5. Health and Safety Laboratory, U.S. Energy Research and Development LA dministration, 1977. Final Tabulation of Monthly 90 Sr Fallout Data:
1954-1976, BASL-329, New York, New York 10014.'
- 6. Larsen, Richard J., 1983. Worldwide Deposition of ' Sr through 1981, y EML-415, Environmental Measurements Laboratory, U.S. Department of Energy,.New York, New York 10014.
L
(- 7. U.S. Environmental. Protection Agency, 1976, Radiological Coality of the l Environment, Office of Radiation Programs, Washington, D.C.
20460.
i l
- 8. _. Hardy, E. P., Jr.'and L.~E. Tconkel, 1982, Environmental Measurements i Laboratory ' #ironmental Report, ML-405, Environmental Measurements Laboratory, U.S. Department of Energy, New York, New ' fork 10014.
l i-31
- 9. U.S. Department o'f Health, Education, and Welfare, 1960 through 1968, Radiological Health Data, Volumes 1 through 9. I
~ 10. Limerick Generating Station Radiological Environmental Monitoring i
Progriam, ' 1971-1977, Prepared for Philadelphia Electric Company by Radia' tion Management Corporation May,1979.
- 11. ~U.S. Environmental Protection Agency, 1976 through 1982, Environmental Radiation Data, Reports 6, 10, 15, 18, 23-24, 25-26, and 29, Office of Radiation Programs,'P.O. Box 3009, Montgomery, Alabama 36193.
. 12. Menzel, Ronald G., 1975, " Land Surface Erosion and Rainfall as Sources
-of Strontium-90 in Streams," Journal of Environmental Quality, Vol. 3, No. 3, pp. 219-223.
13.- U.S. Geological Survey, 1982, Water Resources Data for Pennsylvania- -
Water Year 1982 volume 1 - Delaware River Basin and Volume ~2 -
4 Susquehanna and Potomac River Basins, Water Resources Division, P.O.
Box 1107, Harrisburg, Pennsylvania 17108.
- 14. ' City of Philadelphia Water Department, 1982. How Water in Philadelphia is Treated and Distributed, 1180 Municipal ~ Services Building, Philadelphia, Fa. 19107.
- 15. U.S. Nuclear Regulatory Commission, 1977. Calculations of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of i
Evaluating Compliance with 10CFR50, Appendix I, NRC Regulatory
. '.' Guide 1.109.
I' ~
l l 16._ Simpson, D. B., and B. L. McGill, 1980. User's Manual for LADTAPII - A Computer Program for Calculating Radiation Exposure to Man from Routine Releases of Nuclear Reactor Liquid Effluents, Oak Ridge National Labora-
. tory, NUREG/CR-1276.
I r
32 I '
I
.. _ . _ . . _ _ _ - , _ . _ ._..~. _ _ _ - - - _ - ,_.- _ .._.-.-_... __ _ .--. , - . . . _ - . . . . _ _ _ _ _ _ _ . _ _ _ . _ .
li . .
17.' .Aptowicz, Bruce S., 1984. Letter to Robert E. Martin, USNRC, dated
~
April.23,-1984 and private communication, S. Gibbon, PBCO and B.
Aptowics, City of Philadelphia, May 25, 1984.
.. l .
> 18. PhilapelphiaWaterDepartment,1982. Table of pumping, treatment and consumption rates for FY '02.
'19. Commonwealth of Pennsylvania Disaster Operations Plan, Annex E, Fixed Nuclear' Facility Incidents, February 1984, p. E-12-42, 20.. Straub, C.P.,1964 Iow-Level Radioactive Wastes, Their Handling, 4
Treatment and Disposal, Division of Technical Information, United States Atomic Energy Cosutission.
- 21. . Hardy, E.P., Jr., 1981, Environmental Measurements Laboratory Environ- -
mental Report, ENL-390, Environmental Measurements Laboratory, U.S.
+
Department of Energy, New York, New York 10014.
4 .
L i
l i
33 l-L
. - - - - _ . . . _ . _ . . . . _ , _ , . _ _ _ _ . _ _ . _ . . . , ~ . _ . . _ . . . ~ . _ . _ - _ _._ .___ _ _ _ . -_. _ _ _ _ _ _ _ _.. _ __ _--,._ _
.- Table 1 Protective Action Guides for Drinking Water Concentrations (pCi/ Liter) 1 I
90Sr 137Cs 134Cs 131r 1337 10CFR Part 20- 300 20,000 9,000 300 1,000 PEMA - uncontrolled 96 2,400 240,000 36 120 discharges to surface water and in circumstances where the water supply is influenced by contaminated run-off and fallout-exposure time not to exceed 1 year PEMA - acute crisis conditions 8,000 200,000 2 x 107 3,000 10,000 where no other water supply is available-exposure time not to .
exceed 30 days ,
i l
l-i L
I
.__._.m,_ _ ,_
-Table 2 Coefficients Used to Relate Deposition and Surface Water Concentrations (based on monthly average data)
Schuylkill River Delaware River-
.Br-89 Sr-90 Cs-134- Cs-137, St-89 Sr-90 Cs-134 Cs-137 kl 0.0096 '0.0096 0.0096' O.0096 0.0207 0.0207 0.0207 0.0207 2 4.903+9' 4.903+9. 4.903+9 4.903+9 2.015+10 2.015+10 2.015+10 2.015+10' A (m )
di (yr-1) 4.804+0 2.502-2 3.388 2.310-2 4.804+0 2.502-2 3.388-l' 2.310-2
>2 (yr-1) 7.209-2 7.209-2 7.392-2 7.392-2 9.178-2 9.178-2 9.360-2 9.360-2 k2 (yr/1) 2.978-15 2.978-15 1.732-16 1.732-16 6.486-16 6.486-16 3.773-17 3.773-17 k3 (1-1) 4.335-15' 4.335-15 2.517-16 2.517-16 1.032-15 1.032-15 5.989-17 5.989-17
- 4.903+9 = 4.903 x 109' l
l l
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'56 '58 '60 Year Figure 1 - Comparison of Empirical Correlation Relating Rate of Fallout to Concentration in Tapwater-New York City Data (Table 2 of Ref. 1, Appl.
Exh. 153)
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. t , )- c.
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- i -. A .. , .-. _. - _ _ _ __ _.
- o SCHUYLKILL WATERSHED - SR90 CONCENTRATION 10-4 _ . > > uuj . i nung . i nung i onuj i i unag . . nun . . n ung . . o nu l : :
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10 5 CONCENTRATION CPIC0 CURIES PER LITER) 90 Sr in Schuylkill Figure 4 (a) - CCDF of Concentration'of l' Water
- Revised 6/12/84
SCHUYLKILL WATERSHED - CSl37 CONCENTRATION l
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Figure 4(b) CCDF of Concentration of Cs in Schuylkill Water
. Revised 6/12/84
, . _ . ~ . . _ . _ . . _ . - - . _ . _ . _ . . . . . _ _
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- l. 137 Figure 5(b) CCDF of Concentration of Cs in Delaware
. water l
I 1
l Revised 6/12/81
- c
1 1
, o. .
OUEEN LANE RESERVOIR - INSTANTANEOUS CONCENTRATION l 10" _ i i nuq a unq i inun i
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10-* 10-' 10-' 10' 10' 10' 10' 10 4 10' 10' 10 CONCENTRATION CPIC0 CURIES PER LITER)
Figure 6 CCDF of Instantaneous Concentration of I, CS 90 and Sr in the Queen Lane (and Belmont) Raw Water Basins Revised 6/12/84
i BAXTER/TORRESDALE RESERVOIR - INSTANTANEOUS CONCENTRATION 10" _ i i uu i sinig i i nung i in uj i inung i inuuj i i nia.g c inuug i sinaj iinna n 10-' _ _
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Fipre 8.- Conelation between 8%r concentrations in Schuylkill River water and New York City tapwater.
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=
Figure 9. Correlation between M Sr concentrations in Delaware River water and New York City tapwater.
w- ,
o ERRATA TO' APPLICANT'S TESTIMONY RELATING TO CONTENTION CITY 15 PAGE NO. DESCRIPTION 8' Line 10 -Add the word " water" to end of line 3
4- Last line . Add the phrase " Appendix F of the Severe Accident Risk" 10 Last'line Change "combinaition" to " combination" Ill Line'S Change " radio" to " radio "
. Line-9 Add the phrase "whereas the WASH-1400 conversion factors" before "are" 13 lLine 15 Change "approximatley" to "approximately" 14 Line'16 Add.the word " year";before the comma at I the'end of the line .
, .14 'Line>22: ' Add the word " reactor" after "per" 14 Line 23 Add the word " reactor" after "per"
- 15 'Line 16 Delete "1 year".from line 116: Line Change "significante" tx)-" significance"
~16- .Line 4 Delete " require that" from'line
~19 Line 9 Change "(130 rem" to read "(330 mrem" 22 Line 13 Change " uncovered" to " covered"
-Table 1 .Line-7 Change ~"10CRF"~to read "10CFR" Table 1 Line ll Change ~"influended" to " influenced" it 4
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