ML20205N579
| ML20205N579 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 10/31/1988 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#488-7487 OLA, NUDOCS 8811040210 | |
| Download: ML20205N579 (204) | |
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l GENERAL PUBLIC ITTILITIES NUCLEAR )
I CORPORATION. et al. ) Docket Ntx
) 50-320-OLA (THREE MILE ISLAND, UNIT 2) )
i LICENSE AMENDMENT APPLICATION )
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l l Pages: 67 through 267 Place: Lancaster. Pennsylvania Date: October 31, 1938 l
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j ATOMIC SAFETY AND LICENSING BOARD f
i In the Matter of: )
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GENERAL PUBLIC iTTILITIES NUCLEAR l
f CORPCRATION. et al. ) Docket Number
- ) 50-320-OLA (THREE MILE ISLAND, UNIT 2) )
LICENSE AMENDMENT APPLICATION )
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f Pages: 87 through 287 i
j Places Lancaster. Pennsylvania ,
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Date: October 31. 1988 i
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() UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Tax 50Ttl In the Matter of )
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GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-320 OLA CORPORATION. c1 giu )
) l (THREE MILE ISLAND. UNIT 2) ) l LICENSE AMENDMENT APPLICATION )
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, t i
j Monday.
f October 31. 1988 l i
- Courtroom A & Sixth !
- Floor Hearing Room ,
Lancaster County Courthouse I l
O SO North Duke Street !
{ U Lancaster. Pennsylvania 17603 !
i I The above-entitled matter came on for hearing. [
! i pursuant to netice, at 1:10 p.m. ;
i j !
} BEFORE: JUDGE PETER BLOCH, Chairman '
l Atomic Safety & LicensinE Board j U. S. Nuclear Regulatory Commission l
Washington, D.C. 20555 ;
i 4 JUDGE OSCAR PARIS. Member i Atomic Safety & Licensing Board l U. S . Nuclear Regulatory Commission 5 Washington, D C. 20555 ;
I i JUDGE GLENN O. BRIGHT. Member l Atomic Safety & Licensing Board t i U. S. Nuclear Regulatory Commission .
[ Washington, D.C. 20S55 j i i i
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() APPEARANCES:
On behalf of the Licensee. GPU Nuclear Corp _:
THOMAS A. BAXTER. Esquire DAVID R. LEWIS. Esquire MAURICE A. ROSS. Esquire Shaw. Pittman. Pott s & Trowbric;ge. P.C.
2300 "N" Street. N. W.
Washington, D. C. 20037 l
ROBERT E. ROGAN Director of Licensing & Nuclear Safety for GPU Nuclear Corp.
Three Mile Island Unit 2 On behalf of the UL.S. Nuclear Reeulatory Commission Staff:
STEPHEN H. LEWIS. Esquire COLLEEN P.WOODHEAD. Esquire U. S . Nuclear Regulatory Commission Office of General Counsel Washington. D.C. 20555 On behalf of the Commonwealth of Pennsylvania:
(~}
RICHARD MATHER. Esquire Assistant Counsel Department of Environmental Resources
-and-AJIT BHATTACHARYYA Bureau of Radiation Protection Departnent of Environmental Resources 505 Executive Building P. O. Box 2357 Harrisburg. Pennsylvania On behalf of the Intervenors. Susquehanna_Valleg Alliance & Three Mile Island Alert:
FRANCES SKOLNIK 2079 New Danville Pike Lancaster. Pennsylvania O Heritage Reporting Corporation (202) 628-4888 r
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i 89 h CONTENTS f C1a50Ndx l WITNESSES: DIRE /T. CROSS REDIRECT. _ RECROSS EXAM i
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l- RICHARD PICCIONI 118 151 f by Mr. Baxter 125
! by Mr. Stephen Lewis 159 1
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l Panel: 161 i KENNETH HOFSTETTER l KERRY L. HARNER i by Ms. Skolnik 194 l
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- l h CONTENTS EXHIBITS: IDENTIFIED RECEIVED DESCRIPTION (No Exhibits) l l
INSERT.Si i
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Teatirrony of Richard Piccioni 125 Testimony of Kerry L. Harner 163 and Dr. Kenneth Hofstetter on ,
j Sampling & Analysis of the AGW I
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('Ti/Blaci
) E R Q G E E-Q J ?1 G E 2 JUDGE BLOCH: Good afternoon. I am Peter Bioch.
3 I am Chairman of the Licensing Board, for the case or' 4 General Public Utilities Nuclear Corporation, el alu It is 5 a license amendamnt application. Docket Number 50-320 OLA.
6 It is my pleasure as the Chiir of the Licensing Board with 7 deep respect to welcone all of you here wholeheartedly.
8 On my left. Member of the Licensing Board Oscar 9 Paris. And on my right. Mr. Glenn Bright. Together, we 10 constitute the Licensing Board for this plant.
j 11 Our Reporter today is Joan Rose of Heritage 12 Reporting Company. I would appreciate it if the parties 13 would introduce themselves for the record, starting in front 14 of me and going clockwise.
15 MS. SKOLNIK My name is Frances Skolnik. I 16 represen' the membership of Susquehanna Valley Alliance and 17 Three Mile Island Alert.
18 MR. BAXTER: Good afternoon. Appearing for the 19 Licensee. GPU Nuclear Corporation. I am Thomas A. B ax t e r.
20 To my immediate left is Davis R. Lewis and to my far left.
21 Maurice A. Ross. We 're with the firm Shaw. Pi t t man. Potts a 22 Trowbridge. Also I would like to introduce to my right 23 Robert E. Rogan who is Director of Licenuing and Nuclear 24 Safety for GPU Nuclear at TMI-2.
25 MR. STEPHEN LEWIS: Your Honors. Stephen H. l.ewis O Heritage Reporting Corporation (202) 628-4888 i
s 92 O i eaa cotieea e. woooneea cooaeet ror the wac sterr.
2 MR. MATHER: Your Honor, my name is atit hard f
3 Mather Assistant Counsel with the Department of i t
4 Environmental Resources, partic.4.poting as an interested f 5 state. To my left is Aj it Bhattacharyya who works within p 6 the Department 's Bureau of Radiation Protection.
7 JUDGE BLOCH: Mr. Mather, just so that it will be p 8 easier for me later, could you tell me roughly what the !
'9 extent of participation you anti 31pate to be?
10 MR. MATHER: Well, Your Henor, as it 's obvious we I 11 have not submitted any testimony, so the extent will be ,
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12 observing the testimony and cross examination and at some [
r 13 point requesting an opportunity to provide some cross !
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14 examination. {
15 JUDGE BLOCH: Okt.y. So I will not routinely call
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16 on you for cross. but if you war + cross, you will take a 17 microphone and request it. Okay? !
19 JUDGE BLOCH: Thank you. [
20 MR. MATHER: Thank you. f t
I 21 JUDGE PARIS: How do you spell your name, sir?
i Mather.
22 MR. MATHER: M-a-t-h-e-r.
I 23 JUDGE BLOCH: The purpose of this hearing is to t 24 receive evidence related to the issues that are left in the 25 case after our decision on summary disposition. These j O !
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() i issues relate to water, which is being held by CPU Nuclear [
2 as the result of the Three Mile Island accident. The water ;
7 containn some radionuclidos. And the proposal of the 4 utility, which is the licensee and applicant in this case.
5 is that the water be evaporated with the consequence that 6 the solid radionuclides would be drawn off and they would be 7 called bottoms and they would be shipped to the State of 8 Washington for burial. And the remainder of the waste water 9 would be evaporated, and there would be some radioactive 10 content of that in the form of tritium so that a small 11 amount of radioactivity would be released to the atmosphere.
12 There is a debate about how important that 13 radioactivity is in terms of its health effects. There is a 14 difference of opinion between the Staff and the Utility on 15 the one hand and the Intervenors on the other hand.
16 The preferred alternative, as I understand it, for 17 the Intervenors, is to leave the water on site for a period 18 of t itre, perhaps 30 years, during which it might decay, and 19 recace that risk to the public by staying on site.
20 In the course of the introduction of testimony and 21 cross examination, the Board is looking for these issues to 22 be further clarified and we urge the parties to stick to the 23 merits of this controversy. And the purpose, of course, is
- 24 to persuade the Board of the merits of your case.
a 25 That said, my understanding is that the first i
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() i witness is Mr. Piccioni for the Intervenors. Is that 2 correct?
3 MR. BAXTER: Judge Bloch, we*ve discussed with the 4 other partica the desire to make a brief opening statenent 5 of about eight minutes ' duration, if we could.
6 JUDGE BLOCH: Will each of the parties be making 7 opening statements?
8 MR. STEPHEN LEWIS: The Staff has no opening 9 statement.
10 JUDGE BLOCH: Okay. There 's an opening statement 11 for the Utility. Is there one by the Intervenors?
12 MS. SKOLNIK Yes.
13 JUDGE BLOCH: So they are eight minutes each?
14 MS. SKOLNIK A couple of minutes.
15 MR. BAXTER: That 's what mine is.
16 JUDGE BLOCH: All right. Thank you. So who will 1
17 go first?
18 MS. SKOLNIK: The Licensee.
l 19 JUDGE BLOCH: Okay. The Licensee will go first.
20 MR. BAXTER: As this Atomic Safety & Licensing 21 Board stated in the first sentence of its August 25 22 Memorandum and Order, the issue before us is almost a decade 23 old. I would add that nearly two Tnd one half years have l
24 been devoted to the review of GPU Nuclear 's proposal to 25 dispose of the processed accident-generated water at TMI-2 O Heritabe Reporting Corporation (202) 628-4888 l
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() i In July 1986, GPU Nuclear filed with the NRC a f 2 report on the disposal of the water. In the report. GPUN .
t 3 identified and evaluated three disposal options on the basis j 4 of relative technical feasibility, regulatory compliance, l 5 environmental ef fects, costs, vaste generated and time !
6 required to accomplish. j 7 One of the options evaluated was the controlled i 8 discharge of the process-diluted water to the Susquehanna ,
l 9 River. Since the water haa been and is being processed to 10 lower the levels of radioactivity, the river discharge 11 option was found to involve insignificant environmental 12 impact and meet NRC regulatory requirements and was found to [
13 be the simplest and least costly option.
14 GPUN did not recommend river discharge. however, 15 because of the public perception that unique health risks i 16 are associated with this option. Instead, on the basis of 17 the careful evaluation documented in that report, GPUN ,
I 18 eele'ded and proposed for NRC approval the option of :
1 j 19 evrporation of the water and burial of the residue of f site 20 ao commercial low-level waste. l 21 Prior to the atnespheric release, the evaporator 1
22 disposal system will further reduce radioactive particulates 23 by a factor of 1.000.
24 In Decenber of 1966. the NRC issued for public !
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l 25 comment a Draft Supplement Number 2 to its Progranmatic !
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- () 1 Environmental Impact Statement on the TMI-2 cleanup. This l
1 2 impact statement supplement is devoted solely to the water 3 disposal issue. GPU Nuclear 's proposal and eight !
4 alternatives were given detailed. quantitative evaluations !
S while 15 others were considered and rejected for reasons ,
1 4 6 stated.
U 7 In June of 1987, the NRC issued its final version 8 of PEIS Suppsement Number 2 which includes responses to i 1
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10 The NRC then issued a Notice of Opportunity for i l
a 11 Prior Hearing on GPUN 's application for a license amendment
! 12 to delete the current prohibition on disposal of the ;
f 13 accident-generated water. ,
i Q 14 Over the course of the last 15 months. Intervenors f
i j 15 SVA and TMIA have advanced their criticisms of the l I
J 16 evaporation proposal and have advanced their assertions of !
! 17 further impacts and alternstives which they believe should 1
18 be studied.
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. 19 A considerable effort has been made by the NRC I 20 Staf f and GPUN to re.spond to the Intervenors ' contentions i 21 and questions. A creat deal of information has been nede !
l 22 available and exchanged and many issues have been resolved. I i
i 23 As a result of this process. the material issucs t
- 24 which remain in dispute at this hearing are relatively few J 25 and are defined in the Boerd 's 90-page memorandum and order l C:)
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2 The principal issue is.whether the alternative of 3 the Intervenors is obviously superior to GPUN 's evaporation 4 proposal. As a part of that question, the Board has held 5 that the amount of tritium in the water and the health ,
i 6 effects of its release through evaporntion will also be ;
7 examirad. j
'8 An important threshold question on which I 9 respectfully urge the Board to focus is the identification 10 of the Intervenors* alternative. The NRC 's hearing process l 1
11 imposes few obligations on an Intervenor. As the Applicant j 12 for the license amendment. GPU Nuclear has the burden of :
l 13 proof or. the issues. The Intervenors need only come here [
O 14 and ask questions.
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15 One ob!igation Intervenors have, however, is to [
l 16 state their allegations with sufficient specificity that we i 17 are put on notice of what our burden is. In the context of
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18 challenges to the NRC 's environmental reviews, the United 19 States Supreme Court has stated that administrative f 20 proceedings should not be a game or forum to engage in 2i unjustified obstructionism by making cryptic and obscure !
22 reference to rnstters that ought to be considered.
23 In short, fundamental fairness dictates that we
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24 should not be required to guess at what the issues are and 20 the Intervenors should not be allowed to trove that target at j O Heritage Reporting Corporation t (202) 628-4888 I
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i 2 The alternative remaining here is termed the "no i 3 action alternative" in Intervenor 's Contention Nunber 2. As !
4 we learned during the discovery process, however, that is f i
5 not an accurate description of the alternative. The {
6 Intervenors, in response to our discovery request, defined 7 their alternative as requiring three msjor stepu -- the pre-8 processing of the water GPUN alreedy has planned, storage of 9 the water on the site and eventual disposal. The 10 Intervenors would not and have not to this day identified i i
11 quantitatively the length of the storage period they propose 12 and they had not identified the ultimate disporal method I l
13 that would be used. ,
O 14 Obviously, these facts are critical in order to f 15 conduct, as the Intervenors claim must be done, a thorough (
16 evaluation of their alternative.
17 In this situation, we nave had no choice but to }
't 18 make our own good faith assumptions. I aubmit that the
- i 19 Ir.terver, ors are in no position at this point to question or j 20 critici=e those assumptions. I note that Intervenors' l I
21 witness Piccioni appears to agree with our 30-year t 22 assumptions for the storage period. It must also be i 23 recognized that we are not here to assess the no-action ;
24 alternative described in the PEIS but rather, an alternative 25 of the Intervenors which does require considerable action -- l l
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9t "O 1 pre treetmeat of the weier. coestrection ef tenxa. storece !
2 a'id disposal of the water eventually, i
3 The Licensee will present here the testimony of j 4 nine witnesses to assess aspects of the evaporation proposal 5 and the Intervenors ' alternative. First. Mr. Harner and Dr.
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- 6 Hof stetter will explain our ef forto to sample and analy::e j I
7 the water and will describe why we are confident that we !
f 8 know its tritium content, j 9 Mr. Buchanan will describe the evaporation !
1 l 10 proposal, will elaborate on the storage requirements for the !
11 alternative and will compare the costs of the two. j 4
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12 Mr. Tarpinian will compare the proposal and the }
t 13 alternative from the standpoint of worker exposure to 7
14 radiation, while Mr. Weaver will compare the risk to the !
i i 15 public from postulated accidents during each option.
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j 16 Dr. Laker and Mr. Cooper wi!I compare the f
17 estimated radiological doses to the public off site. i
- i. 1 18 And Dr. Auxier and Dr. Fabrikant, two of the 19 world 's leading experts, will assess the heatsn effects of f
! 20 the tritium to be released, i t
! 21 While these witnesses will provide the record wi'.h !
1 I 22 a complete environmental evaluation. the decision comes down j J
23 to an assessment of the benefits of further decay of tritium f j 24 during the Intervenors ' proposed storage period and the J l 4 25 costs of achieving those benefits. l lO Heritage Reporting Corporation (202) 628-4888
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() 1 The evidence clearly shows that the benefits of 2 the storage period are non-existent in our view while the 3 costs are significant. The estimated radiological doses to 4 the public f rom e/aporation are already so small that no 5 adverse effects are expected. A conservati"?. upper bound 6 estimate of the average exposure to a member of the 50-mile 7 population is 0.005 -- that is 5 thousandths -- of a 8 millirem, to the total body. In contrast, the average
} 9 person wfll receive about 300 millirem per year from natural 10 background. That is 60.000 times the dose from the 11 evaporation process.
12 To illustrate further, the ev4dence shows that the 13 additional dose from living in a brick instead of a wood 14 house is 20 millirem per year. or 4.000 times the dose from 15 evaporation. Even exposure to a color television set.
16 estimated to be i millirem per year. is 200 times the 17 evaporation dose.
18 In short. we are talking here about doses below 19 the level of meaningful measurement and consideration.
20 If the water is stored for 30 years more the 21 t ritium undeniably will decay. All other things being 22 equal, the 5 thousandths of a millirem everage total body 23 dose would be reduced to about one foarth of that amount.
24 But one quarter nothing is still nothing.
25 And what would it cost ? GPU Nuclear 's proposal O Heritage Report i ng Corporation (202) 628-4888
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() 1 will cost a total of 84 1 million. The Intervenors '
i 2 alternative would cost at least $2.1 million for the pre- l r
3 processing of the water. 89.1 million for the tanks they [
t 4 suggest plus the unknown costs of ultinate disposal of the :
5 water.
6 Clearly, this is not a hard choice. The evidence ;
7 will show that the Intervenors' alternative is not clearly [
8 superior to the evaporation proposal. Indeed, it will be !
l 9 shown that their alternative is clearly inferior. [
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l 10 Thank you.
$ T2/Bledi JUDGE BLOCH: As I understood your brief on ,
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I 12 summary disposition, the standard is obviously superior, not L
13 clearly superior?
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MR. BAXTER: i
! 14 You 're correct. Thank you, I
q 15 JUDGE BLOCH. Thank you. [
16 WS. SKOLNIKt I ahree with the Licensee that the I
I 17 issue before us has been in the discussion phase for two and I think that, in itself, demonstrates an I l 18 a helf years.
i l 19 indication of the serioueness with which we view the (
, 20 dispersal of low level radioactive vaste into our !
t 21 environment. Furthernore, we also believe that the process
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- 22 .# evaporation has much note risk than the Licensee has led [
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to believe and that is the purpose for having the Atomic j 24 Safety and Licensing Board hearings. l
- 25 The public does have the right to participate. l l !
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( )' 1 And befora this Board there are curtain issues that still 2 have not been resolved even though two and a half years have 3 gone by.
4 JUDGE BLOCH: Ms. Skolnik. when you say "much more 5 risk " could you give us a preview of what your testimony 6 will show about what risk there really is? What in the 7 level of radioactivity that you are concerred about?
8 MS. SKOLNIK I 'm concerned about the tritium that 9 will be released. I 'm concerned ab0ut any radioactive 10 releases that will be made by the evaporation process.
l 11 JUDGE 3 LOCH: Do you know the dose? What will the 1
12 done be?
13 MS. SKOLNIK: Yes. I would rath'er lea /e that to l
l 14 the witnessen. Bececase they are expert witnesses. That is 15 their field.
16 I intend. at the hearing. to demonstrate certain 17 points. I intend to demonstrate that the Licensee has f ailed 18 to present a proposal which is in keeping with the NRC 's 19 policy to provide a safe and expeditious cleanup at Unit 2, 20 I also intend to demonstrate that the NRC has not 21 net its responsibilities as mandated by NEPA in providing 22 the pub'.ic with a detailed and suf ficient review of the no-23 action alternative and indeed that they have presented us 24 with a view of the no-action alternative which is nost --
25 they have shown Te no-action alternative in a nost O Heritege Reporting Corporat ion (202) 628-4888
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(,) - 1 unfavorable light.
2 I intend to bring forth Dr. Morgan and Dr.
3 Piccioni and Dr. Hoover, who will demonstrate that the 4 health effects are much more than the Licensee has made out, 5 that the no-action ulternative is a viable alternative and 6 tnat the NRC has not provided enough evidence about the 7 tritium in order for the public to make an evaluation of the 8 evaporation proposal.
9 JUDGE BLOCH: Ms. Skolnik?
10 MS. SKOLNIK: Yes.
11 JUDGE BLOCH: The burden is going to be on the 12 Licensee.
13 MS. SKOLNIK: Yes.
14 JUD)E BLOCH: But you 're going to have to show 15 that there is some alternative that is obviously superior to 16 their alternative. Could you describe what the alternative 17 is that is obviously superior?
18 MS. SK0LNIK: Well, first of 61), let me say I 19 don 't feel it 's right that this forum nas put the burden on 20 me to show that the no-action alternative is obviously 21 superior. One of my contentions is directed to the fact 22 that the NRC has not adequately evaluated the no-action 23 alternative. I 24 JUDGE BLOCH: The purpose of this hearing, though, 25 is to test whether the Intervenors are able to show that O Heritage Reporting Corporation (202) 628-4888
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(_) 1 there is something better than the alternative proposed by 2 the Licensee. Now, if you show that there is something 3 there, the burden of proof will actually be on the Licensee.
4 But you 've got to suggest to us, the burden of going 5 forward, what the alternative is. The fact that the NRC may 6 not ; e previously analyzed to your satisfaction the no-7 action alternative is at this stage irrelevant because we 8 are now compiling a record, an evidentiary record, which t
9 vill be fuller than'what the NRC staff did previously. The 10 Applicant 's testimony on this record will be part of the 11 record of how the NRC studied the no-action alternative.
12 So the previous insufficiency that you are 13 alleging is irrelevant at this stage. We have to see, with 14 the water that 's there -- and there is no alternative of
. 15 going back and uncreating it, it 's there -- the quest ion is 16 What as the best way to handle it. And in this hearing tne 17 suld ect is wnether th" Applicants have shown that their way i
18 is the best way.
19 If you can indicate a different way, that is 20 obviously superior, it will be then burden to show it is 21 not obviously superior. But we can't go back to a prior 22 time as to the NRC study. We are really going to be 23 contesting here what is best.
24 MS. SKOLNIK: Yes. I agree. That 's true. We 25 can 't. It wasn't just me who denonstrated -- I demonstrated l
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) 1 that the NRC had not evaluated the no-action alternative 2 sufficiently. And you agreed with that in your Order of 3 August 25th.
4 JUDGE BLOCH: Yes.
5 MS. SKOLNIK: So the point I would like to make is 6 that the ASLB forum is not the proper forum for the NRC to 7 rehabilitate its evaluatioh of the no-action alternative 8 because I am alone here. The reason that the evaluation is 9 made in the first place, it 's for the public to be provided 10 with sufficient information for evaluation of the no-action 11 alternative.
12 JUDGE BLOCH: As a matter of law, I just disagree 13 with you about what the purpose of this hearing is. If thin (D
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14 hearing is a public forum and it takes evidence about the 10 no-action alternative ar.d these Judges decide on the record 16 what the situation ic, that will substitute for what the NRC 17 did previously. This is a public hearing for the purpose of r
18 seriously determining the merits of what you are raisittg.
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19 There is no way of cuing back to that prt'vious study.
20 That's my ruling.
21 Now, if one of the other parties thinks there is a 22 problem with that, they may raise that in order to assist 23 the Board.
24 But as I understand it, the law is that you can 't 25 go back to that. That 's what we 're here for now is to make
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.( ) 1 a complete record on this alternative.
2 MS. SKOLNIX: Okay. And I will also make a 3 complete record on the preferability of the no-action 4 alternative.
5 JUDGE BLOCH: Good. Now, as you say no-action 6 alternative, Mr. Baxter asked a question: what is the no-7 action alternative? Is it, as he said, the pre-treatment c.f ;
8 the water by the Licensee, storage for 30 years and then 9 what? Then evaporation? What is the no-action alternative?
10 MS. SKOLNIK: The no-action alternative is pre-11 treatment of the water, storing the water in proper tankage.
12 monitoring the water. There is no time period designatud.
13 JUDGE BLOCH: So indefinite?
14 MS, SKOLNIK: It could be as indefinite as the 15 rest of tlse cleanup at Unit 2. yes. I don 't see why a time 16 period should be fixed. Because Unit 2 is radioactive and 17 <ill continue to be radioactive for a period that I probably n 18 won 't be around.
I 19 JUDG2 BLOCH: Okay. If that 's the case, how would l 20 you suggest that we estimate the radioactive consequences of 21 that alternative? There 's a possibility that it will be 22 evaporated after the 30 years, there 's a possibility it will 23 be stored for 130 years. Are you proposing different l 24 alternatives or one?
j 25 MS. SKOLNIK: Well, Judge Bloch, I really don 't I
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() i have the resources to go out and investigate the different 2 alternatives that might be available in 30 years, so I think 3 it is unfair to put that burden on me to come up with what 4 might happen in 30, 50, 60 years ' time. I think what has to S be recognized first of all is that the major radio-isotope 6 in the water is tritium and that even in 30 years ' time it 7 will have decayed to the point where it 's not going to have 8 the same effect. !
9 And you know, if you want to, we could have 30 10 years as the starting point. But on the other hand, it 11 could be 60 years. And at the end of that stage. I do think 12 that we can allow for technology to have been developed to ,
13 take care of the water.
14 JUDGE BLOCH: Okay. I'm doing this in order to try 15 to be of some assistance, because there are certain issues 16 we are going to hcve to decide on the merits at the end.
17 And we are going to be looking for differences in the f
18 radioactive consequences of the alternative applicants 19 propose, licensee applicants, and the alternative that you ,
20 propose, i
21 So we are going to have to have some way to get a ,
22 handle on thats what are the radioactive consequences, the -
23 differences in those. And the other part of it of course is 24 the costs. What are the differences in costs. And those 25 are the two thingo that we are going to have to weigh.
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(_) 1 Do you understand that?
2 MS. SKOLNIK: Yes.
3 JUDGE BLOCH: Okay. Thank you. Do you want to 4 continue and conclude? Continue this to sum up.
5 Take your time, because I know I made a 6 substantial disruption.
7 MS. SKOLNIK: Yes. Well, I wonder -- my opening 8 statement is more or less concluded. But I wonder if I 9 could address one other thing. It concerns the Licensee 's 10 motion about Dr. Morgan's testimony and your telephone call 11 which told me that we would have to address that on Thursday 12 morning?
13 JUDGE BLOCH: Yes. You want to address that as a
/~T
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15 MS. SKOLNIK: Yes.
16 JUDGE BLOCH: Please.
17 MS. SKOLNIK: Okay. What I would like to ask is 18 that since of ficially Dr. Morgan 's testimony hasn 't been on 19 the record, it 's alnest premature to strike parts of it from 20 the record and I'm asking therefore that we addrese the 21 whole issue of that particular motion when Dr. Morgan is 24 present so that he could assist me and defend his position.
23 JUDGE BLOCH: Mr. Baxter?
24 MR. BAXTER: Judge Bloch, we 'd have to oppose 25 that. The motion is entitled "A Motion to Strike." It 's em b Heritage Reporting Corporation l (202) 628-4888 i i 1 i
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(_x) i really in the nature of also giving the parties advance 2 notice of what obj ections we would of fer. I think we 're 3 providing assistance both to you and your preparation'for 4 the trial and the Board and the other parties by knowing in 5 advance and in writing exactly what arguments we would be 6 raising so you wouldn't have to respond on the spot.
7 Dr. Morgan 's appearance is really unnecessary for l 8 the Board to decide whether the testimony is relevant to the I l
9 materiai issues that remain. And we would appreciate a 10 ruling early so that we can all economize in our preparation 11 for cross examination and for the hearing. I don 't thinx 12 the witness is needed at all to help decide what is relevant 13 in his testimony.
14 JUDGE BLOCH: Would the Staff like to comment?
l 15 MR. STEPHEN LEWIS: Your Honors, the Staff also 16 believes that it would be of assistance to the efficient 17 running of the hearing to have a ruling as soon as possible 18 on whether or not eny portion of Dr. Morgan 's testimony will 19 be stricken,
< 20 The testimony has been filed and it is oovious
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21 that the Intervenors intend to of f er that testimony so I 22 don 't think that the matter can be put off on the grounds 23 that it 's premature.
24 It was of assistance that a motion was filed and l
25 the Staff would be prepared to address it on Thursday as you r
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'(_) 1 have requested.
2 MR. BAXTER: If I might edd one other point, Judge 3 Bloch. It is also the fact that we are down to one day for 4 Dr. Morgan as an acconnodation to the Intervenors and I 5 would hate to see the actual presentetion of evidence 6 compromised by having a large procedural matter left to go ,
7 through that day as well.
8 JUDGE BLOCH: Ms. Skolnik, may I ask. I was able 9 to arrange to have the Appeal Board room available the 10 Wednesday morning following Dr. Hoover 's appearance on the i 11 15th.
12 MR. STEPHEN LEWIS: Dr. Morgan 's appearance. Will 13 he be able to be there the following morning?
14 MS. SKOLNIK: I believe not. I can 't quite 15 remember. But I think he bas to leave Washington that 16 evening to be somewhere else the next day. I could ask him. ,
17 But I believe not. .
1 18 JUDGE BLOCH: Do you have anything that you would 19 like to rebut that was new to you that you didn't 20 anticipate?
21 MS. SX0LNIX: Concerning this motion?
22 JUDGE BLOCH: In the responses that you got to 23 your motion.
24 MS. SKOLNIK: Well, I feel also if I direct ny !
25 attention to this particular motion, that it is taking away (2) Heritege Reporting Co: porat ion
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( ,) 1 from my preparation for the witnesses that were scheduled 2 for this week, i 3 JUDGE BLOCH: Thank you. We#11 take a very brief f
4 recess to talk this over.
S (Whereupon, a brief recess was taken.)
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(,_f 1 JUDGE BLOCH: The licensing Board is in order.
2 After conferring, we 've decidea to deny your totion. Mrs.
3 Skolnik.
4 We understand it would some advantage to have Dr 5 Morgan with you while you argued that procedural motion.
6 But your responsibility is to know which parts of the 7 testimony you filed are relevant to the issues of this case.
8 You 're responsible for knowing what the record is 9 and knowing what is relevant and what is not. ,
10 So that really is your expertise and not Dr.
11 Mo rgan 's. In addition, almost all of the motion has to do l 12 with relevance.
13 There 's one part that has to do with whether or
- 14 not you authentically filed the proper document for a 10 particular appendix.
16 And it seems to me you can clarify that by talking 17 to Dr. Morgan yournelf.
18 So I don 't see why his presence is nocessary and 19 there would be some expedition in being able to go forward 20 on Thurednr 21 Whethe7 it 's Thursday morning or not, I 'm not 22 certain. We 're going to be here through Thursday evening 23 for limited appearances.
24 And it 's even possible that there will be a gap in 25 the hearings before you have to argue the notion.
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() 1 So we can try to accommodate you but . I 'd like to ;
2 argue it on Thursday because I anticipate, although I can't 3 be sure, that we won 't need Friday for hearings this week.
4 So I deny the notion and we will argue it on ,
5 Thursday.
6 Ms. Skolnik, it 's your first witness.
7 MS. SKOLNIK: Okay.
8 MR. STEPHEN LEWIS: Your Honor, there is one other 9 preliminary matter, 10 JUDGE BLOCH: Please.
11 MR. STEPHEN LEWIS: I don 't know whether Mrs.
12 Skolnik was completed with -- are you completed here?
13 MS. SKOLNIK: Yes. Yes.
14 MR. STEPHEN LEWISt There 's a preliminary matter 15 relating to the fact that we had identified to Ms. Skolnik 16 last week that due to a conflint in the schedule of Mr.
17 Thonus who is a witness with Dr. Masnik regardind the 18 sampling that we had requested that his testimony, that 19 their joint testimony be considered earlier in the 20 proceeding than is currently set forth in the scht.dule we 21 filed with the Board.
22 And that would be most likely we would request 23 that it be af ter the testimony of Applicant 's witnecaes.
24 Hofstetter and Harner who are their witnesses on the 25 sampling on analysis of the accident generated water.
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() 1 I advised Ms. Skolnik of that on Wednesday so that 2 in f airness to her so that she could adjust her preparation 3 as appropriate.
4 She called us back on Thursday and indicated that 5 she was not prepared to accommodate our request.
6 Now, Mr. Thonus is not available on Wednesday or 7 Thursday of this week. And if all of the Applicant 's panels 8 were heard before Mr. Thonus and Dr. Masnik went on. then we 9 would be putting their testinony merely by that decision ,
10 back inevitably into Friday.
11 And so we are requesting that they be permitted to 12 testify after Harner and Hofstetter. Perhaps Ms. Skolnik 13 would care to respond.
14 But that is where that request stands at the 15 moment and we would like that r..atter cleared up. h r
16 JUDGE BLOCH: Ms. Skolnik, would you like to i 17 respond to that?
18 MS. SK0LNIX: One of the reasons I had said no to 19 Stephen, well. there 's t w-). was because I had already 20 planned how I was going to approach the hearings. So the 21 schedule was important to me.
22 And when I did ask Stephen whether or not Mr. (
23 Thonus could appear on Friday, because I understood the NRC 24 and the Licensee did accommodate with my witnesses and when 25 I find that Mr. Thonus and Mr. Masnik could appear on ;
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() 1 Friday, I thought, well, it 's okay if I say no, I 'd rather 2 not have them in between there. That 's the only reason.
3 JUDGE BLOCH: Could you say just a little bit more 4 about how the order affects your case? Can you say.
5 something?
6 MS. SKOLNIK Mentally, it affects my mental 7 thinking. I had a pattern that I had in my mind and I guess 8 I didn 't really want to change it. That was all.
9 And since it didn't mean the dif ference between 10 the NRC 's witnesses appearing or not appearing, it seems 11 that I should just please myself.
12 JUDGE BLOCH: I guess I don 't understand why it 13 hurts your case. The fact it changes --
0 14 MS. SKOLNIK: It doesn 't hurt my case.
15 JUDGE BLOCH: Okay. So if it doesn 't hurt your 16 case, then it 's just a question of your not wanting to be 17 flexible, is that correct? j 18 MS, SK0LNIK Most people here to be --
19 JUDGE BLOCH: You had a certain idea in your mind 20 and you don 't like to shift that. That 's j ust a question, 21 it 's a personal flexibility, isn 't it?
22 It 's not a question of a meritorious reason? I t 's 23 not a strategy consideration?
24 MS. SKOLNIK: No. I guess it isn't. It is. Yes.
25 it 's just a matter of flexibility.
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116 l!h 1 JUDGE BLOCH: Thank you. Does the Licensee want 2 to comment?
3 MR. BAXTER: We have no obj ection to Staf f 's 4 witness following ours. It is the same subj ect mat ter --
S one place in the record.
6 MS. SKOLNIK: I should say too, if my cross 7 examination of Mr. Harner and Hofstetter would finish early 8 this afternoon. I do not have my papers with me for Mr.
9 Thonus and Mr. Masnik if they were to be cross examined this 10 afternoon.
11 Definitely, they could only be cross examined 12 tomorrow morning.
13 MR. STEPHEN LEWIS: Well. I mean if we got to that
'x' 14 point on the understanding that they could be taken the 15 first thing tonorrow norning. That would al.so be 16 satisfactory.
17 JUDGE BLOCH: Okay. So if there 's that problem 18 for you physically, what we will do is wait until first 19 thing tonorrow morning for those wi(nesses.
20 And we 'll work with whatever oeder we can work out 21 before then. So to that extent, we can accommody.a your 22 needs and we will allow these witnesses to come first.
23 If I knew we were going through Friday, I would 24 accommodate your needs but I don 't know that we 're going 25 through Friday.
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(,) ? So let 's take the order as requested by Staf f.
2 Are there any other preliminary matters? There being none.
3 Ms. Skolnik. you could begin with your witness.
4 MS. SXOLNIK: Okay. I 'd like to introduce Dr.
5 Richard Piccioni.
6 Does Dr. Piccioni continue to sit here? Does b) 7 have to move anywhere else? Does it matter?
8 JUDGE BLOCH: It would be easier if he were next 9 to the microphone either on the witness -- do you prefer --
10 at this table over here, this microphone is on.
11 The full name of the witness, please?
12 THE WITNESS: (Piccioni) My name is Dr. Richard 13 Piccioni. I'm a senior staf f scientist with Accord Research 14 and Educational Associates which is a not-for-profit 15 enviro nment e.1 research group based in New York City.
16 MS. SXOLNIK: Dr. Piccioni, would you please 17 explain your area of expertise?
18 JUDGE BLOCH: Oka/ . 3efore we do that. Dr.
19 P icc iord . I 'd like to volcome you to the heerl.'8 And I'o 20 iike to inform you that the testinony that you are about to j 21 give must be the truth and the whole truth and that ycur 22 test imony is subj ect to possible penalties for perj ury.
23 Do you understand the warning that I 've j ust 24 given?
25 THE WITNESS: (Piccioni) Yes.
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118 O 1 wnereuvon.
2 RICHARD PICCIONI 3 having been first duly sworn, was called as a witness herein 4 and was examined and testified as follows:
5 JUDGE BLOCH: Thank you. Now, Ms. Skolnik.
6 MR. BAXTER: Mr. Chairman. I would be happy to 7 stipulate the admission of Dr. Piccioni 's testimony, skip 8 the formal questions if that 's convenient.
9 MS. SKOLNIK: I just have one question I want to 10 address to Dr. Piccioni before the testimony.
{
11 JUDGE BLOCH: All right. Let 's hear that. Sure.
12 DIRECT EXAMINATION 13 MS. SKOLNIX: Okay.
14 BY MS. SK0LNIK:
15 Q Dr. Piccioni, will you please explain why you 're 16 presenting this testimony and explain which contention you 17 are addressing and briefly summarize your testi,nony. Thank 18 you.
19 JUDGE BLOCH: The first two questions are 20 f rrel e va.1t. The t rief summary I think will also be 21 irrelevant because we have reed all the testimony. And we 22 really would like to proceed efficiently now.
23 If there 's some highlight, if there 's come brief
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[m.) i few sentences, that would be okay.
2 But I don't want to have all of the pre-filed 3 testimony summarized in this case or it will take a very 4 lengthy period of time for everyone to do thei.
5 Is there something you 'd like to say about your F
6 testimony to emphasize some point?
7 THE WITNESS: CPiccioni) Sure. I mean it 's not a 8 lot. I could make it pretty brief.
9 Basically what I tried to illustrate by way of 10 calculation in the testimony which I've submitted is that 11 the impact, even the potential impact, due to accidental 12 release of onsite storage is much less than the predicted 13 octual impact of evaporation.
14 But to see that, that is the case you have to look 15 at the numbers which are provided by the Licensee in a 16 different way from the way that the Licensee presents them.
17 And in particular the issue really has to do with 18 three assumptions about the impact of an accidental release 19 of water that is stored on site.
2,0 The first is the assumption the3, that woter is 21 not going to oe pre-treated or actually 1 believe the term 22 that 's used in the supplement is re-treated in order to 23 decrease ten-fold its concontration of all radionuclides 24 which are filterable which does not include the treated 25 ones.
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() 1 The second assumption is that --
2 JUDGE BLOCH: I 'm sorry, your testimony assumes
-3 that it will not be re-treated even though the Applicants 4 say that it will be?
S THE WITNESb (Piccioni) No. Actually I am going 6 on the basis of what is in the supplement in which the no l
7 action alternative is described as the storage of water 8 without re-treatment.
9 JUDGE BLOCH: Okay. So the no action alternative 10 you support would have it re-treated?
11 THE WITNESS: (Piccioni) Yes. It would have it 12 re-treated, number one. Number two. f.t would have it stored 13 in such a way which is to say in numerous vessels rather 14 than a single vessel, so that release of the full 2.3 15 million gallons is not really a credible accident. That 's 16 two factors.
i 17 The other is simply to point out that a very large L
18 fraction of the dose that the Licensee calculates due to an l 19 accident is through the specific pathway of shellfish !
, I l 20 consumption.
t 21 And that since an accident would be something that 22 would occur with knowledge, provided that they were
- 23 monitoring the storage. the spontaneous or active i 24 interdiction of shellfish downstream would have on enormous i
i 20 effect on the actual calculated dose. .
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121 O You put these factors together and you compare
(_) i 2 the, again, possible dose due to an accident of the stored 3 water, compare that dose to the actual predicted dose of 4 evaporation, you cone up with a very large ratio of those 5 two, a very large ratio, in excess of 4,000 if you exclude 6 the shellfish consumption pathway.
7 I think this is very important to keep in mind 8 when they 're considering, when there is a consideration of 9 the so-called no action alternative as being something which 10 is in some wey a less desirable than evaporation.
il Clearly the no action alternative, by its very 12 nature does not allow environmental relaeee. It is the 13 decision not to release the material into the environment 14 for the indefinite future.
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1 15 Since radioactive decay is on our side, that is a 1
16 priority to the goed and the possibility of improvement in 17 technology in the coming decade is also, shows that time is f, 18 on our side.
19 but really the main thing in that it is a decision 20 not to ro19ase radioactivity into the environment.
21 And again, sorry if I 'm repeating myself, the only 22 counterbalancing issue is the impact of an accidental 23 release of the materials stored.
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() 1 was greatly overstated by the Licensee has never been in 2 this position before of pointing out an overstatement of 3 risk by the Licensee.
1 4 But that appears to be the case here. It 's rather 5 extraordinary. l 6 JUDGE PARIS: -- intake from shellfish?
7 THE WITNESS: (Piccioni) It 's due to the f act 8 that they assume, first of al) :.at the water will not be 9 pre-treated and therefore you don't have the ten-fold 10 reduction in all filterable radionuclides.
11 Second, that all of the 2.3 million gallons will 12 be promptly. I believe their phrase is, the prompt 13 accidental discharge of 2.3 million gallons. That 's the [
N-) 14 basis for the calculation.
l 15 And also again the inclusion necessarily of this ,
16 shellfish pathway that turns out to account for the majority ;
17 of the dose.
! 18 JUDGE PARIS: Are you assuming that if there were
- t 19 an accidental release the fishery people would prohibit i
20 shellfish collecting and putting on the market? !
I 21 THE WITNESS: (Piccioni) What I think is that, i
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22 that is a pos;ibility, yes. Because an accident would be ;
23 something that would happen with indication that it was ;
24 happening.
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20 And so it would be definitely possible, yes, to !
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'() i control fishing activity downstream. This is in contrast to 2 an evaporative release over many months in which case you 3 couldn 't -- you were not in a position to interdite 4 anything. The distinction. I think, is meaningful. Is that 5 clear?
6 JUDGE BLOCH: No. I heard everything you said.
7 THE WITNESS: (Piccioni) Okay.
8 JUDGE BLOCH: Thank you.
9 MS. SKOLNIK: I have nothind else to add except 10 that Dr. Piccioni's testimony should be entered into the 11 record.
12 JUDGE BLOCH: Is there any obj ection?
13 MR. BAXTER: No.
14 JUDGE BLOCH: There being no obj ection, the 15 testimony is received for the record. Do we have a copy to 16 hand to the reporter to bind in?
17 THE WITNESS: (Piccioni) If it 's useful. I happen 18 to have an extra copy.
19 JUDGE BLOCH: We need one that's unmarked to be 20 bound in.
21 THE WITNESS: (Piccioni) Uh-huh.
22 JUDGE BLOCH: I can use my copy.
23 JUDGE BLOCH: Off the record.
24 (Discussion held off the record.)
25 JUDGE BLOCH: We 'll bind that in and we car label j
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(,,,) i it Intervenor 's -- no we don 't need to. It will be given 2 page numbers. It should be numbered within the transcript 3 consecutively.
4 (The testimony of Dr. Richard 1
< 5 Piccioni is inserted into the i 6 record and followszy i
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125 Octobar 10, 1908 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O('s BEFORE THE AT MIC SAFETY AND LICENSING BOARD In the Matter of ) ,
GPU Nuclear Corporation ) Docket No.50-320-OLA (Three Mile Island Nuclear ) (Disposal of accident Station, Unit 2) ) generated water) l TESTIMONY i Richard Piccioni, PhD l Senior Staff Scientist Accord Research and Ebucational Associates 314 West 91st Street, New York, NY 10024 Although I have previously expressed skepticism reg rding the i predictions in NUREG 0683, Supplement 2, on the environmental impacts of che forced evaporation of 2.3 million gallons of accident generated water (AGW), the disposal alternative favored l by the licensee, General Public Utilities, it !.s not necessary to challange those estimates to conclude that forced evapora-tion, as opposed to retreatment of all AGW followed by onsite monitored storage, is not in keeping with the principles of l r~) ALARA, and of the NRC's mandate regarding the TMI/2 cleanup
(_/ operation.
In NUREG 0683 Supplement 2, Table 5.1, it is clearly indicated that the ord y alternative with no of f site or occupational exposure is onsite tank storagit. In Table 5.2, however, which l considers possibic radiologica,. accident im pa c t s , onsite tank storage is shown to have the h:ghest potential accidental offsite im pac t . A reanalysis (see below) of the possible impacts of an accidental release of treated AGW stored in 11,000 gal tanks, based entirely upon the assumptions and methods described in NUREG 0683 Supplemens 2 shows the possible impac t s I of such an accident to be substanticily smaller than the actual impacts of forced evaporation predicted in the same document. If a temporary interdiction of shellfish from the Chesapeake Bay is included in the accident scenario, the calculated total body population dose due to forced evaporation is over 4000 (four thousand) times greater than the possible impact of an accident during onsite storage, page 1
126 page 2 The reanalysis refered to above is as follows: ,,
NU REG 068 3, 3.31: Radiation exposure to the public due to
. release of retreaped AGW (2.'3 million gallons):
14 person-rem to bone (with shellfish comsumption) 11 person-rem to bone (due to shellfish alone) 1.0 person-rem to total body (with shellfish) 0.9 person-rem to total body (shellfish alone) l Prom this it follows that an accidental release of 11,000 gallons would have the following impacts :
0.067 person-rem to bone (with shellfish) 0.053 person-rem to bone (chellfish alone) 0.0048 person-rem to ' total body (with shellfish) l 0.0043 person-rem to total body (shellfish alone)
This should be compared with the predicted doses due .t?
forced evaporation (NUREG 0683 Supplement 2, p3.7 ):
0.2 person-rem to bone 3 person-rem to total body up to 6 person-rem to thyroid Thus the ratio of possible accident-dose during storage to ,
predicted dose due to evaporation is l 3 for population bone-dose (with shellfish) I 600 for population total-body dose (with shellfish)
Finally, it, in the event of an accidental relrase of stored water, there is an organized or spontaneous avoidance of Chesapeake Bay shellfish, the doses due to the release would be reduced to:
0.014 person-rem to bone (no shellfish) 0.0007 person-rem to total body (tio shellfish)
In this case, the ratio of possible accident dose during h storage to predicted dose due to evaporation is:
14 for population bone-dose 4300 for population total body dose The use here of 11,000 gallons for the storage tank capacity follows the example set by the ALSB (Memorandum and order of the ASLB issued 8/25/88, p 15).
O
127 page 3 In addition to substantially lower possible dose to the public O and to GPU employees, retreatment and storage places the public and GPU employees at less risk if, as is likely, there has been an underestimation of the radionuclidic inventory, the rate of aerosol release during forced evaporation, and the effective population dose and its im pac t upon human health, especially with regard to tritium. Storage should e2 tend for at least the length of the post defueling monitored storage period which will apply to the rest of the facility, understood to be at least 30 years. This storage period will have a significant im pac t upon the level of tritium, Sr-90 and Cc-137. Retreatment and storage also takes advantage of inevitable improvements in waste-handling technology over the coming decades.
In summary, I strongly recommend that forced evaporation of over 2 million gallons of radioactive water at TMI Unit 2 nat be permitted. Instead, retreatment of all AGW should be carried out, followed by long-term onsite storage of the treated water in monitored tanka. A decision on the ultimate disposal of t i, e water and its residual radioactvity should be deferred to the end of the storage period in order to exploit the best technology which will be available at that time. Pretreatment of the water now will substantially diminish the impact of any possible leak which may escape detection and secondary containment during the storage period. This approach will avoid the human exposure to radioactivity which will inevitably accompany forced evaporatior., while lowering the im pac t of a possible accidental release of the stored water.
(]}
f.ignedt (O.
Attachment:
biographical sketch of R. Piccioni.
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12' Biographical Sketch:
Dr. Richard Piccioni, PhD, is Senior Staff Scientist at Accord Research and Educational Associates, Inc., a not-for-profit public O .
health research group based in New York City. Ile holds a aoctorate in biophysics from The Rockefeller University, New York, and conducted three years of postdoctoral research at The Rockefeller University, supported by grants from the National Science Foundation (NSF) and the National Institutes of Ilealth (Nill) . Dr. Piccioni was Assistant Professor of Biological Sciences in the City University of New York (CUNY) where his resastch was funded by the US Department of Agriculture (USDA) and the MacArthur Foundation of Chicago.
Under the auspices of Accord Research, Dr. Piccioni submitted comments on the Draft Environmental Impact Statement on TMI ra d wa s t e disposal, and was an expert witness before the ASLB at their hearings on the safety of the Indian Point Nuclear Power Station.
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(,, 1 JUDGE BLOCH: Licensee?
2 MR. BAXTER: Thank you.
3 CROSS EXAMINATION 4 BY MR. BAXTER:
5 Q Dr. Piccioni, in your oral supplement j uJt now you 6 were at one time referring, as I understood it to that PEIS 7 supplement and yet discussing Licensee 's assumptions.
8 What 's your understanding as to who wrote that 9 document?
10 A (Piccioni) This document? Yes, it was prepared 11 by the staff of NRC.
12 Q The NRC?
13 A (Piccioni) Yes.
14 Q So when you were saying. Licensee 's presentati9ns 15 and analyses, you meant the NRC staf f 's?
16 A (Piccioni) Well. I didn 't think there was a l 17 disagreement on this point. But, sure, technically you 're l
18 right, yes. <
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19 Q On page one of your testirony, second paragrcph. .
20 do you have a copy there?
21 A (Piccioni) Right.
22 1 The first sentence of the second part.araph 23 indicittes that and you cite Table 5.1 of PEIS ,supplemen:
24 Nunber Two and you say i+. provides a clear indicstiors that 25 the onsite storage alternative has no offsite or O Heritage Reporting Corporat ion (202) 628-4888
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(,) i occupational ex} sure.
2 Would you turn to that table, please?
3, A (Piccioni) Yes.
4 Q I assume you 're referring to the zeroes that are 5 on the horizontal. last colsmn on that table?
6 A CPiccioni) Yes.
7 Q Isn't there a footnote E that applies to each of 8 those zeroes that indicates that this is only the impact 9 during storage and that disposal in the future would enta!.1 10 additional dose?
11 A (Piccioni) Yes, that 's true.
12 Q But in your presentation, you have not considered 13 any radiological release for the ultimate disposal after 14 storage, is that correct?
ib A (Piccioni) That 's correct . Because you don't .
I 16 know what it will be, because you don't know how loils you 're f 17 going to store the water.
r 18 Q But no matter how long it 's etore, there 's geing i i I 19 to be some radioactivity left, t, n n ' t there, I mean withirt l
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< 20 reason?
21 A (Piccioni) Well, there actually, you see there l
22 are two lusues regarding time. One is decay and the other [
,. 23 is technological improvenent . l 24 And I would agree with the ove 4'l approach here
! 25 that it dcean't seem really to make sei.se for anyone at this ;
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() i point to have to claim an understanding or the ability to 2 predict qJantitatively what those, especially the second ci j 3 those two factors is going to allow in the future.
4 And, but actually I must say that seemed to me to 5 be the approach that was taken by the outbors of this report 6 which is why they didn't put a value down for the future 7 disposal because that is contingent upon all kinds of things l l
8 that are not knowable now. i 9 Q But they certainly didn't indicate that this j
, 10 alternative involves no relesses, did they? I 11 A (Piccioni) They said there would t releases in 12 the future, h 13 Q In terms of what the PEIS sr,ys?
' 14 A (Piccioni) Yes. I would agree with that. I L 15 should have said that in a different way.
$ 16 Q Okay. As you go on to state in your testimony or !
17 page one, you then refer to the Table 5.2 of this PEIS !
l 10 Supplement Nunber Two, where the NRC staf f has presented l 19 estimates of the environmental impacts of radiological
?O accidents. !
21 As I think you discuss in your opening remarks, in l l
22 Table, storage in tanks is alt ernative 3. 5.1 and the i
1 23 accident assu rd there is the failure of all tanks, is that !
24 correct? )
l
- 25 A (Piccioni) Right. l l
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'q Now you decided to re-analyze a storage accident (j i Q 2 based on the failure of an 11.000 gallon tank?
3 A (Piccioni) Yes.
4 Q Now Table 5.2 as you look up to the other 5 alternatives analyzes in several places the effects of a l
6 rupture of an 11.000 gallon tank?
I 7 A (Piccioni) Yes. j 8 Q But you didn't use any of those numbers, did you? l l
9 A (Piccioni) They 're not the appropriate values. I .
10 mean the value which is calculated in Table 5.2 line 3.5.'1
, 11 is based o.1 the release, as it says there, of all of the 12 tanks. the total of the 2.3 million gallons being released. ;
13 effec tually the only one that makes that assumption. ;
O 14 So I made the assumption that was consistent with 15 the other accident scenarios which is that you woulo have 16 smaller tanks as I'm sure one would.
17 JUDGE BLOCH: Dr. Piccioni. I 'm sorry. You didn't 3 '
18 answer the question.
19 THE WITNESS: (Piccioni) Maybe I didn't 20 understand the question.
21 JUDGE BLOCH: He said there were several in this 22 table that had 11.000 gallon examples and you didn 't 'se 23 those.
24 BY MR. BAXTER:
25 Q In terms of your dose nurbers, you didn 't adopt
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() i the dose estimates that the staff has for the failure of 2 11,000 gallon tanks on that page, is that correct?
I 3 A (Piccioni) Well, the reason I 'm pausing is l
'4 because it may be now that you mention it that some of these 5 impacts might turn out to be the same as I calculated 6 because you end up releasing the same amount of !
7 radioactivity as if you, As stored the water on site in l
8 11,000 gallon tanks and B re-treated it. ,
9 But the specific alternative that 's being 10 considered in the other rows of that column it different [
3 11 from onsite storage after pre-treatment.
12 So I don't quite see why I would have used any of -
13 those, forced evaporation solidification with retention on 14 site, for example, that 's not the alternative that I am ;
15 considering.
16 I'm talking about pre-treating the water and l 17 storing it.
18 Q Ir 4 t because of the pre-treatment that you didn 't :
19 use these numbers?
l 20 A (Piccioni) There are a number of differences.
21 Each of them deals with a completely different alternative 1
l 22 from the one that I was considering.
23 I mean I can't do that on the spot here. But if 24 they weren't relative. I don 't see why they would have been 25 relative.
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134 1 )' i Q Well, there are tanks of water f ailing. It 2 doesn 't matter wh6t the intent was to deal with the water 3 afterward.
4 They 're each addressing the f ailure of a tank with 5 water in it.
6 A (Piccioni) Right. But what 's in the tank of 7 water -- from case to case --
8 JUDGE BLOCH: Please. instead of arguing, let's 9 ask questions.
10 uY MR. BAXTER:
11 Q This is not a point worth spending a lot of time 12 on but at least as the accident is described in that column, 13 they all icok identical to me. What is the difference in 14 the accidents that are identified for those various 15 alternatives?
16 A (Piccioni) Oh, okay. Okay. Well, i'm not 17 comfortable with this because I don't want to do a 18 calculation in my head sitting here that I haven 't done
'9 before.
20 I mean what I did is extremely straiEhtforward. I 21 would have to look at each of these to see how it is 22 different.
23 It 's not the same assumptions that are going into 24 it. okay.
25 JUDGE BLOCH: Dr. Piccioni?
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135 E( ) 1 THE WITNESS: (Piccioni) Yes.
2 JUDGE BLOCH: As I read the assumptions, they 're 3 all the same.
4 THE WITNESS: (Piccioni) Yes. ,
5 JUDGE BLOCH: Tell me if I'm right or wrong. i 6 THE WITNESS: (Piccioni) All right. 11. yes.
7 JUDGE BLOCH The assumptions are, 11,000 gallon ;
8 tank ruptures.
Yes.
9 THE WITNESS: CPiccioni) 4 10 JUDGE BLOCH: Untreated water flows into 11 Susquehanna River.
12 THE WITNESS: (Piccioni) Yes.
t 13 JUDGE BLOCH: That 's the whole osuumption and all 14 of the amounts that are estimated are identical for that. 7 15 THE WITNESS: (Piccioni) Yes. That 's pretty 16 clear, yes.
17 JUDGE BLOCH: Why is it that you chose either to 18 use that number or not to use it?
19 THE WITNESS: (Piccioni) Re-treatment is 20 definitely one of the differences. And the other 21 difference, which I consider. i mean I outlined all of these 22 as included in the calculation in making the three different 23 assumptions.
24 Re-treatnent is definitely one assumption that I 25 make which is not in those att.er rows. And the other is O Heritage Reporting Corporation (202) 628-4888
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(_) 1 that I consider the possibility of shellfish avoidance.
2 BY MR. BAXTER:
3 Q Dr. Piccioni, would you turn to page two of your
'4 testimony. please? Now, as I understand reading your 5 tectimony and your reference to page 3.31 of PEIS Supplement 6 Number Two, you derived your starting point of 14 person-rem 7 bone dose and the one person-rem total body dose from that 4 8 page. 3.31 of the DEIS.
9 And on that page. the NRC etaff is discussing the 10 doses from the short term river discharge citernative, is 11 that correct?
12 A (Piccioni) Yes.
- 13 Q Could we turn to that page, please? Actually page 14 3.29 where the discussion of short term river discharge 15 begins.
i 16 A (Piccioni) Uh-huh.
! 17 Q Now does it indicace there in the first paragraph 18 under. Alternative 3.4.2 that the staff is analy=ing here n
- 19 situation in which the water, the accident generated water.
20 would be discharged over a period of at least 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />?
21 A (Piccioni) Sure, that*s what it says. yes, uh-22 huh.
23 Q Is that consis+ent, in your view, with an accident 24 scenario involving a tank rupture?
! 25 A (Piccioni) Oh, it doesn 't matter.
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() i Q Why doesn't it metter?
2 A (Piccioni) It doesn't matter because the person-l 3 rem exposure due to the release of the given amount of 4 radioactivity is independent of the rate of release. if you 5 don't consider the possibility of evacuations and [r 6 interdictions and things like that. l i
7 I 'm saying if no one knows ebout it and it j ust t
8 happens, if you release a certain nutber of micro-curies.
9 millicuries, curies or megacuries, given the size of release ;
10 the rate of that release has no impact on the total number 11 of person-rene of population exposure that will result. ;
12 This is key to the consideration of this whole p 1 13 issue. j l ( 14 Q Dr. Piccioni, we 're talking about the liquid
- iS pathway, aren't we? r 1
1 16 A (Piccioni) Yes.
17 Q How do people get this dose? l 18 A (Piccioni) Through the liquid pathway? [
t 19 Q Yes.
l 20 A (Piccioni) By drinking the water primarily and l T
21 then there 's also +his issue of contamination of fish and j 2 ?, shellfish. !
23 Q And it 's your testinony that the concentration of 24 the radioactivity in the water and in the marine life that ;
25 are going to be consumed has no impset on the dosage that [
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th 1 the humans are going to receive? I 2 A (Piccioni) Ah, you have to take concentration. l J
3 Let's say for example, an easier example. _ let 's j ust ;
i 4 consider drinking water for the moment. Okay? l.
5 If you release into the river a certain number of l t
6 curies of radioactivity and suppose you do it all at once l 7 and you are downstream sampling the concentration of i 8 radioactivity in the water. then indeed, there will be this l l 9 period of time of a certain duration in which there will be {
) 10 a level of radioactivity in the water you can measure.
11 If you release that same total curie amount ;
12 slowly, then you will have a lower concentration of i
13 radionuclides in the drinking water but over a longer period i
14 of t irr.e.
f I
- 15 You see. because you have the river flow which is l l 16 so many liters per day. And you have your release in curies ,
17 pre day. f i
18 Well. you teke the ratio of those and the days i
j 19 cancels out. :
20 And since what mat ters, you see, is the total l l
4 21 amount of radioactivity which is consumed by people f 22 downstream.
23 It is except for small effects at half life.
24 essentially independent of the rate a+. which this material 25 is released into the water supply because it being released O Heritage Re,arting Corporation (202) 628-4888
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() i into the rive.
2 Because the total integrated exposure, integrated 3 consumption, time integrated consumption of radioactivity 4 will be the same.
5 It 's a very fundamental issue actually.
6 Q On page 3.30 does it not indicate also in 7 paragraph 3.4.2.1. the third paragraph there that under this j 8 alternative the water is going to be diluted by a factor of 9 120 prior to its release to the river?
10 A (Piccioni) Yes. J 11 Q And again, is that consistent in your view with an ,
12 accident scenario in the analysis of a tank rupture? ;
a 13 A (Piccioni) Yes. Again it doesn't matter. I 14 Because the question is, how many curies are you putting j iS into the river, i
16 Q Isn't the question how many doses are going to be 17 received by a person?
l !
18 A (Piccioni) That's the ultimate, by how many j 19 people, right? Bat that 's the ultimate. The ultimate [
20 question is. the number of person-rems. Okay?
I I
- 21 And that is going to be a product of the series of 22 terms. And the term that we 're talking about here is at one 23 end is the number of curies you put in.
24 All of the other terms of the dilution or the rate 25 that you put it in are all going to cancel out because i
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() i you'll end up eventually that a certain f raction of the 2 curies that you add to the water will be consumed by people.
3 And that number is not influenced by the rate at 4 which you put it in or anything you do to dilute the S effluent into the river.
6 The only thing you could do to change it is to 7 massively increase the flow of the river, for example. That 8 would influence it. If you have people avoid the water.
9 that would influence it.
10 But the consumption, the ultimate consumption of 11 radioactivity is a certain fraction of the radiom tivity 12 that you add to the river and the rate at which you put it 13 in and your dilution of that effluent as it goes into the 14 river does not matter.
15 And I should point out that this is a rather 16 crucial point because the regulatory controls on effluents, 17 very frequently not always, but very frequently deal with 18 issues such as concentration which really serve the -- have 19 the effect of letting us see less clearly what the impact 20 will be.
21 Because really what matteJe is the total curie 22 release.
23 JUDGE BLOCH: I think I 've heard that. I've heard 24 that before. Mr. Baxter, would you clarify for me why we 're 25 in 4.he section on river discharge?
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() 1 MR. BAXTER: Because at the top of Dr. Piccioni 's 2 testimony on page two he begins this entire calculation by -
3 using the doses from page 3.31 which is the short term river 4 discharge as a basis for calculating a release from an 5 11.000 gallon tank. !
7 6 JUDGE BLOCH: And I take it that 's because you 're 7 assuming the same kind of treatment of the water before :
r 8 storage ss you do for river discharge?
9 THE WITNESS: (Piccioni) Yes.
f 10 JUDGE BLOCH: Okay. Thank you. l l
11 BY MR. BAXTER:
12 Q Okay. Let 's move to your assumption of the 11.000 ,
13 gallon tank. You indicate at the bottom of page two that 14 the use of an 11.000 gallon tank follows the example set by ,
15 the Board on page 15 of their memorandum and order. Do you j 16 have a copy of that with you? {
4 I forgot to bring l 17 A (Piccioni) You know. I don 't.
18 that with me of all things. .
19 (Pause.) ;
20 j 21 [
r 22 j i
23 !
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() 1 THE WITNESS: (Piccioni) I'm awfully sorry for 2 this delay. I just -- it 's probably sitting on my desk at 3 home.
4 JUDGE BLOCH: /5e 'tenrd is aware and we 'd like the f 5 witness to know that Mr. Baxter believes the Board made a 6 mistake in citing the 11.000 gallon tank, that we should 7 have cited the much larger tank. ;
i 8 And we haven't ruled on that. But that is the r
9 contention of the Licensee.
10 THE WITNESS: (Piccioni) Yes. I can understanti ,
t 11 why they would be saying that. Right. Okay. You know 12 maybe it 's j ust because of the -- I don't see the part that 13 I was referring. '
14 BY MR. LAXTER:
15 Q You cite page 15 at the bottom of page two of your !
16 testimony.
P 17 A (Piccioni) Well. I don't have a page 15 in my f l
18 hand here, i 19 Q Do you have it now? ,
20 A (Piccioni) No. All I have. I have some notes !
l 21 somewhere from -- yes, here we are. Right. Page 15 Okay. [
l 22 Thank you.
23 Q The Board here is discussing the accident scenario :
t L
24 for the onsite storage alternative. And as a reference for l
r 25 the doses that the Board gives. it cites about nine lines !
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() 1 down. 10 lines down, pages 3. 8 and 3. 9 PEIS Supplement 2 Number Two. Did you check that reference before you adopted 3 this 11.000 callon tank asuumption?
4 A (Piccioni) Hold on. Oh, oh. you mean -- yes. I 5 did. And I noted the dif ference in the assumption.
6 Q What is that?
7 A (Piccioni) You know. I just want to be awfully
- 8 careful about this because -- you are asking ne if I 9 referred to Section --
10 Q Page 3. 6 area 3. 9.
11 A (Piccioni) Okay.
1
! 12 Q The reference given by the Board.
13 Does it look familiar to you? Have you read it?
i O 14 A (Piccioni) Sure, I mean, sure, the whole document i
15 is reasonably familiar to me.
16 Q I'm simply asking at this point whether you simply 17 relied upon the Board 's statement or whether you looked up 18 this reference.
19 A (Piccioni) I relied upon the Board's statement as 20 I indicated in ny testimony.
] 21 Q Now that you have pages 3.8 and 3.9 before you.
22 are they the discussion of the accident analysis for the !
23 evaporation proposal? !
1 24 , A (Piccioni) Yes. Yes. Right. l
, 25 JUDGE BLOCH: The Board concurs.
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() 1 BY MR. BAXTER:
i 2 Q So the assumption if one were following this l
[
3 assumption, it would be that an 11,000 gallon tank should be j 4 used to analyze an evaporation proposal accident? !
i 5 .. (Piccioni) Yes.
l 6 Q Not the onsite storage?
4 4
l i
7 A (Piccioni) Yes. Except I mean. I disagree with i 8 that assumption, that 's all. And I follow an example for a 9 cmaller tank that I think would clearly be more prudent to l 10 use. [
! 11 0, You're disagreeing with it this morning for the
, 12 first time now that you 're aware -- {
13 A (Piccioni) No, no. no. No, no. r.o . I 'm saying l
14 in my testimony I clearly disagree with the assumption in [
f 15 the evaluation of an onsite storage accident that the full I 16 2.3 million gallons would necessarily all be promptly !
17 discharged into the river. :
1 18 And as an alternative. I used in my celeulation ;
19 and explicitly cited consideration of an 11.000 gallon l l
20 container. t E
21 Essentially I relied upon the Board's mention of l 22 that container was that storage in such containers was a j i
23 feasible possibility, i 24 Q But now that you 've seen that the Board was 25 instead talking about a tank used during the evaporation
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.() i preposal, what is the basis for your suggestion that an 2 11.000 gallon tank is a reasonable tank to look at for an
, 3 accident analysis for the onsite storage?
4 JUDGE BLOCH: Mr. Baxter. my sense is that you 're 5 talking in cross purposes. The alternative I understand is l
6 being laid out now. is that you hold things on site. that l l
7 everything be dumped into 11.000 gallon tanks.
8 I have no idea what the cost of that is, but !
4 9 that 's what Mr. Piccioni is suggesting that you have a whole j 10 different system of storage on site, transferring everything 11 into smaller tanks. Am I correct. Dr. Piccioni?
4 12 THE WITNESS: (Piccioni) That 's right. That 's 13 right.
14 "
.JDGE BLOCH: Da you know the cost of that?
l 15 THE WITNESS: (l'iccioni) It would probably be 16 significant.
1 17 JUDGE BLOCH: So, if I hear you correctly, it 's 18 that you don't know the cost of that, is that correct?
19 THE WITNESS: (Piccioni) That 's right. I am not.
20 I am not -- my training is in bio-physics. It is not in 21 nuclear engineering and I am not in a position to come up 22 with a cost estimate of producing 11.000 gallon tanks.
23 JUDGE BLOCH: I take it also that the exposure 24 implications for the workers in making those transfers also 25 is something you haven 't figured out, is that correct?
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() 1 THE WITNESS: (Piccioni) That 's true. l 2 JUDGE BLOCH: Thank you.
3 BY MR. BAXTER: l 4 Q I think I was following but let me pursue. I 'm 5 simply trying to clarify what the basis is for your 11,000 l
6 gallor assumption. ;
7 It 's now not the Board 's analysis and it 's not the i 8 PEIS. This is your own independent conclusion that an 9 11,000 gallon tank is the appropriate tank to use for onsite 10 storage?
11 A (Piccioni) Well, you see it is now. It remains, 12 my use of that value remains that. that value won used in 13 the nenorandu.a and order from the Board.
14 That 's why I used that value.
15 Q But having just agreed that it is an error, you 're 16 not using it now are you?
17 A (Piccioni) Okay. No, this is a legal question 18 that I don 't quite understand.
19 Q I think we --
20 A (Piccioni) My testimony is here and it has that 21 citation. I can 't change the words on the page. Are you 22 askinE me now if I feel dif ferently about the calculation or 23 if I would like to redo the calculation knowing that this 24 was an error? Is that the question?
25 Q No. I'm not asking you to redo any calculations.
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() 1 A (Piccioni) Yes. Yes.
2 JUDGE BLOCH: Mr. Baxter. I 'm not understanding i
3 the question either. Could you explain it so that I can j 4 understand what 's happening here.
5 He and the Board have both acknowledged that using .
6 that estimate in the context we used it was an error. It 's l I
7 an evaporation estimate. He stated that it was. I believe.
e 8 Is that your problem? You don't think he stated 7
9 that? f 1 10 MR. BAXTER: That 's correct. j I, 11 BY MR. BAXTER:
, 12 Q All right. Mr. Piccioni, in the context in which 13 the Board used the 11.000 tank. gallon estimate, is it your l 14 belief that the Board was in error? l 15 A (Piccioni) No. Because storage in 11.000 gallon j 16 tanks is feasible. j a
17 But that was not what was being proposed at that Q f 18 time, is thLt correct? They were much larger tanks? f 19 A (Piccioni) I don 't -- I 'm not -- I wasn 't privy l
20 to this correction and whatever went on here. I gather that 21 you now think that 11.000 gallons was too small.
22 Q Well, the tanks that were proposed by the Licensee 23 were not 11. 000 gallon tanks.
94 A (Piccioni) Okay.
l 25 Q They were much larger.
i i
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() i A (Piccioni) Yes.
2 Q Were you aware of that in reading the PEIS?
3 A (Piccioni) This is the first I hear -- oh, you 4 mean that the proposed were larger? Yes, yes.
5 Q For the no action alternative?
6 A (Piccioni) Yes, yes. Well, let 's put it this 7 way. I understocd that the basis of their calculation for 8 the consequence of an accident was the release of the entire 1
9 2.3 million gallons all at once which clearly suggests to me j 10 that it 's all in one enormous I mean tank or whatever the
- 11 scenario used for that full release.
12 And by using a smaller vessel for storage, the 13 fact is that such a release would beconc much, much less 14 probable, f 15 I used the 11.000 gallons because of its 16 appearance in that memorandum and order. That 's why I used i
j 17 tha' value and it was my basis for using that value.
t 18 Obviously the consequences of release of a larger 19 tank go up proportion to its volune.
I 20 Q But we have established that the 11.000 gallon
! 21 figure from the Board's order came from a section of the l 22 PEIS that was assessing the evaporation proposal?
l 23 A (Piccioni) 'le s , because that 11.000 gallons is a j 24 particular tank that they 're talking about which is 4
l 25 connected with the evaporator, yes. That's right.
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() i So it becomes an implication --
2 JUDGE BLOCH: Stop, please. Mr. Piccioni. what I 3 prefer is that you just answer the question. If there 's 4 something you have to do by way of rehabilitation later.
5 make a little note of it because we 're getting repetitious.
6 THE WITNESSx (Piccioni) Okay.
7 JUDGE BLOCH: Just answer the question.
8 THE WITNESS: (Piccioni) Fine.
9 JUDGE BLOCH: You don 't have to def end it each 10 time.
11 THE WITNESS: (Piccioni .1 Fine.
I 12 JUDGE BLOCH: Just say. yes.
13 THE WITNESS: (Piccioni) All right.
1 14 JUDGE BLOCH: And we can go on to something else.
15 THE WITNESS: (Piccioni) Okay. Fine.
16 BY MR. BAXTER:
17 Q Have you considered. Judge Bloch already asked you 18 about cost, have you considered the feasibility in terms of 19 land connitnent at the Three Mile Island site to locate the 20 209 11,000 gallon tanks that would be necessary?
21 A (Piccioni) No.
22 MR. BAXTER: Excuse me just a second.
23 BY MR. BAXTER:
24 Q Dr. Piccioni, would you agree that there will be 25 come occupational exposure involved in the pre-treatment of O Heritage Reporting Corporation (202) 628-4888
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() i the water as your alternative suggests?
l 2 A (Piccioni) Yes. It's my understanding that there 1
3 would be, there would be some, yes. But I didn't 4 specifically attempt to re-evaluate that or verify that, but !
i 5 my understanding, yes.
f G MR. BAXTER: I have no other gaestions. Thank l 7 you.
8 MR. STEPHEN LEWIS: If I may have a moment? '
- e i 9 JUDGE Bl.OCH
- Sure. -
10 MR. STEPHEN LEWIS: To go through my questions, a j 11 number of which have been covered by the Licensee 's l 12 questioning -- !
JUDGE BLOCH: Okay. I
)i 13 I like to take short breaks.
i 14 But what 's the length of a short break? !
i 15 MR. STEPHEN LEWIS: Five minutes. Five minutes is ;
16 fine. t i !
l 17 JUDGE BLOCH: Okay. Well. let 's make it 10 !
l i f 18 minutes so that people can have are opportunity to do whst ;
i l 19 they might like to do.
I 20 It 's 2:25 on my watch. It will be 2:35 when we 're 21 in session, exactly.
t 1
22 (Whereupon, a short recess was taken.) f
)
23 JUDGE BLOCH: Mr. Lewis. I I [
24 MR. STEPHEN LEWIS: Mr. Chairman, our areas of j 8
- ', . 25 cross examination have been adequately covered by the l l
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() 1 licensee 's cross examination and we hcVe no questions.
2 JUDGE BLOCH: Thank ycu. Is there any redirect?
3 MS. SKOLNIK: Yes. I 4 REDIRECT EXAMINATION 5 BY MS. SKOLNIK:
6 Q Dr. Piccioni, is it true to say that you didn't 7 calculate the dose from eventual disposal of the water
, 8 because the NRC themselves defined the no action l
i 9 alternative. PEIS?
I
! 10 JUDGE BLOCH: Ms. Skolnik, stop, please.
11 MS. SKOLNIK Yes.
l l 12 JUDGE BLOCH: You 're not to testif y. You 're to l 13 ask questions.
( 14 MS. SKOLNIK: I was going to ask a question. I 15 began my question with, is it true?
16 JUDGE BLOCH: Yes. I know. But what you 're doing 17 is you 're putting a lot into the witness ' mouth. If you 18 could just ask him a question.
19 I know you 're not a lawyer.
20 MS. SKOLNIK Yes.
21 JUDGE BLOCH: But see if you can just see how you 22 could ask a question so that it will come out from him.
23 BY MS. SKOLNIK:
24 Q Dr. Piccioni, what is your understanding of the 25 NRC 's definition of the no action alternative?
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() 1 MR. BAXTER: Obj ec t ion, Mr. Chairman. That is not 2 an area that was covered during the cross examination. It 's 3 improper redirect.
4 JUDGE BLOCH: Could you tell me why you think it 's 5 relevant since he's testifying about his own no action 6 alternative. not about the NRC 's? t 7 He has fairly clearly laid out that he wants {;
8 11,000 gallon tanks and he wants re-processing before and he ,
9 wants to leave open as to what 's going to happen in 30 10 years. .
.i Why is it relevant 'o ask him his understanding of 12 the NRC 's no action alternative? He 's not testifying about t I
13 that.
O 14 MS. $KOLNIX: Because when he 's speaking about the 15 no action alternative, obviously the comparison arises I
[
16 between his and the NRC 's.
17 JUDGE BLOCH: No. The only comperison that the 18 Board is going to draw is between his alternative and the ,
i 19 Licensee 's alternative which is ovaporation. -
t 20 If you 're not relying on the NRC 's alternative, ,
21 i t 's irrelevant. !
22 MS. SKOLNIK I guess I 'm at a loss, Judge Bloch, f 23 because I know my contention two was admitted according to 24 your order of August 25. ,
25 You did say on that, this is why I am confused. ;
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() 1 JUDGE BLOCH: We are conducting this hearing --
2 one of the major purposes is to compare your contention 3 about the no action alternative to the applicant 's.
4 But if you'd like to refer to a specific part of 5 our order, you may do that.
6 MS. SKOLNIK: Yes, my contention to --
7 JUDGE BLOCH: Page one on our order you should
\
8 refer to right now. ,
9 MS. SKOLNIK Pardon? I 'm sorry. Page 22.
10 JUDGE PARIS: Order dated when?
11 JUDGE BLOCH: The August 25 order, correct?
12 MS. SKOLNIX: Yes. Your consideration of 13 contention two starts on page 10 and ends on 22 with the 14 statement. "therefore we conclude that the portion of 15 Contention Two relating to the no action alternative must be 16 litigated. Licensee 's motion for summary disposition of 17 Contention Two to that extens is denied".
18 And my contention states. "that the NRC. the PEIS 19 f ails to comply with the requirements of the National 20 Environmental Police Act. The NRC f ails to conduct 21 conclusive risk benefit analysis of the no action 22 alternstive".
23 JUDGE BLOCH: Ms. Skolnik. you're correct. The 24 question is, are you going to be contending that the old no 25 action alternative, the one defined by the NRC is superior O Heritage Reporting Corporation (202) 628-4888
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() i to the evaporation alternative or are you now contending 2 that the one that Dr. Piccioni is testifying about is 3 superior or both?
. 4 MS. SKOLNIKt I think it 's a matter of both. I 'm 5 contending that the NRC 's evaluation of the no action 6 alternative is inadequate in order for uu to make a proper 7 evaluation of that alternative.
8 And, to the best of our ability we are going to 9 present as much as we can to show that the no action 10 alternative is preferable to the Licensee 's evaporation 11 proposal which we will also show is not in keeping with a 12 safe and expeditious cleanup which indeed will release 13 radioactivity into the environment which will cause 14 exposure.
15 JUDGE BLOCH: It may not have been clear to you at 16 the time we wrote it. 'Ju t I have said it today. The purpose 17 of litigating the ne action alternative is for you to show 18 that it 's superior to the applicant 's alternative. That 's 19 the only purpos9 20 You must show that there is a reason for the 21 applicants to take the burden of proof on something.
22 Now you have done that to some extent with Mr.
23 Piccioni 's t est inony. You 've laid out a form of the no 24 action alternative which y J apparently are Contending is 25 superior, l O heritage Reporting Corporation (202) 628-4888
155 h i Now, if you 're going to argue that another form is 2 also superior, you could litigate that. but to show that 3 Mr. Piccioni 's alternative is dif f erent to some extent than 4 the st af f 's isn 't going to get you anywhere.
S It is different. We know that. Wel1, you 're 6 having difficulty understanding me. I can see that. Ennt 7 is the problem
- 8 MS. SKOLNIK: The dif ficulty rrost ly in in the 9 burden that you are placing on tne to bring forth an 10 alternative.
11 When according to the regulations, the burden is 12 on the applicant to go forward and show to resolve the 13 contentions that you have admitted into these hearings.
14 JUDGE PLOCH: I 've laid it out as clearly as I iS can. You can ehow an elternattve 1ike you have through Dr.
16 Piccioni. Then the burden of proof is on the applicants to 17 show that this is not an obviously ::uperior alternative.
18 That'n their burden, to show that this alternative 19 in not obviously superior. If you have another alternative
?O that you 're going to show by evidence, is an acceptable 21 al t ernat ive and the eoplicant s will have to show that they
?? have carrisi the burden of proof that it 's not an obviously 23 superior alternative.
24 Attacking the st af f 's environmental statement at 25 t hi s po i n t is irrelevant. I 've said that and I nean it.
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() i MS. SKOLNIK: I will go forward and show to the 2 best of our ability that the no action alternative is 3 superior to the Licensee 's evaporation proposal.
4 JUDGE BLOCH: Okay. And the burden of proof on b that will be on them but you're going to show what your l 6 alternative is that they 're going to have to denonstrate is t
7 not o tously superior. So, please, proceed on that basis.
8 BY MS. SKOLNIK:
I 9 Q Dr. Piccioni. could you clarify -- when you talk l
i 10 about pre-treatment, could you clarify at what point that l
l 11 pre-treatnent would be given to the water? What would the 12 status of the water be, the radionuclide content of the 13 water be before you pre-treat it again? Does that make 14 sense?
15 A (Piccioni) The pre-treatment that I refer to --
16 I'm sure we 're going to confuse any future historian who is 17 trying to make sense of this by saying, pre-treatment and 18 r e- t re at me nt .
19 But what I mean is --
20 JUDGE BLOCH: We 're no' interested in historians 21 at n '$ 1. That 's a decision we 're going to make.
22 THE WITNESS: CPiccioni) Okay. Fine. The 23 radionuclidic content of the water, everyone seems to agree.
24 can be decreased by treatment with SDS and EPICOR 25 technology.
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() 1 And the assumptions that I made in my calculation 2 of the possible consequences of a possible accidental 3 release are that, that water be treated in the way in which 4 it is proposed to be treated prior to evaporation, making 5 the same assumption that --
6 JUDGE BLOCH: I think you just micspoke. Did you !
7 mean prior to evaporation?
8 THE WITNESS (Piccioni) Yes. Right. Prior to 9 evaporation, my understanding is that there is a plan to 10 treat the water so as to decrease the radionuclidic content 11 of things like strontium 90 by about ten-fold.
12 JUDGE BLOCH: No. A thousand-fold.
13 THE WITNESS: (Piccioni) The thousand-fold comer 14 during the actual evaporation itse 4
- my understanding 15 that particulate --
16 JUDGE BLOCH: Okay. I don 't. But you can clarify 17 that later. But I believe tho' fou were using not the 18 evaporat ion pre-t reat ment , but the river discharge pre-19 treatment. Are you surc you were using the evaporation pre-20 treatment and not tF' river discharge pre-treatment?
21 THE WITNESS (Piccioni) Well. i t 's my 22 understanding that there is a --
23 JUDGE BLOCH: Well, which way is it? Why don 't 24 you check your --
25 THE WITNESS: (Piccioni) Oh, I thouEht the two O Heritage Reporting Corporation (202) 628-4888
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4 158 e
i were the same. That is that there is a trestment which has 2 been proposed of the water which is to precede evaporation.
3 And in evaluating the various etternatives, that 4 pre-treatment was also assumed to precede direct river 5 discharge.
6 And I, dif ferent from the staf f, assumc1 that.
7 that pre-treatment would also precede oncite stcrags.
8 So then when I evaluate an accident of the stored 9 water, the consequences are lower becauss the water has been 10 treated previously as everyone seems to agree it should be.
11 JUDGE BLOCH: Just to clarify, are you also 12 plannint to draw of f the bottoms and ship them to Hanford?
13 THE WITNESS: (Piccioni) After that procedure.
14 JUDG2 BLUCH: Before this no action alternative.
15 Are you crawhig of f the solid radioactive wastes in the form 16 of bottoms and shipping them for storage?
17 THE WITNESS: (Piccioni) There are no bottoms 18 without evaporation, *'here
. would be the radioact .?ve 19 filtration ma*erials l 20 JUDGE LLOCH: Okay. And those would be from the 21 LPICOR and SD." syst ems?
22 THE WITNESS: (Piccioni) Yes. That 's a.1 the 23 sano J the evaporation so everything is *.he same as 24 evi,poration in terms of what has to be done, worker exposure 25 and so un except that instead of evaporating this treated O Herrtege Reporting Corporation (202) 623-4888 t
Y 159
( ) 1 water, you are storing it in numerous container onsite and 2 monitoring it for an indefinite period.
3- MS. SK0LNIX: That 's all .
4 MR. BAXTER: Nothing further.
5 MR. STEPHEN LEWIS: I have a question that arises 6 out of the redirect.
7 CROSS EXAMINATION 8 BY MR. STEPHEN LEWIS:
9 Q Dr. Piccioni. when you speak about pre-treatment 10 through SDb and EPICOR 2 and talk in terms of everybody 11 agreeing that further pre-treatment should be done. I 'd like 12 to direct your attention to table 2.2 of PEIS Supplement 13 Number Two on page 2.3?
(D
'/ 14 A (Piccioni) Yes.
15 Q Is your proposal for pre-treatment through the SDS 16 and EPICOR 2 systems equivalent to the achievable column in 17 that table?
18 A (Piccioni) Yes, that 's right, yes.
19 MR. STEPHEN LEWIS: Thank you. That 's all.
20 JUDGE BLOCH: Ms. Skolnik, you would be allowed 21 redirect only limited to this particular question by Mr. ,
22 Lewis.
23 MS. SKOLNIK: No, I don 't have another question.
24 JUDGE BLOCH: Thank you. Dr. Piccioni, thank you 2f very much.
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( ,, 1 MS. SKOLNIK: Thank you, Dr._Piccioni.
2 JUDGE BLOCH: You 're excused f rom the stand.
3 (Whereupon, the witness was excused.)
4 MR. BAXTER: Licensee calls Kerry L. Harner and 5 Dr. Kenneth J. Hofstetter.
6 Gentlemen, would you each state your name for the 7 record, please?
8 THE WITNESS: (Harner) My name is Kerry Harner.
9 THE WITNESS: (Hofstetter) I 'm Kenneth 10 Hofstetter.
11 JUDGE BLOCH: I 'd like the witnesses to know that 12 we welcome them and that the testimony that they're about to 13 give should be the truth, the whole truth, and nothing but O
\- the truth and that their testimony is subj ect to possible 14 15 penal ty for perjury.
16 Do you both understand that?
17 THE WITNESS: (Hofstetter) Yes. <
1 ^. THE WITNESS: (Herner) Yes.
19 JUDGE BLOCH: Let the record indicate .that they 20 both said that they did. Thank you.
21 Whereupon.
22 KERRY HARNER 23 KENNETH HOFSTETTER 24 having been first duly sworn, were called as witnesses
(
25 herein and were examined and testified as follows:
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() 1 DIRECT EXAMINATION 2 BY MR. BAXTER:
3 Q Gentlemen. I refer you to a document that bears 4 the caption of this proceeding. It 's date October 11, 1988 5 entitled, "Licensee 's Testinony of Kerry L. Harner and ')r.
6 Kenneth J. Hofstetter on Sampling and Analysis of the AGW, 7 paren (Contentions 3 and 4Cb)), closed paren", consisting of 8 18 pages of questions and answers, one table and two 9 attachments.
10 Does this represent the testimony prepared by you 11 or under your supervision for presentation at this hearing?
12 Mr. Harner?
13 A (Harner) Yes, it does.
14 Q Dr. Hofstetter?
15 A (Hofstetter) Yes, it does.
16 Q Do either of you have any changes or corrections 17 to make to your testimony?
18 A (Harner) No , not at this time.
19 A (Hofstetter) No. I don 't.
20 Q Is your testimony true and accurate to the best of 21 your knowledge and belief?
22 A (Hofstetter) Yes, it is.
23 A CHarner) Yes.
24 MR. BAXTER: Mr. Chairman. I move then that the 25 testimony be received into evidence and incorporated into O Heritage Reporting Corporation (202) 628-4888
,4 162
[) i the transcr as if read.
2 JUDGE BLOCH: Are there any objections?
3 MR. STEPHEN LEWIS: No obj ection f rom staf f.
4 MS. SKOLNIX: No obj ection.
5 JUDGE BLOCH: Does the entire document ac 6 originclly submitted to be bound in?
7 MR. BAX7ER: Yes, please.
8 JUDGE BLOCH: Okay. Then the Board orders that 9 the entire document shall be considered testimony and shall 10 be bound into the record.
11 MR. BAXTER: And the Court --
12 JUDGE BLOCH: Have you handed r, copy -- -
13 MR. BAXTER: The Court reporter has a copy and 14 we 've also prov.i.ded some extra copies for any members of the 15 public who would like to have one. The witnesses are 16 available for cross examination.
17 (The joint testimony of Kerry 18 Harner and Kenneth Hofstetter i 19 on sampling and analysis of 20 the AGW, contentions 3 e.nd 21 4(b). is inserted into the 22 record and follows:)
23 24 25 O Heritage Reporting Corporation (202) 628-4888
163
-(M
%f detober 11, 1988
' UNITED STATES OF AMERICA NUCLEAR REGUT ATORY CCA4 MISSION BEFORE THE_ ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) . ,
)
GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA f
) (Disposal of Accident-(Three Mile Island Nuclear ) Generat34 Water) -
Station, Unit 2) )
)
LICENSEE'S TESTIMONY OF KERRY L. HARNER AND DR. KENNETH J. HOFSTETTER ON SAMPLING AND ANALYSIS OF THE AGW (CONTENTIONS 3 and 4b)
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164' G I
("x Q.1 Please state _your names.
.x)
A.1 (KLH) Kerry L. Harner.
(KJH) Kenneth J. Hofstetter.
Q.2 Mr. Harner, by.whom are you employed, and what is your position?
A.2 (KLH) I am employed by GPU Nuclear Corporation
("GPUN") at Three Mile Island Nuclear Station, Unit 2 ("TMI-2") .
as Radiological Chemistry Manager.
Q.3 Dr. Hofstetter, by whom are you employed, and what is your position?
A.3 (KJH) I am employed by E.I. du Pont de Nemours & Co.
as a research staff chemist in the Environmental Technology Divi-(]) sion of the .9avannah River Laboratory.
Q.4 Mr. Harner, please summarize your professional qualifi-cations and experience relevant to this testimony.
A.4 (KLH) I have a B.S. degree in Chemistry, and I am a licensed Wastewater Treatment Plant Operator. Since 1974, I have been employed by G?UN (and its predecessor Metropolitan Edison Company) in a variety of positions involving plant chemistry at TMI-1 and TMI-2. At the present time, my responsibilities in-clude providing chemical and radiochemical technical expertise to !
all TMI-2 projects supporting defueling, plant operations, radwaste processing, and accident-generated water ("AGW") dispos-al. A complete statement of my professional qualifications is appended as Attachment 1 to this testimony.
165
() Q.5 Dr. Hofstetter, please summarize your professional qualifications and experience relevant to this testimony.
A.5 (KJH) I have an A.B. degree, and a Ph.D. degree in G?>mistry from Purdue University. From 1967 to 1969, I did post-coctoral research in the Chemistry Department at Texas A & M Uni-versity. I'was an Assistant Professor teaching undergraduate courses in general and physical chemistry, and graduate courses in radiochemistry and nuclear chemistry, for five years at the University of Kentucky. From 1974 to 1980, I was a Radiochemistry Supervisor for the Allied-General Nuclear Services nuclear fuel reprocessing plant at Barnwell, South Carolina.
From 1980 to November, 1987, I was employed by GPUN in radiochemistry support positions at TMI-2. As Supervisor of
() Radiochemistry, I set up and managed the radiochemistry la-boratories to support the decontamination and defueling of TMI-2.
I developed most of the radiochemical analysis procedures in use at TMI-2. As Radiochemical Engineering Supervisor, I provided technical direction for all liquid radwaste processing opera-tions, including 3DS, EPICOR and RCS processing. I monitored the chemintry status of the plant, overviewed operations of the Chem-istry Department, and provided engineering support for chemistry and sampling activities associated with all recovery projects. I also coordinated off-site analyses and reviewed all the results of such analyses. My present position with Savannah River La-boratories involves the development of equipment to monitor tritium at environmental levels for the Department of En.ergy.
O
i 166 A complete statement of my professional qualifications is
.' l appended as Attachment 2 to this testimony.
Q.6 What is the purpose of your testimony?
A.6 (KLH, KJH) The principal purpose of our testimony is to respond to the sub-issue identified for hearing as to whether the tritium content of the AGW has been accurately determined.
While addressing this issue, we will respond to related Joint In-tervenor statements of material facts under Contention 3, and to the single issue left under Contention 4(b). ,
Q.7 How is your testimony organized?
A.7 (KLH, KJH) First, we give GPUN's current estimate of the tritium content of the AGW and explain the basis for GPUN's f]) estimate. Second, we explain why GPUN is confident that its sam-pling data is representative of the entire body of water. Third, we discuss the various sources of data on the AGW. Fourth, we will address the questions presented by the Joint Intervenors concerning the procedures followed during the sampling and analy-sis of the AGW.
Q.8 What is GPUN's estimate of the amount of tritium in the AGW?
A.8 (KLH) It is estimated that the AGW contains no more than 1,020 curies of tritium, which represents an average concen-tration of 1.2E-1 uCi/ml in the projected 2.3 million gallons of AGW.
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Q.9 How was the figure of 1,020 curies of tritium derived?
A.9 (KLH) While the AGW is in a number of storage loca-tions, approximately 73 percent of the AGW is in only four loca-tions. During the preparation of GPUN's July 1986 Report, the most recent sample data from 25 bodies of water was used and the concentration of each body of water was then multiplied by its corresponding tank volume to yield the amount of tritium present >
in each tank.
The total inventories of tritium in each tank were then added to obtain the total curies of tritium in the AGW. The result was a total of 1,180 curies of tritium in the AGW.
Correcting the data in the July 1986 Report to October, 1988, for radioactive decay, a conservative total tritium curie content of 1,020 is estimated. This estimate is conservative be-
{} cause reductions for normal evaporative losses have not been in-cluded. Table 1 contains a summary of the data presented in the 1
July 1986 Report corrected for radioactive decay. The 1.9 mil-lion gallons of AGW present at that time has also been increased to a projected 2.3 million gallons, the maximum quantity of AGW estimated to be processed through the evaporator.
In addition to this 1986 sampling effort, GPUN has since an-alyzed about 5,000 routine samples of the AGW, including measure-mants of tritium which confirm the 1986 data. In conjunction with the routine samples analyzed by the GPUN laboratory, period-ic independent Quality Control analyses are also performed. The QC techniques include round robin, blind, duplicate, replicate,
~'~
(:)
A
i 168
() spiked and split samples. In this way, the accuracy and preci-sion of the entire analytical process is verified frequently. In addition, a sample was analyzed independently by GPUN's chemistry department-and by the U.S. Department of Energy's Radiological and Environmental Sciences Laboratory ("RESL"), Idaho Falls, Idaho, on behalf of the NRC. This analysis, as discussed further below, is consistent with the GPUN data.
Q.10 The Joint Intervenors assert in Material Statement of Fact 4(xii), under Contention 3, that the alleged changing source term of the AGW is particularly relevant to tritium. As an exam-ple, the Joint Intervenors state that Licensee relied on data from PEIS (1981) and EGG-PBS-6798 to get 3,161 curies and 4,231' curies, respectively, while TPO/TMI-043 Rev. 6 (1986) shows that
.O .
the cover inventory of tritium at the time of the accident was
~
.8,794 curies. Given the above data, what conclusions do you draw with respect to thm tritium source term?
A.10 (KJH) there are many computational methods available in the literature which attempt to model what might occur at the time of a reactor accident having failed fuel exposed to its cooling medium or the atmosphere. Each uses a set of assumptions to define the accident. Assumptions are made defining core con-ditions, plant configuration, responses to the event and dura-tion. As would be expected, each estimate is different due to the assumptions made and computational method utilized.
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{} Two of the early estimates of the tritium source term at the time of the TMI-2 accident are 8,794 curies (TPO/TMI-043, Rev. 6, Data Report - Radioactive Waste Management Summary Review) and 4,231 curies (EGG-PBS-6798, TMI-2 Isotopic Inventory Calcula-tions). Both of these estimates are based on postulated condi-tions. ,
Another type of estimate of the TMI-2 accident tritium source term can be made by making an accurate inventory. based on actual conditions at a particular point in time. Again, a calcu-lation is needed to combine the various input data to 'a single number. A tritium source term of 2,910 curies (NUREG-0683, PEIS, 1981) was based on limited sample data and source volumes in September, 1980. The GPUN tritium source term of approximately
() 1,180 curies, reported in July 1986, was based on much more sam-pie data and source volumes from early 1986. The quantity of tritium in the AGW continues to decrease through radioactive decay and evaporative losses.
The estimated upper-bound tritium source term of 1,020 curies, presented by GPUN in July 1986, and by the NRC in Table 2.2, NUREG-0683, Supp. 2, is a projection to October 1, 1988, taking into account only radioactive decay. Since tritium is not produced in the fuel after the fissioning process has stopped, I there has been no tritium added since March, 1979. The amount of ,
tritium present continues to decrease through radioactive decay, while some is released to the atmosphere through normal
() ~~
170
-) evaporation. Therefore, the tritium source term estimate of (G
1,020 curies, which is not corrected for evaporative losses, is a realistic and upper-bound value based on actual laboratory ana-lytical results and storage location volumes of virtually all of the AGW at TMI-2.
Q.11 Joint Intervenors' Material Statement of Fact 4(iv) under Contention 3 a'sserts that it is difficult to acquire'an accurate assessment of the tritium concentration of water. Can you comment on the Joint Intervenors' assertion?
A.11 (KJH) Yes. As a general matter, I would like to point out that determining the concentration of any element in a liquid sample is an intricate process. Tritium analyses are par-ticularly difficult since tritium emits only very low energy beta particles. When determining tritium concentrations in liquids, two major interferences are (1) the ' presence of other beta emit-ting radionuclides in the sample and (2) the variations in counting efficiencies caused by chemical impurities in the sam-ple. Both of these interferences are addressed in TMI-2 Chemis-try Procedure 4212-CHM-3013.81, which was used to analyze all tritium samples taken by GPUN.
The presence of other radionuclides which also emit beta particles (and/or gamma rays) can give a falsely high indication of the amount of tritium present in a sample. Therefore, Chemis-try Procedure 4212-CHM-3013.81 provides methods to remove the in-terfering radionuclides using various methods -- filtration, ion exchange, or flocculation.
O e
171
(~} The second major interference comes from the presence of v
chemical impurities either in the scintillation cocktail or the water sample itself which can produce a falsely low indication of the amount of tritium present in the sample. Chemistry Procedure 4212-CEM-3013.81 provides two methods which control these chemi-cal interferences. Ascorbic acid is added to the sample to react with any organic material and minimize its "fect on the detec-tion efficiency. The other technique requires the addition of a known amount of tritium to a second aliquot of the same sample.
This spiked aliquot is used to determine the exact counting effi-ciency for the detector in the sample matrix. Once this is
, known, the tritium concentration of the unspiked sample can be determined accurately.
Q.12 The NRC assumes that the average concentrations of radionuclides as shown in Table 2.2, of NUREG-0683, Supp. 2 can be reasonably considered a maxim'um. The Joint Intervenors con-tend in Material Statements of Fact 4(viii) and 4(x) under Con-tention 3 that this assumption is invalid, citing as an example the average concentration of tritium in Table 2.2 as 1.3E-1 uCi/ml, while the Technical Specification for Processed Water Disposal lists the tritium concentration in PWST-2 as 2.1 uCi/ml.
This is also the only issue remaining under Contention 4(b).
Please assess the Joint Intervenors' assertion.
A.12 (KLH) I do not agree with the Joint Intervenors' as-sertion.
i 9
l l
l
172 First, the values for radionuclides listed in Table 2.2 of NUREG-0683, Supp. 2 are reasonable projections of concentrations expected to exist in the influent to the eyaporator. I have com-pared the projections of concentration for processed water in Table 2.2 against the RESL analyses of SDS and/or EPICOR II pro-cessed water in PWST-2 on February 24, 1987. The actual analyti-cal results for PWST-2 processed water were lower than the pro-jections of Table 2.2 for all radionuclides except tritium. This demonstrates that the data from Table 2.2 is a reasonable esti-r can be used for dose calculations. Since t'he concen-mate whic tration of tritium is not reduced by water processing, the final concentration in each storage location after processing can be no greater than the tritium influent concentration. Therefore, de-(} pending on which of these locations is being processed, the tritium concentration will vary. The average tritium concentra-tion is then a mathematical calculation and must be done in place of the capability to undertake a physical mixing of the entire AGW volume in a single, homogeneous batch.
Second, the tritium concentrations at issue cannot be com-pared directly to each other. The values are a mixture of actual sample results, as well as estimates calculated using averaged numbers, actual numbers and other input at various points in time. The tritium value of 1.3E-1 uCi/ml was a mathematical pro- '
jection of the average tritium concentration of all the AGW on October 1, 1988, and was based on 2.1 million gallons of AGW.
{} '
-- , - - - - - - ,n, -_.,,,-------------..,n.----,m
. . - - , ,,------- ,.,-. ,.,w-, _ , . - , - - - . - - - , - - . - . .n-
173 The tritium value of 2.3E-1 uCi/ml was an actual analytical re-b%
sult obtained by GPUN for a PWST-2 sample (GPUN sample number 86-15668) on October 27, 1986. It was als6 the result obtained for a tritium analysis performed for a sample of PWST-2 (GPUN sample number 86-17062) on November 21, 1986.
The tritium value of 2.1 uCi/ml was an error on page 43, step 7.3 of a GPUN document titled, "Technical Specification for Processed Water Disposal for GPU Nuclear Corporation Three Mile Island - Unit 2 Nuclear Power Plant". This document is a bid specification sent to vendors and provides information'necessary for them to evaluate the task and return a proposal for construc-tion. No sample from TMI-2 ever contained tritium as high as 2.1 uC1/ml. My check of the lab results shows that the correct value for the sample in question is 2.3E-1 uCi/ml.
({}
Q.13 Joint Intervenors' Material Statement of Fact 4(11) under Contention 3 observes that tables 2-3 and 2-4 in the July 1986 Report list 25 sources of vaste water in storage at TMI with the total radioactivity in each. The concentration of tritium in the different sources was, according to the Joint Intervenors, highly variable. Is GPUN confident that its sampling data is representative of the entire body of water?
A.13 (KJH) It is important to understand why there are
+
variations in the radioactive concentrations of water in dif-forent locations. At the time of the TMI-2 accident, some of the projected 2.3 million gallons of AGW was already on site 1
174 supporting various plant operations.(i.e., Bleed Hold Up, Reactor
- Coolant. System ("RCS"), Borated Water Storage Tank ("BWST"), Mis- ^ .
cellaneous-Waste Hold Up). The water in these tanks had very low to no concentrations of radionuclides.
The vast majority of the radionuclides now present in the AGW came from the failed fuel via the water of the RCS through the Pressure Operated Relief Valve / Reactor Coolant ("RC") Drain Tank or through the RC letdown / purification pathway. In addi-tion, the recovery of TMI-2 has been a complex task with many jobs proceeding in parallel. Most tasks have required water, from small volumes for hands-on decontamination and operation of the chemistry laboratory to very large volumes used for shielding in the Spent Fuel Pools (SFP-A and SFP-B) or stored for emergency
(} use as in the BWST. Through these uses and processing, varying amounts of the highly radioactive water of the RCS found its way into tanks, sumps, piping and the Reactor Building ("RB") base-ment. This commingling of RCS water with the listed storage lo-cations over the years has produced batches of water which are not identical in contaminant concentrations. Therefore, as in the case of tritium, the quantity or concentration of radionuclides in each storage location is dependent on the amount of original RCS water contained with pre-accident water or post-accident water additions. The tritium concentration of PWST-2, for example, is higher than the average AGW tritium concentra-tion. This is because the tank contains mostly processed vater
{} .
175 m from the RB basement, which leaked directly from the RCS at the ;
+
(-)s !
time of the accident. Thus, it contained very high concentra- !
tions of radionuclides. l l
Q.14 Joint Intervenors' Material Statements of Fact 4(vi) and (vii) under Contention 3 state that the analyses of the PWST-2 samples by RESL for the NRC and by GPUN gave differing re- :
suits for Co-60, Cs-137, and Sr-90, and that neither detected C-14, whereas an analysis by Westinghouse found C-14 at a concen-tration of 3.0E-4, greater than the average concentration listed in Table 2.2 of NUREG-0683, Supp. 2, by a factor of three. Why is there a difference in the sample results for Co-60, Cs-137, and Sr-90?
A.14 (KLH) A sample of PWST-2 was obtained on February 23,
( 1987 (GPUN sample number 87-02569). A portion of the sample was
, transferred to the NRC for anal'jsis by their contracted laborato-ry, RESL. A comparison of the GPUN data and the RESL data can be done on positive (greater than LLD) results for individual radionuclides. One method for comparison is outlined in the NRC l "Inspection and Enforcement Manual," Inspection Procedure 84725.
This method is used to evaluate a licensee's analytical capabili-ty to make consistently accurate radioactivity measurements. The licensee's measurement is compared to a NRC or RESL measurement and a determination is made whether the two values are close enough to be in agreement. The "agreement" criteria are based on j an empirical relationship which combines prior experience and the
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accuracy needs of the program. Applying the procedure to the -
k) specific GPUN and RESL data for the PWST-2 sample yields the fol-
]
loving results:
GPUN RESL Radionuclide Value (uCi/ml) Value (uCi/ml) Acreement Tritium (1.9 0.05) E-1 (1.9 1 0.03) E-1 Yes Cobalt-60 (7.6 1 0.7) E-7 (3.2 1 0.5) E-7 Yes Cesium-137 -(7.0 0.3) E-6 (8.0 1 0.2) E-6 Yes Strontium-90 (5.8 1 0.2) E-5 (2.55 1 0.07)E-5 No The differences observed between those two sets of data for tritium, Co-60 and Cs-137 are not major and, in fact, are within the range of normal differences observed when comparing radiochemistry data from two separate laboratories in accordance with.NRC standards.
() The difference between the GPUN data and RESL data for Sr-90 results from the procedures used by the two laboratories. GPUN uses either a 72-hour or a rapid method to analyze for Sr-90 in
. liquid samples. GPUN quality control data for the liquid Sr-90
- analysis has shown the 72-hour method to be more accurate than the rapid method; however, both are inherently conservative. The
] 72-hour analysis results average 40% higher than the actual, 1
l vhile the rapid method results average 100% higher than the actu-l al concentrations at the 1E-4 uCi/ml Sr-90 level, when compared to standards or the results of split samples reported by otf-site laboratories using more traditional methods, l
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fs In addition, the Sr-90 analyses performed by RESL occurred b two to four weeks after the sample was obtained. During the in-tervening period, particulate in the sample could have settled out to the bottom or could have attached itself to the surfaces of the sample container. These processes would cause an aliquot of the sample to be lower in concentration. To preclude this potential problem, GPUN boils the sample to release Sr-90 which may be bound to particulate matter.
I also would like to point out that the environmental impact analycis in the PEIS was not calculated from these sin'gle sample analytical results. The average or "base case" data was conser-
~
vatively calculated from many sample results and assumptions made from knowledge of a long history of water processing through the SDS and EPICOR II Systems.
Q.15 Why are the analyses for'C-14 at variance with one an-other?
A.15 (KJH) The C-14 concentrations at issue vary because i the values are a mixture of actual sample results, averaged num-i bars and estimates or projections calculatud from various input.
The C-14 value of 3.0E-4 uci/mi is an actual sampic resu'.t obtained from a PWST-2 sample (GPUN sample number 85-16198) ana-lyzed by Westinghouse. The sample date is December 23, 1985.
The C-14 value of (2.0E-7 uCi/ml is an actual sample result i obtained from a PWST-2 sample (GPUN sample number 87-02569) ana-lyzed by RESL. The sample date is February 24, 1987. The C-14 l
O ,
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178 value of 1.OE-4 uCi/ml found in Table 2.2 of NUREG-0683, Supp. 2,
(~))
x is a calculated estimate based on operational experience of SDS and EPICOR II Systems and on the average of four processed water analyses performed by Westinghouse in early 1986. A calculated projection of concentration for the total volume is not the same as an actual sample result of a single portion of water. The C-14 values listed vary, but the NRC and GPUN appropriately have used the 1.OE-4 Westinghouse average concentration for dose esti-mates, even though RESL measured a much lower value.
Q.16 In Material Statement of Fact 4(11) under Contention 3, the Joint Intervenors argue that the NRC's sampling of the AGW is inadequate because the NRC took a 4 liter sample from a tank which contains one-fifth of the AGW. Has the NRC analyzed a rep-resentative sample of water available for evaporation?
A.16 (KLH) Yes. In February, 1987, the water in the PWST-2 was sampled. The sample of PWST-2 was divided between the NRC and GPUN. All of the PWST water has undergone treatment through EPICOR II or through SDS and EPICOR II. Similar pro-cosning has been given or will be given to the AGW. While some variations in concentrations of radionuclides occur among batches of AGW processed through SDS and EPICOR II, the average concen-trations resulting from this processing have not been signifi-cantly different. Therefore, the PWST-2 water is representative of the TMI-2 water available for evaporation, and it has been ovaluated by the NRC Staff.
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I o 179 Q.17 Joint Intervenors' Material Statements of Fact 4(111) and (iv) claim that procedures presented in ASTM Method 3370 and 4212-CEM-3013.81, p. 5.0, 6.1.7 were not followed when the AGW was sampled in February, 1987. Are the Joint Intervenors' asser-tions correct?
A.17 (KLH) No. In February, 1987, a sample was removed from the recirculation flow path of PWST-2 in accordance with TMI-2 Chemistry Procedure 4212-CEM-3011.05, Rev. 0 (5/23/84) en-titled, "Sample Procedure." This procedure explains how one ob-tains a representative sample from a plant system. The procedure does not concern analysis or tecting of the water. It is used simply to obtain a bottle full of water from a well-mixed larger volume.
Step 2.4 cf 4212-CEM-3011.05, Section 2.0, References, in-O cludes "ASTM Section D 3370-82" as one of four ASTM standards followed and incorporated into 4212-CEM-3011.05.
TMI-2 Chemistry Procedure 4212-CEM-3013.81, entitled "Deter-mination of Tritium By Liquid Scintillation Counting," provides instructions on how to determine the tritium concentration of the sample. The then current version of this procedure was followed by GPUN when the PWST-2 sample was transported to the laboratory for analysis.
Q.18 The Joint Intervenors have stated in Material State-ment of Fact 4(iv) under Contention 3 that Chemistry Procedure 4212-CEM-3013, 81-P 5.0, 6.1.7 (10/27/87) is an updated version
(]) O
180 of Chemistry Procedure 4212-CHM-3011.05, Rev. 0 (S/23/83).
~
Is O the Joint Intervenors' statement correct?
A.18 (KLH) No. Chemistry Procedure 4212-CHM-3013.81 is not an updated version of 4212-CRM-3011.OS. They are distinct procedures that give directions for two entirely different tasks.
Chemistry Procedure 4212-CHM-3011.05 explains how a liquid sample is drawn from a plant system. Chemistry Proced'ure 4212-CIIM-3013. 81 provides step-by-step instructions which must be followed to produce an accurate and reproduceable determination of the tritium concentration in a given aliquot of sa5ple.
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181 Table 1 TRITIUM SOURCE TERMS Volume H-3 Tank Description Gallons Ci RCS Reactor Coolant System 67,286 2.64E+01 PWST-1 Processed Water Storage 109,081 1.07E+02 PWST-2 Processed Water Storage 480,134 4.39E+02 CO-T-IA Condensate Storage 101,518 1.86E+01 WDL-T-9A Evap. Cond. Test Tank 5,610 2.03E+00 WDL-T-9B Evap. Cond. Test Tank 2,231 8.07E-01 OC-T-1 EPICOR II Off-Spec 20,500 8.72E+00 CC-T-2 EPICOR II Clean 16,887 4.78E*00 SFP-B Spent Fuel Pool "B" 241,698 . '3.56E+01 SDS-T-1A SDS Monitor 373 9.29E-02 SDS-T-1B SDS Monitor 497 1.19E-01 WDL-T-1A RC Bleed Holdup 3,810 1.06E+00 WDL-T-1B RC Bleed Holdup 4,420 1.88E+00 WDL-T-1C RC Bleed Holdup 57,116 3.12E+01 BWST Borated Water Storage 458,915 9.91E+01 WDL-T-8A Neutralizer 8,675 2.55E+00 73 WDL-T-8B Neutralizer 8,605 1.91E+00
(_) WDL-T-2 Miscellaneous Waste Holdup 3,712 8.38E-01 WDL-T-11A Contaminated Drains 1,931 1.33E-04 WDL-T-11B Contaminated Drains 820 3.75E-05 Chem Cleaning Bldg Sump 1,680 2.47E-01 Auxiliary Bldg Sump 5,917 2.46E+00 Reactor Bldg Basement 43,082 3.49E+00 SEP-A Spent ruel Pool "A" 205,234 1.75E+02 Deep End of Transfer Canal 58,685 5.77E+01 Additional Water to Proces- 391,000 sing
- Total for Disposition 2,299,417 Ci = 1,020 Average Concentration uci/ml = 1.2E-1
- Projections other data taken from July 1986 report.
182 '
ATTA;H:E::: ,
1
(~J R
NAME: KERRY L. HARNER ADDRESS: P.O. Box 480 Middletown, PA 17057 TELEPHONE: 717-948-8709 EMPLOYMENT HISTORY:
CURRENT TITLE: Radiological Chemistry Manager DEPT./ LOC.: Site Operations - TMI-2 SUPERVISOR: Dave Buchanan, Manager, Recovery Engineering Provide Chemical and Radiochemical technical expertise to all projects supporting Defueling, Plant Operations, Radvaste pro-cessing, accident generated water disposal and Post Defueling Monitored Storage. .
1/82 - 1/88 -
Manager, Plant Chemistry - Planned, directed i and managed the activities of technical and supervisory personnel in implementing ~the plant chemistry program. This included training, quality control, labor relations, department s, ) administration, chemistry analyses, ra-diochemical analyses, and research and develo-ment activities.
Special activities: Managed all laboratory support for recovery frem microbiological fouling during defueling activities.
7/79 - 1/82 -
Chemistry Supervisor - Organized and directed l the efforts of the THI-2 chemistry department
< including Chemists, Sample Coordinators and j Chemistry Foremen.
- 7/76 - 7/79 -
Chemistry Foreman - Supervised bargaining unit chemistry technicians and laboratory activities l for plant start-up and commercial ope ation.
1 Provided system / chemistry operational guidance and expertise for plant operations.
1 Special activities: Corrected and improved the condensate polisher performance through equip-ment modifications and special procedures.
7/75 - 7/76 - Chemist - Responsible for review and analysis j of chemistry results performed at THI-1.
()
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183' KERRY ~KARNER
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Page 2 U 1/74 - 7/75 -
Chemistry Technician - member of the Met Ed bargaining unit responsible for performing ana-lytical chemistry for startup and operation of THI-1.
EDUCATION:
B.S. Chemistry Major Lebanon Valley College - 1974 t Certificate in Management -
Messiah College (AMA) - 1984 Wastevater Plant Operators Training - Commonwealth of -
i Pennsylvania - 1978 Company Sponsortd Courses: Manager oevelopment Program Basic Superviso'ry Development Progr Leadership Effectiveness Training -
Decision Analysis Kepner Tregoe Problem Solving Radiochemistry Course for Superviso (B&W)
Labor Relations Training for Supervisors O Seminars in Labor Relations, Qualit Control Time Management, Franklin Institute Senn Delaney Managing for Productivity Situational L4adership Laboratory Quality Assurance /Quallt Control Practices (NUS)
Managing Differences and Agreements PROFESSIONAL MEMBERSHIPS:
Member American Nuclear Society Licensed Wastevater Treatment Plant Operator PUBLICATIONS:
Use of (202 As A Biocide In Spent Fuel Pool At Three Mile Island -
Unit 2, October 1967. K. J. Hofstetter, K. L. Harner 4
s, 184 .
KERRY HARNER !
( Page 3 l Chemistry Support For Submerged Demineralizer System Operation at ,
Three Mile Island, September 1981. K. J. Hofstetter, C. Hitz, K. L. l
- Marner, P. S. Stoner, G. E. Chevalier, H. E. Collins, P. Grahn, W. F.
Pitila Condensate Polishing Experience at Three Mile Island - Unit 2, October 1979. K. L. Harner, K. H. Frederick. l s
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Office Address: E. I. duPont de Nemours & Co., Inc.
Savannah River Laboratory Building 735-A Aiken, si! 29808 Education: A . P. . 1962 Augustana College Rock Islar.d, IL 61245 Ph.D. 1967 Purdue University ,
Lafayette, IN 47907 ausleveest EisterY:
Postdoctoral Research Department of Chemistry 1947-1969 Associate Cycletros lastitute '
Texas A4N University College station, TX 77443 i Assistant Professor of Department of Chemistry Chemistry 1949-1974 University of Kentucky
, Lestagten, RY 40506 l l Radiochemistry supervisor Allied-General Nuclear Services
, O 1974-1980 Analytical Services Department Barnwell, SC 29412 i
Radiochemical Engineering GPU Nuclear Corporation !
Supervisor 1980-1987 .Three Mile Island Nuclear Station l Middletown, PA 17057 t
Research staff Chemist E. !. duPont de Nemours & Co. j 1987-present Environmental Technology Div. ,
Savannah River Laboratory i Aiken, SC 29808 i society Memberships and Professional Activities )
i Member, American Nuclear Society Member, American Chemical Society i Member, Alpha Chi signa >
Member, ACs speakers Tour, 1971-1974 l General Program Chairman, MUCL Div., National ACS seeting, 1972 ;
1 Member, GPU Nuclear Speakers sureau, 1931-1987 ,
Secretary, Central Pa. Chapter AMs, 1944-1985 :
Consultant, IAEA, Plutonius safeguards, 1985-1986 i O _ .
i i
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. 1 186 -
l
() Previous Job Responsibilities l l
Univers,ity of Kentucjk - Taught undergraduate courses in General l Chemist y and Physical Chemistry and graduate courses in ]
Radiochemistry ata! Nuclear Chemistry. Directed graduate research -
in nucleer spectroscopy, reaction mechanisms, and charged I particle induced X-ray fluorescence. Grants received from i Research Corporation and National Science Foundation for research !
programs. Member of UNISOR censortium at ORNL.
Al.'.ied-General Nuclear Services - Set up radiochemistry laboratories to support nuclear fuel reprocessing. Ordered, setup, and calibrated equipment; devised methods, operating procedures, and QC program for performing analyses, Developed in-line specialized radiacion instrumentation for monitoring the process. Developed plutonium acasurement system for near-real-time SNM accountability. Directed environmental analyses of s*sples from Chen-Nucicar Systems, Inc. on a contract basias Designed sampling systems for dominetalizer system at TMI-2.
GPU Nuclear Corporatica - As supervisor of Radiochemistry, set up radiochemistry laboratories to support decontamination and defueling of TMI-2. Devised methods, operating and calibration - .
procedures, QC program and trained technicians. Supervised staff of chemists and technicians. As Radiochemical Engineerino
() Supervisor, provided technical direction for all liquid ridwante processing operations, including SDS, EPICOR, RCS processing, etc. This included scheduling, prioritizing, and nonitoring all radwaste processing and transfer operations to ensure re<;uistory compliance. Monitored chemistry status of plant and ovetvaewad operations of Chemistry Department. Ptovided engineering support for chemistry and sampling activities associated with all reevvery projects. Directed scientists from BPNL in DOE opecial analysis laboratories and reviewed all off-site analysis r.'eults.
Savannah River Laboratory - Conducting basic and applied 'eJJarch in environmental sciences. In charge of mobile emergency response laboratory for monitoring atmospherte and terrestrial radioactive contamination. Developing instruments to measure atmosphecie particula.:es, gases, transuranics, tritium, C-14, I-129, etc. at environmental levels in the field. Developing l on-lina process inntrumentation for monitoring aquecus tritium -
releeses to the environment, t
Publications:
Has presented morce than 50 papers at professional meetings and has authored more than 30 papers in the scientific literature.
List of pubitcations available upon request. l O
187 Papers Presented at Professional Meetingst 180
- 1. "New Isotope 180 0s and the Decay of Re and 182 Re",
vith P. J. Daly, Bull. Am. Phys. Soc., M , 68 (1964).
(
"Decay of New 181 0s Isomers to Levels in 181 Re", with P.
2.
J. Daly, BAPS, M , 825 (1966).
- 3. "A 2- Two-Quasi-Particle State in 180W " , with P. J. Daly, International Conference on Nuclear Structure, Toyoko, Sept 1987.
- 4. "Oe(Li) Coincidence Spectroscopy of 186 0s. Levels", with T. T. Sugihara, BAPS, M , 1468 (1968).
- 5. "Levels in 189 0s Populated in the Decay of 189 Re", with K. J. Schroader, BAPS, M , 674 (1972).
- 6. "A Comparison of 3 He, 4 He and 12 C induced Nuclear Reaction Cross Sections on Heavy Mass Nuclei at Excitation Energies up to 100 MeV", with J. D. Stickler, BAPS, M , 685 (1972).
"Comparison of 3 He, He and 12 C Induced Nuclear Reactions 4
7.
in Heavy Mass Targets at Medium Excitation Energies", with J. D...
Stickler, sull. Am. Chem. Soc., M (1972).
O)
D
- 8. "On-Line Study of Short-Lived Activities for A=115", with UNISOR Consortium, APS Meeting, Winston-Sales, November 1973.
- 9. "Positrons from A-115 and A-116 Mass Chains", with UNISOR Consortium, BAPS, M , No. 4, 452 (1974).
- 10. "Coexisterce of Spherical and Deformed Shapes in 189 Hg",
with UNISOR Consor lua, BAPS, M , No. 4, 578 (1974).
- 11. "Decay of 190 T1", with UNISOR Consortius, BAPS, 19, No.
4, 578 (1974).
- 12. "Decay of 189 Hg and 190 Au", with UNISOR Consortius, BAPS, M , No. 4, 578 (1974).
- 13. "On-Line Study of Short-Lived Activities for A-115", with UNISOR Consortium, BAPS, M , No. 5, 691 (1974).
- 14. "Confirmation of a New Thallius Isotope of Mass 189",
with UNISOR Consortium, BAPS, M , No. 5, 699 (1974).
- 15. 190,191,192 T1", with UNISOR "Positron Decay of Consortius, BAPS, M , No. 6, 1019 (1974).
O
188 O
\> 16. "On-Line Measurement of Total and Isotopic Plutonium Concentrations by Gamma-Ray Spectroscopy", with G. A. Huff, R. >
l Gunnick, J. E. Evans and A. L. Prindle, 21st Conference on (
Analytical Chemistry in Energy Technology, G,atlinburg, October 1977.
- 17. "Application of on-Line Alpha MonitorsM.to Tucker, ProcessJ.Streams at the Batnwell Nucleat fuel Plant", with G. H.
Gray and G. A. Huff, ACS Meeting, Anaheim, March 1978.
- 10. "Non-Destructive Assay of Leached Hulls for Undissolved Reactor ruel", with B. C. Henderson, J. H. Gray and G. A. Huff, ANS Meeting, Williamsburg, May 1978.
i
- 19. "On-Line Radiation Monitoring Program at a Nuclear Fuel Reprocessing Plant", with W. B. Stroube, B. C. Henderson and G.
A. Huff, Trans. Am. Nucl. boc., 30, 272 (1978). .
- 20. "Application of on-Line Plutonium Isotopic Concentration Monitors at a Nuclear fuel Reprocessing Plant", with G. a. Huff, R. Gunnick, and A. L. Prindle, Joint Chemical Congress of the ACS and the Chemical Society of Japan, Honolulu, April 1979.
- 21. "On-Line Monitoring of Low Level Plutonium Concentrations with T. V. Rebagay and G. A. Huff, 23rd Conference on Analytical
() Chemistry in Energy Technology, Gatlinburg, October 1979.
"On-Line Monitoring of Plutonium in Mixed Uranium-22.
Plutonium Solutions", with T. V. Rebagay, and G. A. Huff, fourth Int. Conf. on Nuclear Methods in Environmental and Energy Research, Columbia, MO, April 1980.
- 23. "An Automated on-Line Plutonium Concentration Monitor for Process Control and Safeguards Applications", with T. Y. Rebagay and G. A. Huff, 1981 Pittsburg Conference and Exposition on Analytical Chemistry and Spectroscopy, Atlanti<: City, March 1981,
- 24. "Chemistry Support for Submerged Demineralizer System K. L. Harner, operation at Three Mile Island", with C. G. Hitz, Collins, P. Grahn and W. T.
P. S. Stoner, G. Chevalier, H. E.
Pitka, 25th Conference on Analytical Chemistry in Energy Technology, Gatlinburg, October 1981,
- 25. "Treatment of contaminated waste water Three Mile Island", 1982 Water Pollution Control Association of Pennsylvania, Pittsburg, March 1982.
- 26. "Submerged Demineralixer System Design, operation and Results", with C. G. Hita, T. D. Lookabilland S. G. Eichfeld, Int. Joint Topical Meeting (ANS-CNA) on Decontamination of Nuclear racilities, Vol. 2, 5-81, Sept 1992.
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189
- 27. "TMI-2 Containment Sump Cleanup using the Submerged Domineraliser System", with C. G. Hitz, 1982 Annual Meeting of Am. Inst, of Chem. Eng., Los Angeles, November 1982.
- 28. "Zeolite Processing of the TMI-2 Reactor Building Sump and Reactor Coolant System", with C. G. Hitz, TANS, 43, 146 (1982).
- 29. "The use of the Submerged Domineralizer System at Three Mile Island", with C. G. Hits, Separation Science and Technology Conf e'.'ence, Gatlinburg, June 198 3.
- 30. "Surface Characterization of Leadscrews Taken from the TMI-2 Reactor Vessel", with H. Lowenschuss and V. F. Baston, 26th Conference on Analytical Chemistry in Energy Technology, Knoxville, October 1983.
- 31. "Adherent Activity on TMI-2 Leadscrew", with V.'r.
Baston and M. Lowenschuss, TANS, 45, 278 (1983).
- 32. "Experimental Examinations of TMI-2 Debris Samples Indicate Absence of Pyrophoric Characteristics", with W. E.
Austin, v. F. Baston and D. E. Owou. j3gi., 46, 482 (1984). ,
- 33. "Decontamination Barrier on TMI-2 Leadscrew", with V. F. ,
() Baston, G. M. Rain, G. O. Hayner, TANS, 46, 384 (1984). l
- 34. "Radiation Effects on Resins and Zeolites at Three Mile Island Unit 2", with J. K. Reilly, P. J. Grant and G. J. Quinn, ASTM Symposium on Effects of Radiation on Materials, Williamsburg, June 1984.
l
- 35. "Leng Tern Appearance Rate of Radionuclides in the TMI-2 Coolant", with V. F. Baston, TANS, 47, 111 (1984).
- 36. "Initial Examination of Decontamination Barrier on TMI Leadscrews", with V. F. Baston, G. M. Sain and G. O. Hayner, National Association of Corrosion Engineers Symposium, Boston March 1985.
- 37. "TMI-2 Water Chemistry", with V. F. Baston, ACS Symposium on TMI-2, Miami, May 1985.
- 38. "Adherent Activity on TMI-2 Internal surfaces", with v.
- r. Baston, ACS Symposium on TMI-2, Miami, May 1985. j
- 39. "operation of Water and Surface cleanup Systems", with C.
G. Hitz, ACS Symposium on TMI-2, Miami, May 1985.
- 40. "Cleanup of TMI-2 Demineralizer Resins", with W. D. Bond, L. J. King, J. B. Knauer, and J. E. Thompson, AC9 Symposium on
() TMI-2, Miami, May 1985.
l n =
190
- 41. "A Comparison of TMI-2 and Laboratory Results for Cesius f'J Activity.
)
Retained on Reactor Material Surfaces", with V. F.
Baston, C. M. Sain and R. ii. Elrick, ANS Winter Meeting, San l' Francisco, November 1985.
- 42. "TMI-2 Accident Water Cleanup Operations", with C. G.
Hitz, AIcht Meeting, Seattle, August 1985.
1
- 43. "Cesium Retention on Reactor MLterial Surf 3ces, Summary I of Accident and Test Data", with V. F. Baston, G. M. Bain and R.
M. Elrick, Am. Inst, for Metal. Eng, and Soc. of Metals, New Orleans, March 1986. ,
- 44. "Post-Accident TMI-2 Decontamination and Defueling", with V, r. Baston, Symposium on Chemical Phenomena Associated with Radioactivity Releases during Severe Nuclear Plant Accidents, National ACS Meeting, Anaheim, September 1986.
- 45. "TMI-2 Reactor Coolant lystem Radionuclide Accumulation Rates", with v. F. Baston, Symposium on Chemical Phenomena Associated with Radioactivity Releases during Severe Nuclear Plant Accidents, National ACS Meeting, Anaheim, Septembe r 1986.
- 46. "10CTR61 Radionuclide Correlations from TMI-2", with C.
P. Deltete, and P. J. Robinson, Waste Management-87, Tuscon, March 1987.
l O 47. "Microorganisms, rilters and Water Clarity at TMI-2",
with L. E. Katonak, Waste Management-87, Tuscon, March 1987.
- 48. "Green Grows the Monster at TMI-2", with J. H. Hicks, B&W Water Chemistry Symposium, Lynchburg, April 1987.
- 49. "TMI-2 In-Vessel Hydraulic Systems Utilize High Water and High Boron Content Fluids", with V. T. Baston, L. A. Hofman and '
R. E. Gallagher, ANS Summer deeting, Dallas, June 1987.
- 50. "TMI-2 RCS Activity and Solids Loading from Aggressive ,
Defueling Techniques", with V. F. Baston, ANS Summer Meeting, Dallas, June 1987.
- 51. "Resolution of TMI-2 Reactor Vessel Water Clarity .
Probles", EPRI Radwaste Managemant Seminar, Boulder, July 1987.
- 52. "10CrR61 Isotopic Correlations at TMI-2", EPRI Radwaste 4 Management Seminar, Boulder, July 1987.
- 53. "Identification and Control of Microorganisms at Three Mile Island Unit-2", with B. S. Ausmus, Topical Meeting on TMI-2 Accident: Materials Benavior and Plant Recovery Technology, Washington D.C., November 1988.
O
191 i
l Fapers Published in Scientific Journals:
- 1. "DecayPropertiesoftfgutrogggefic{ggtOssiuyggndRhenium g
Isotopes. I. Decay Modes of Re, Re, Os and Os", with P. J. Daly, Physical Review, 152, 1050 (1966).
- 2. "Determination of copper Alloys by Fast Neutron Activation", with P. J. Daly and F. Schmidt-sleek, J. Chem. Ed. ~,
y , 412 (1967).
- 3. "Decay Properties of Neutron Deficient Osmium and Rhentua Isotopes. II. The A=180 Decay Chain", with P. J. Daly, Phys.
Rev., 159, 1000 (1967).
- 4. "The Decay of 195 It and 195m gg., with P. J. Daly, Nuclear Physics, A106, 382 (1967).
- 5. "The Decay of 87 Ru, ZR and ' Nb", with T. T. Sugihara, Nuclear Physics, A140, 658 (1970). .
- 6. "The Level Structure of 181 W from the Decay of 181 Re",
with P. J. Daly, K. Ahlgren and R. Hochel, Nuclear Physics, A161, 177 (1971).
189 "Levels .in 0s populated in the Decay of
{89 Re", Leitschrift fur Physik, 261, 143 (1973).
184 The Level Structure of 0s from 184 It Decay and
$85 Re(p,2ni In-Beam Spectroscopy", with R. Hochel and P. J. Daly, Nuclear Physics, A211, 165 (1973).
- 9. "Effact of Strong Rotation-Particle Coupling of the Energy Levels o Applicationto{8Jw-Quas{ggeticleSystemswithPossible Ir and It", with G. T. Easty, R. Hochel and P. J. Daly, Nuclear Physics, A211, 189 (1973).
186 0s as Populated from the Decay of 15.8hr "Levels in 1 106 It", Sugihara and D. S. Brenner, Phys. Rev., CS, with T. T.
No. 6, 2442 (1973).
- 11. "Comparison of 3 He ,
4 He , and 12 C-Induced Nuclear Reactions in Heavy Mass Tatgets at Medium Excitation E7ergies. I.
Experimental Cross Sections", with J. D. Stickler, Phys. Rev.,
C_9 , 1064 (1974).
3 4 1'2
- 12. "Comparison of He , He , and C-Induced Nuclear Reactions in Heavy Mass Targets at Medium Excitation Energies.
I II. Reaction Model Calculations", with J. D. Stickler, Phys.
Rev., Q , 1072 (1974).
l 13. 116 "on-Line Mass separator Investigation ot New Isotope 2.9 see I , with UNISOR Consortium, Phys. Rev., C13, 1601 (1976).
m a
192
( 14. "on-Line Measurement of Total and Isotopic Plutonium Concentrations by Gamma-Ray Spectroscopy", with G. A. Huff, R.
Gunnick, J. E. Evans and A. L. Prindle, Analytical Chemistry in Nuclear ruel Reprocessing, ed. W. S. Lyon, Princetont Science Press, pp 266-274, (1978).
- 15. "Application of on-Line Alpha Monitors to Process Streams in a Nuclear Fuel Reprocessing Plant", with G. M. Tucker, R. P.
Remmerlin, .'. H. Gray and G. A. Huff, Nuclear Safeguards Analysis, ed. E. A. HkWhila, ACS Symposius Series 79, Washington D.C., pp 124-143, (1978).
- 16. "Non-Destructive Assay of Leached Hulls in a Nuclear ruel Reprocessing Plant", Analytical Measurement Methods for Nuclear Materials Safeguards, ed. H. T. Yolken and J. E. Bullard, National Bureau of Standards Special Publicatiori 528, (1978).
- 17. "on-Line Monitoring of Low-Level Plutonium
- Concentrations", with T. V. Rebagay and G. A. Huff, Radioelement Analysis, Progress and Problems, ed. W. S. Lyon, Ann Arbor Science, Ann Arbor, pp 281-292, (1980).
l 18. "On-Line Radiation Monitoring Program at a Nuclear Fuel-I Reprocessing Plant", with W. B. Stroube, 443, B. C. Henderson and G.
A. Huff, Nuclear Technology, 49, No. 3, (1980).
o
- 19. "On-Line Monitoring of Plutonium in Mixed Uranium-Plutonium Solutions", with T. V. Rebagay and G. A. Huff, Analytical Chemistry, 54, No. . 1, 8, (1981).
- 20. "Chemistry Support for Submerged Domineraliswr System operation at Three Mile Island *, with C. G. Hits, R. L. Harner, P. 5. Stoner, G. Chevalier, H. E. Collins, P. Grahn and W. F.
Pitka, Analytical Chemistry in Energy Technology, ed. W. S. Lyon, Ann Arbor Science, Ann Arbor, pp 301-322, (1982).
- 21. "The Use of the submerged Demineralizer System at Three Mile Island", with C. G. Hitz, Separation Science and Technology, 18, No. 14&l5, 1747, (1983).
l
- 22. "Radionuclide Analysis Taken During Primary Coolant Decontamination at ThreeHitz, Mile Island Indicats General V. F. Baston and A. P.
Circulation", with C. G.
Malinauakas, Nuclear Technology, 63, No. 3, 461, (1983).
- 23. "Surface Characterization of Leadscrews Taken from the TMI-2 Reactor Vessel", with H. Lowenschuss and V. F. Baston, l Analytical Spectroscopy, ed. W. S. Lyon, Elsevier Science, Amstercia, 293, (1984),
- 24. "Circulation within the Primary System at TMI-2 with t
Lowered Coolant Level and at Atmospheric conditions", with 3, r.
V. 308, l
I
() Baston and A. P. Malinauskas, Nuclear Technology, 69, No.
(1985).
i
I
. l 193 l
G U 25. "Water Chemistry", with V. r. Baston, The Three Mile <
Island Accident Diagnosis and Prognosis, ed. L. M. Toth, ACS symposium series 293, Washington D.C., 108, (1986).
- 26. "Adherent Activity on Internal surfaces", with V. r.
Baston, The Three Mile Island Accident: Diagnosis and Prognosis, ed. L. M. Toth, ACS Symposium Series 293, Washington D.C., 124, (1986).
- 27. "Water Cleanup Systen", with C. G. Hits, The Three Mile Island Accident: Diagnosis and Prognosis, ed. L. M. Toth, ACs Symposium series 293, Washington D.C., 228, (1986).
- 28. "Cleanup of Domineralizer Resins", with W. D. Bond, L. J.
King, J. B. Rnauer and J. D. Thompson, The Three Mile Island Accident: Diagnosis and Prognosis, ed. L. M. Toth, ACS symposium Series 293, Washington D.C., 250, (1986).
- 29. "Antimony Telluride Formation Hypothesized from Reactor Coolant system sample Data", with v. F. Baston, Nuciaar Technology Letters, 73, No. 1, 125, (1986),
- 30. "Post-Accident TMI-2 Decontamination and Defueling", with V, r. Baston, Us Nuclear Regulatory Commission Report NUREG/CP-0078, 4-37 (June 1987).
{}
- 31. "TMI-2 Reactor Coolant System Radionuclide Accumulation Rates", with V. r, saston, Us Nuclear Regulatory Commission Report NOREG/CP-0078, 4-53 (June 1987).
- 32. "A Comparison of Measured Radionuclide Release Rates from Three Mile Island Unit 2 Core Debris for Different Oxygen Chemical Potentials", with V. F. Baston and R. F. Ryan, Nuclear l Technology 76, 377 (1987).
- 33. "Characterization of Reaction Gases and Aerosols from Underwater Plasma Arc Cutting Demonstration Tests", with v. r.
Baston and R. Karuhn, Nuclear Technology (in press).
- 34. "ch[racterizationofSuspendedParticlesinTMI-2 Reactor i
~
Coolant Samples", with R. Akamine and v. F. Baston, Nuclear '
Technology (in press).
- 35. "The Identification and Control of Microorganisms at Three Mile Island Unit-2", with B. S. Ausmus, Nuclear Technology (to be published).
O
)
194 t'%
(_) 1 CROSS EXAMINATION 2 BY MS. SKOLNIX:
3 Q Yes, good afternoon. Mr. Horner and Mr.
4 Hofstetter. And. Mr. Hofstetter, have you been involved in 5 evaluating the disposal options since the beginning when GPU 6 Nuclear decided to submit the proposal?
7 A (Hofstetter) I've been involved since I lef t 8 prior to leaving GPU in early or late 1987.
9 Q Mr. Harner, have you been involved in the 10 evaluation of GPU's proposal f rom the beginning?
11 A (Harner) Yes. in one form or another. I was 4
12 laboratory manager at one point in time and right now I 'm j 13 radiological chemistry manager. So in both of those 1 14 positions. I 've been involved in parts of preparation.
15 JUDG8 PARIS t Mr. Hofstetter, it 's not clear to me i
16 how you answered the question. Did you say that you were 17 involved until you left GPU in 1987?
18 THE WITNESS: CHofstetter) Yes, I was involved 19 until I left GPU in 1987 and since that time I have been.
20 just recently have been asked to come back and evaluate from 21 a historical perspective some of the earlier conferences.
22 JUDGE PARIS: Okay. Thank you.
23 BY MS SKOLNIK 24 Q Mr. Hofstetter, did you devele,p most of the 25 radiologic analysis procedure in use at TMI-2?
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() 1 A (Hofstetter) Yes, I would say the majority of 2 them. the maj ority of the' analysis procedures I developed.
3 Q So. does that mean that the utility develops its 4 own analytical procedures instead rather.the alternative 5 would be to follow the NRC regulations?
6 MR. BAXTER I 'm sorry. I don 't understand why 7 that 's the only alternative.
8 JUDGE BLOCH: Sustained. There 's another 9 alternative which is that they develop their own analytical 10 procedures pursuant to the regulations.
11 So please ask a question that doesn't suggest that 12 that 's not a possibility.
13 MS. SKOLNIK: Oh, okay. Well, that was my O 14 intention. My intention was to --
15 JUDGE BLOCH: Just ask the first question without 16 the "and" part and it will work.
17 MS. SKOLNIK Could I have that read back then?
18 JUDGE BLOCH Let 's not bother. I think your 19 question was, did you develop the analytical procedures?
20 MS. SKOLNIK: Yes.
21 JUDGE BLOCH: Was that your question?
22 MS. SKOLNIK: Yes.
23 JUDGE BLOCH: Did you develop the analytical 24 procedures that are in use by GPU, for what? For what 25 though?
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() i- MS. SKOLNIK For analyzing water samples, 2 sampling, taking samples and analy=ing samples. And in 3 fact, it was more a broader question too.
4 JUDGE BLOCH: Okay. Well. let 's start with that 5 one first.
6 MS. SKOLNIK: Okay.
7 JUDGE BLOCH: And you can ask another one.
8 THE WITNESS: (Hofstetter) Yes. shortly after the
- 9 accident. I was involved with the development of procedures 10 for GPU for the analysis of samples for radioactive 11 material.
12 JUDGE BLOCH: In the accident generated water, is 13 that what you 're doing?
14 THE WITNESS: (Hofstetter) In the accident i
15 generated water. That 's correct. l 16 JUDGE BLOCH: Thank you. ;
i 17 BY MS. SKOLNIK i 18 Q Did you develop or authorize or supervise the use 19 of a substitute for a standard method for determining j t
20 strontium and smear samples on a number of other samples l 21 which are hard to dissolve? j 22 A (Hofstetter) If I can -- I was involved with the ;
i 23 development of procedures for analyzing filter papers for 24 radioactive material, that 's correct. l 25 Q So you didn 't or you did -- in your job. did you i
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() i use a method between 1981 and 1985 which was not a standard 2 method for determining the strontium content and smear
. 3 samples and a number of other samples which were f rom 4 radioactive wastes derived from TMI-27 t
5 MR. BAXTER: Are de talking about the accident '
G generated water? -
7 MS. SKOLNIK: We 're talking about procedures used ;
8 in analyzing radioactive wastes which is the same as 9 radioactive water. It 's also radioactive waste.
! 10 MR. BAXTER: Well. I 'd obj ect then. It 's 11 irrelevant. It 's not dealing with sampling and analysis of 12 the water. That 's what this hearing is about. l>
l 13 MS. SKOLNIK: I think it 's related to sampling and !
i
() 14 procedures which is related to sampling and analysis of the
- 15 water in determining the characteristics of the water. f 16 JUDGE BLOCH
- I take it you 're doing this as a (
17 question of credibility of the witness. Is that your 18 intention? j i 19 MS. SKOI.NIK: Yes.
i 20 JUDGE BLOCH: And you believe that there 's i
21 something he 's done which is analytically incorrect? j 22 MS. SKOLNIK: Yes. I have evidence that he did do !
, 23 something or that he supervised something which was l 24 analytically incorrect and for which the Licensee received a {
95 citation.
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198 I) 1 JUDGE BLOCH: Would you ask a more specific 2 question about what it was that was done?
3 MS. SKOLNIK: Yes, I will.
4 BY MS. SKOLNIK:
5 Q Mr. Hofstetter, isn 't it true that procedures were 6 used to determine the strontium content of radioactive 7 wastes at unit 2 which led to misclassification of waste 8 between 1981 and 198S?
9 MR. BAXTER: I obj ect again, Mr. Chairman. I 10 don't see how this goes to the witness ' credibility in 11 discussing issues that are totally outside the domain of 12 this license amendment.
13 JUDGE BLOCH: Is there a specific violation that 14 you can refer to? Could you state the date of the violation ib that you're interested in?
16 MS. SKOLNIK: I could state that the violation was 17 discovered in September, 1985.
18 JUDGE BLOCH: But was it an NRC finding of a l 19 violation?
i 20 MS. SKOLNIK: The Licensee found the violation and ;
21 the NRC acted upon the violation by giving a citation to the 22 licensee.
23 JUDGE BLOCH: So there was a citation?
24 MS. SKOLNIK: Yes. l 25 JUDGE BLOCH: And was -- did the Licensee conceive
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() i that it was correct?
2 MS. SKOLNIX: That the citation was correct? Yes.
3 JUDGE BLOCH: Do you have the date of that?
4 MS. SKOLNIK: I don 't have the date of the S citation. ,
6 JUDGE BLOCH: I think I would allow you to prove l 7 that there was a violation to which this witness 8 contributed.
9 But I 'm not hearing what the violation was so it 's 10 very hard for him to respond. If you knew the date of it 11 and you knew exactly what was involved in the violation we 12 might know what you 're talking about.
13 It would be like an offense that was related to 14 the subj ect matter. Without that. I think it 's very 15 difficult to pursue this line.
16 MS. SKOLNIK: You want -- the citation was for a 17 violation for mis-classifyirig waste?
18 JUDGE BLOCH: Yes. When was the citation issued?
19 Or what was the identification of it?
20 MS. SKOLNIK: The reason I don't have the number l
- 21 of the citation is because it was discussed at a public 1 22 meeting, a citicen's advisory for the de-contamination of 23 unit 2.
24 JUDGE BLOCH: Do you have anything that precisely 25 describes the violation?
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() i MS. SKOLNIK: Could you --
2 JUDGE BLOCH: So we know -- ,
3 MS. SKOLNIK Like what? I don 't have the paper.
4 No.
5 JUDGE PARIS: You said, mis-classification of 6 wastes? ;
7 MS. SKOLNIK: Yes.
8 JUDGE PARIS: Which means that they were called 9 something they weren't?
10 MS. SKOLNIX: They were -- ,
t 11 JUDGE PARIS: The amounts were different from what 12 they actually were or what?
13 MS. SKOLNIK They hcVe mis-calibrated the i
) it instrumentation used to determine the strontium content, r 15 And as a result for four years, the vaste was mis- (
l 16 classified.
j 17 JUDGE PARIS: With respect to strontium content?
18 MS. SKOLNIK: Da-don?
) 19 JUDGd PARIS: W4 respect to strontium content?
20 MS. SKOLNTK: Yes.
I
, 21 JUDGE BLCCH: Let me try a question. Mr. f 22 Hofstetter, are you aware of a practice in which you i 23 participated in which there were measurements made of 24 strontium content that subsequently led to a finding by the 7 25 NRC of a violation? .
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201 I) 1 THE WITNESS: (Hofstetter) Yes.
2 JUDGE BLOCH: Okay. Could you relate for us the 3 circumstances surrounding that and your part in it as best 4 you can?
5 THE WITNESS: CHofstetter) We had. I had 6 developed a procedure for looking at filter papers, smear 7 samples, solids and the like which would allow us to 8 determine the quantity of strontium 90 present on that 9 sample.
10 As you know strontium has no gamma emitters, pure t
11 beta emitter. And this allowed us to actually measure or i 12 determine roughly the amount of strontium 90 in a sample by 13 means of beta spectrometry.
) 14 During the development of the procedures, ,
15 standards were used of traceable atrontium 90 activity.
j 16 During the use of this particular procedure in the !
t
( 17 calibration mode of operation, the technicians confused the l J l 18 term total beta activity with strontium 90 i l 19 And therefore, when looking at a standard l 20 strontium 90 as a reference standard, they didn't account i !
! 21 for the double beta decay that occurs once strontium 90 i :
22 decays into strontium and itrium. :
i l 23 As a result a number of those filter paper and j 24 filter smear samples were underestimated for their strontium i 25 90 content. l I
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1 202 l (f i This was a procedure that allowed them to make i 2 some estimate of the strontium content rather than just 3 gross beta which is used in other facilities for measuring 4 total beta activity. {
$ This allowed them, the technicians and the TMI :
[
6 people to get some idea of what fraction of the gross beta i 7 is through the strontium 90, i 8 JUDGE BLOCH: So they underestimated the f raction 9 that was due to the strontium 90 or they underestimated the j 10 amount of strontium 90?
11 THE WITNESS: (Hofstetter) They underestimated 12 the amount of strontium 90 that were on these filter papers l 13 and smears as a result of not accounting for the double beta
+ 14 decay in strontium 90 and itrium 90 decay.
i 15 JUDGE BLOCH: Okay. Please, continue.
16 MS. SKOLNIK: Continue?
17 JUDGE BLOCH: Yes, l
i 18 BY MS. SKOLNIK:
i 19 Q Yes, you said that the technicians did the 20 sampling?
- 21 A (Hofstetter) Yes, technicians typically do the 22 sampling.
23 Q But is it true that you were the supervisor of
- 24 those technicians?
i 25 A (Hofstetter) In the early part of the yes. in g
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203 L 1 the early part of my career. I supervised some of the 2 technicians.
. 3 Q Did you supervise those technicians between 1981 4 and 19857 r 5 A (Hafstetter) Part of the time. ,
6 Q Could you identify that part. please?
7 A (Hofstetter) Yes, I believe it was September of i 8 '83 when I moved out of the laboratory. I moved into the j 9 engineering room.
10 Q So then from September, 1981 to 1983 while the {
11 mis-calibration was being used, you were the supervisor of i 12 the technicians?
13 A (Hofstetter) That is correct.
)O 14 MS. SKOLNIX: Thank you. !
15 JUDGE BLOCH: Ard. Mr. Hofstetter, was it your ,
16 responsibility to have discovered that problem?
- 17 THE WITNESS
- (Hofstetter) Yes. I thinK that I
! 18 certainly part of the responsibility is to look at the data. l I
19 I think that the discovery, the samples were run and of [
20 course standards were run. [
21 And the double beta decay in the standard always i 22 cancels out so if you run a standard you will Cet the right !
23 number as long as you consistently make the correction in
{
24 the sample the same way. j 25 So a nurrber of standards were run as you would f l
?
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j- 0 1 normelix run in e leboratorv end of couree the reeuit of <ne !
! 2 standard would always come out to be proper because of j 3 course it 's a pure standard. l
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4 JUDGE BLOCH: I 'm sorry. I don 't understand. I !
5 asked if you were responsible for the mistake. And now what !
6 I thought I heard was that there was no mistake. !
7 THE WITNESS: (Hofstetter) No, no. No, that's t
8 not-true. I was not responsible for the mistake. I think I j 9 was responsible for reviewing the data and not catching the j 10 mistake in en earlier time.
f 11 JUDGE BLOCH: We11. as a supervisor, isn't it your f 12 responsibility to catch the mistake?
13 THE WITNESS: (Hofstetter) Certainly. Yes. I t 's O 14 my responsibility. And I would have to take responsibility i
15 for that. t i
l 16 JUDGE PARIS: Did you design the procedure that l i'
17 the technicians were following? ;
) J j 10 THE WITNESS: (Hofstetter) I modified. yes. I e 19 rrodified a procedure that had been suggested by some of my !
i
! 20 colleagues and we modified the procedure. procured j 1
i j 21 equipment. and developed the technique in order to make l
- 22 those measurements on those filters solid standards, f l
23 JUDGE PARIS: Did your m3dification lead to the j l
l 24 underestimate or lead to the error that caused the 1
- 25 underestimate?
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(). 1 Let me put the question another way. If you had 2 not modified the procedure, would the underestimate have i
3 occurred?
4 THE WITNESS 2 (Hofstetter) Yes. I think it still 5 would have occurred because of not being clear and precise l 6 on how to use the standard in the calculation for double' !
t i
7 beta decay, i
8 JUDGE PARIS: Okay. Thank you. ;
9 (Continued on the next page.)
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() i BY MS. SKOLNIKt 2 Q I just need to clarify it a little further. Did !
3 you say that it' you had not altered the. standard the mistake [
4 would have still been made anyway? Did you just say that? ;
5 A (Hofstetter) Well, the mistake is on how you use ,
6 a calibrated standard. In the case of strontium 90 there ;
(
q 7 are two beta decays for every disintegration once the source L 8 reaches radiocctive equilibrium. If in fact a simple gross ;
9 beta measurement, if you don't ccur.1 for the back that there 10 are two beta decays in the decay of a strontium 90 standard. .
11 you will probably see an erroneous result. You will see an l 12 erroneous result that is off by a factor of 2.
e 13 And so the mistake is in the wording, in the 14 procedures concerning what. when you use a standard, and you 15 are looking at only one particular portion of the beta, what [
l 16 portion of that beta spectrum. what portion of that standard 17 is giving you beta counts in that particular channel.
! 18 Q So the mistake was in the wording of the .
I r i 19 procedure?
- 20 A (Hofstetter) Yes, that 's correct. !
f 1 21 Q Now, who developed the wording of the procedure?
I 22 A (Hofstetter) Well, typically that was done by f 23 myself, some of the chemists that we have, some of the front i
24 line supervisors. We all went into a procedural, or we [
25 wrote the precedures for a variety, for all the various 4 :
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() i analyses.
2 Q So it was the procedure that.was worded by you and 3 ethers which created the mistake?
4 A (Hofstetter) That 's right. That 's where the 5 problem came in.
6 Q So then was there a procedure previous to that 7 which had the sane mistake? I 'm trying to understand. You 8 said that the mistake occurred anyway. whether you developed 9 a new procedure or not and yet you 're saying that it was the 10 wording in the new procedure that created the mistake. I 11 must clarify that for the record.
12 A (Hofstetter) The wording is the key element. In 13 using a standard, you must use it when you go back to the 14 point where you are trying to determine how efficient your
- 15 detectors are, how well you are performing an analysis. You
- 16 use a standard. In the case of strontium 90, there are two 17 beta decays in the decay of strontium 90 as it reaches the 18 ground state. If you use strontium 90 as a prinary standard l
19 in the procedure, whether it 's a gross beta procedure or 20 whether it is in fact this modified method which involves 21 beta spectronetry. if you are looking at all of the beta 22 particles. you must account for the fact that there are two
, 23 betas per disintegration of strontium 90.
24 If you are looking only at a portion of the beta 25 spectiam, in our particular case the yttrium 90 order, then
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() i there is only one beta decay for the decay of strontium in 4
2 that particular window. So the point is that in the 3 procedure for calibrating the instrument, the wording was 4 not specific enough for the technicians to either include 5 the factor of 2 or not include the factor of 2.
6 JUDGE BLOCH: Mr. Hofstetter. I would like to 7 thank you for what you are saying. It feels like it is 8 getting a little redundant nov. I thid< what you have 9 established is that Mr. Hofstetter made a mistake and that 10 there was a violation found subsequent ly as a result of the 11 mistake. I don't think there 's anything more to it than l 12 that. I don't know why we should continue any more with it.
! 13 If there is some reason, tell me, though.
l C 14 MS. SKOLNIX: Yes. As long as that was i 15 established clearly on the record, that 's fine. I just 16 wasn't sure that it was clearly established.
i 17 JUDGE BLOCH: Well, in my hearing. that 's what Mr.
l 18 Hofstetter has said.
19 MS. SKOLNIK: Okay.
20 JUDGE BLOCH: I want to thank you for your 21 forthcomingness about that.
l 22 BY MS. SKOLNIK:
23 Q A nd. Mr. Hofstetter, you are presently working for 24 Savannah River Laboratories?
l 25 A (Hofstetter) That 's correct.
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209 hbl 1 Q Is that laboratory connected to the DOE 's Savannah 2 River Plant?
3 A CHofstetter) That is correct.
4 Q And is that plant presently closed for safety S reasons?
6 MR. BAXTER: Obj ection, Mr. Chairman.
7 JUDGE BLOCH: Sustained.
8 Ms. Skolnik, did you really think that anyone who 9 vent to work for Savannah River wculd be incredible for that 10 reason, someone going to work for a plant that 's closed 11 would not have credibility? I'd just like for you to try to 12 focus on what you 're doing here. I don 't see why you raised 13 that, in terms of persuading the Board of something.
O 14 MS. SKOLNIX: It nay not be a matter of 15 credibility. I guess it 's a nat ter of what your philosophy 16 is.
17 JUDGE BLOCH: But we 're trying to persuade this 18 Board about what the merits of the case are. There 's no 19 jury to make points to. The press doesn 't mat ter here. The 20 question is the merits of this controversy. I 'd j ust like 21 you to focus on that.
22 MS. SKOLNIK: I think that's what I am focusing on 23 because obviously a greater part of the hearing has to do 24 with the characterication of the water. And right now I am 25 cross examining the people who have charactericed the water.
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0 1 au0ce 8'OCH. we etiowed the otner nuestion. we :
2 allowed the questions about the violation. I just want you 3 to see if you con focus on what really matters about ;
i 4 credibility. The fact that this man may have gone to work q 5 for Savannah River does not by itself change his credibility l 6 at all. !
l 7 JUDGE PARISi Savannah River and the other !
I 8 national laboratories have been very strenuously tried in 9 the press lately. We 're not t rying them.
10 BY MS. SKOLNIK 11 Q Mr. Harner how long have you been Radiologicci j 12 Chemistry Manager?
13 A (Harner) Since January of this year.
O 14 Q What was your position before that?
l 1 .
15 A (Harner) I've been the Radiological Chemistry !
16 Manager since January of 1988. My position before that was i 17 Chemistry Laboratory Services Manager. !
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! 18 Q Chemistry -- ? l i 1
, 19 A (Harner' Laboratory Services Manager. ;
i
! 20 Q Could you explain your duties?
l 21 A (Harner) I was in charge of analy=ing samples, f 22 both liquid, air and solid samples. for radiological f L
- 23 characteristics and also chemistry characteristics in 24 support of Unit 2 operations. TMI-2 operations.
l l 25 Q So did you work along with Mr. Hofstetter?
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() i A (Harner) At one point in time I did. yes.
2 Q Did you work along with him during the period 3 which we 've just been talking about between 1981 and 19837 4 A (Harner) Yes.
5 Q Are you the person who actually draws the samples.
6 Mr. Harner?
7 A (Harner) No. I have technicians -- had 8 technicians that reported to me that actually drew the 9 samples from the tanks.
10 Q So you actually supervise them?
< 11 A (Harner) Yes.
12 Q Do you analyse the samples?
13 A (Harner) No. I do not work in the laberatory.
4 14 Q Okay. There was a sample in question from the 15 PWST-2 and the Licensee had said that it was a typographical 16 error?
4 17 A (Harner) Yes.
18 Q You are f amiliar with that? Were you the I
19 supervisor of the person who drew that sample?
4 20 A (Harner) Yes, I was at that time.
1 21 Q When someone takes a sample and then the sample 22 goes to the laboratory, do you look at the results of the
- 23 sample when it comes back?
i l 24 A (Harner) Yes.
]
I 25 Q Particularly this particular sample? )
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3 Q Okay. And could you explain then where does the l 4 sample, where does the paperwork go from there? !
l 5 A (Harner) The laboratory technician well do the i 6 analysis, enter data into a logbook, also enter the data 7 into the computer and also write up a data sheet and that (
i 8 data sheet can get distributed almost anywhere and the [
9 logbook to a permanent plant record and the computer system 10 is there for access to the data. -f 11 Q Who would have given the information to the typist f
12 who made the typographical error 7 13 A (Harner) I do not know. l O 14 Q Who would have passed her those documents?
15 A (Harner) The analyses would have had to have come f 16 out of our department to somevne. I have no idea who would
[
17 have requested it or who handed them the data. j 18 Q This parti.cular sample went onto the vendor 19 document. the document which was provided to the vendor?
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- 20 A (Harner) It went into a bid spec., yes.
! I beicre?
I 21 Q Did you see the bid seec. j i 22 A (Harner) No. I did not.
I
! 23 Q Mr. Hofstetter, did you see the bid spec.?
I f' 24 A CHofstetter) No. I did not. !
25 JUDGE ELOCH: Ms. Skolnik, for my clarification.
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213 O 1 did he see the whett I couidn t understend tne r,rd you 2 used.
3 MS. SKOL4IK: Bid spec.?
4 THE WI'(NESS: CHarner) Bid specification.
5 JUDGT BLOCH: Thank you.
6 BY MS. SKOLNIKi 7 Q At what point were you made aware that the number 8 written on the technical specifications for the vendor had 9 been made in error?
10 A (Herner) I was responsible for responding to 11 questions that were raised during the discovery phase and at 12 that point in time I saw a reference to the tritium value i
i 13 for the PNST-2 and I irrrnediately knew that it was, could not i 14 correctly be correct. I then checked to see where that l 15 number came from. founo that on the piece of p*.per in the 16 bid spec. it was not correct. I went back, checked the
{ 17 laboratory information and the number was not correct. as I i
18 believed it was not correct the first time I saw it.
19 Q How much time had elapsed between your discovery 20 and the actual production of the document?
21 A (Harner) I don 't know. I don't have those dates l
- 22 irrrnediately avt
- lable, j 23 Q Have you any idea. was it months. weeks, years?
l 24 A (Harner) No. I couldn't say. It was at least l 25 months.
i i
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() 1 JUDGE BLOCH: What was the date cf your discovery?
2 Do you know that?
3 THE WITNESS: (Harcer) No.
4 JUD9E BLOCHi Roughly, the montn of it?
5 THE WITNESS (Harner) First quarter of this G year. I 1on't know when the document was created.
7 JUDGE BLOCH: When the document was created or 8 handed rver? You don't ktow when the bid spoc. was actually 9 put out?
10 THE WITh2SS: (Harner) No. I persor ally do not 11 know that date.
12 BY MS. SKOLNIK:
i 13 Q Nevertheless, is it true that it was the document 14 used by the *,endor in determinino what kiiv' f equipment '
(
) 15 vc ald be needed for GPU to evaporate the water? l 16 HR. BAXTE3: I 'm sorry. I aldn't understand the ;
i 17 que.*m sn. The document or the tritium value tnat we are l l
' 'l discussing? [
WS. SKOLNIK 19 We are discussi.g tne document <hich I
20 cortained the ;ritium, the error in the s.itium. j 21 'UDGF BLOCH: Do you r.now the purpose of the bid I 2 ', specificu* ion? I
- I 23 T.iE WITNESS: (Herner) It 's a design specificction [
l r 24 for construction of a piece of equipment to secomplish what j l ;
1 26 the doeurtern vants to accomplish. In thir particular case, j I !
r su i .m Reporting corinration f (202) 628-4886 l k
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[
r
o p 215 i) 1 it was for the evaporator.
2 JUDGE PARIS: Was the tritium error value in the 3 bid spec, document or was it something that occurred when 4 the secretary typed it? Do you know?
5 THE WITNESS: CHarner) I do not know for sure how 6 the error occurred. The wrong number is on the page as 7 compared to all of the laboratory information. I do not l 8 know how the wrong number got there.
9 BY MS. SKOLNIK:
10 Q But it was the number that the vendor received?
11 A CHarner) Yes.
12 Q And the contract, do you know when the contract 13 was signed with the vendor? Do you know that it was June, 14 19877 15 A (Herner) No. I do not deal with the contracts.
16 Q If the error was discovered in 1988, and the 17 vendor contract was signed in June, 1987, and the vendor --
18 obviously when the contract was signed, the vendor had f
19 produced the goods, at least on paper. Is it relevant to 20 you that the tritium value on the specification documents 21 was wrong?
?2 A (Harner) For the design of an evaporator to 13 remove radionuclides, tritium does not enter into it.
24 Tritium is not removed by an evaporator in that process, so 2S it would have on effect on how to design the evaporator.
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() i Q Is the design not important for the licensee to 2 meet its technical specifications?
3 A (Harner) I don 't understand the question.
4 JUDGE BLOCH: I guess I don't understand the 5 question in light of the previous answer. I vould like to 6 apologize for what I did before. I applied a standard to 7 you that I might have applied to a lawyer, and I shouldn 't 8 have. I think you are acting in good faith and I want to 9 apologize for suggesting that you weren't. But right now 10 the question you are asking is a follow-up to an answer in 11 which Mr. Harner stated that the tritium level in the 12 proposal wouldn 't af f ect the evaporator because the 13 evaporator doesn 't reraove tritium. It j ust wouldn 't affect r~
k-)/ 14 the design one way or the other.
Tape 915 BY MS. SKOLNIK:
16 Q Is the design of the evaporator -- and I should 17 clarify that when I eny evaporator I mean all components of 18 the evaporator including the vaporizer. That 's been the 19 general use of that word "evaporator." Does the design u.
20 the evaporator matter for the vaporizer? Wait a minute.
21 Is the design of the vaporizer relevant to the ,
22 release rate of tritium?
23 M3 BAXTER: I 'm going to have to obj ect, Mr.
24 Chairman. These witnesses are not here to describe the 25 design of the disposal system. They are here to describe O Heritage Reporting Corporation (202) 628-4888 1
217 I) 1 the sampling and analytical techniques. This is outside the 2 scope of the direct testimony as well as. I think, 3 irrelevant.
4 JUDGE BLOCH: I think that is well taken. That 5 doesn 't mean you can 't establish your point. Just save it 6 for the witnesses who are coming to testify about the design 7 of the evaporator.
8 MS. SKOLNIK: Ckay.
9 BY MS. SKOLNIK:
10 Q Mr. Harner, in your testimony you said that 11 approximately 73 percent of the AGW is in only four 12 locations.
13 MR. BAXTER: I 'm sorry, Ms. Skolnik. Would you 14 provide a reference for us?
15 MS. SKOLNIK: Sure. Page S.
16 THE WITNESS: CHarner) Yes.
Il BY MS. SKOLNIK:
18 Q Is that the same as saying that 73 percent of the i
19 radioactivity is in only four locations?
20 A (Harner) No, not necessarily.
21 Q You state that the most recent sample data was 22 used for the July, 1986 proposal. However, some locations 23 were sampled in 1985 and that data was used along with the 24 1986 data for the proposal.
25 MR. BAXTER: Is there a question, please?
i
( Heritage Reporting Corporation (202) 628-4888
218 is,j 1 MS. SKOLNIK: Yes.
2 BY MS. SKOLNIK:
3 Q What kind of cleanup activities have gone on since 4 1985 regarding those particular locations of water?
5 A CHarner) Which locations are you referring to?
6 JUDGE BLOCH: First, was there any cleanup
(
7 activity affecting the radioactivity of any of the samples 8 on site?
9 THE WITNESS: (Harner) Yes.
10 BY MS. SKOLNIX:
11 Q This is on Table 2.2-3 of the GPU proposal July 12 1986.
13 JUDGE BLOCH: Do we need this to be an exhibit?
k 14 MS. SKOLNIK: Pardon?
15 JUDGE BLOCH: If we 're going to refer to it. I 16 assume that we were referring before to the PEIS. and that 17 we 'll have later. Do we need to see an exhibit?
18 MR. BAXTER: What we have done, Judge Bloch, is to l
19 put on Page 19 of this testimony. Table 1. the data out of 20 that report that 's relevant to tritium, which is what we f 21 understood to be the issue here. There are large parts of 22 the July 1986 report which was written without a specific 23 design in mind that are no longer current and up to date and 24 so I hesitated to muddy the record with a lot of out of date 25 information. But as to the source term, this tritium data t
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() i is out of the July 1986 report.
2 JUDGE BLOCH: Okay. Ms. Skolnik, if you can rely 3 on Table 1, it will just make it easier. If there is some 4 other document that you want to rely on, we may have to do 5 something in terms of having a reference so we 'll understand 6 what you 're doing.
7 MS. SKOLNIK: Yes. I car, refer to this table. On 8 the understanding that the dates for the sample analysis are 9 in the GPU proposal and that shows that some of the samples ,
10 were drawn in 1985, whereas the dates on Table 1 are not 11 shown and therefore it does not reflect that some of the 12 samples have been taken and analyzed one year before.
13 JUDGE BLOCH: Let 's s; ow down. You want first an
(~%
14 admission that this data was drawn in 1985? Is that what 15 you 're saying?
16 MS. SKOLNIX: No, I 'm trying to clar.fy it. But 17 if you only want me to use this table?
18 JUDGE BLOCH: You may be trying to clarify it.
19 But all you did was confuse me.
20 MS. SKOLNIK: Right. Yes. I do. I want the date 21 from which the water was drawn from each location to be 22 entered on the record.
23 MR. BAXTER: Well, Ms. Skolnik, of course, is free 24 to try to put into evidence through her witnesses what she 25 desires. We have put this in evidence and I think the O Heritage Reporting Corporation (202) 628-4888
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1 oroblem we 're having is that if you want to cross examine 2 with a document that 's not in evidence, you need to bring
- 3. copies of it so people can follow. Or at least that page.
4 Obviously, the Board, and I think the rest of us, would like 5 to understand the examination. And that document isn 't in 6 evidence.
7 JUDGE BLOCH: Mr. Harner, do you know the dates in 8 'which the samples vere taken for Table i on Page 19 of your 9 testimony?
10 THE WITNESS: (Harner) Yes. Those are the same 11 samples that appear on Table 2-3 in our July 1986 proposal.
12 JUDGE BLOCH: So, Ms. Skolnik, if they are the 13 same samples, then you can ask a question about the dates 14 based on that other table. These are the same samples as 15 you were looking at them. So Just ask n question about the 16 dates and you will have it for the record.
17 MS. SKOLNIK: Okay.
18 BY MS. SKOLNIK:
19 Q Mr. Harner, could you give me the dates -- Mr.
20 Harner, is it true that Table 1, which shows the amount of 21 tritium in each location, does not reflect the tritium l 22 content of those locations in July, 19867 23 JUDGE BLOCH: Could you just stato what you think l
l 24 is the truth? Could you state to me what you think is true 20 about the dates?
l l
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1 MS. SKOLNIK: Well, it 's not that I 'm saying 2 somebody 's not telling the truth or anything.
3 JUDGE BLOCH: Just say to me what you think the 4 truth is about the dates.
5 MS. SKOLNIK: Okay. The dates, it says the data 6 was taken from the July 1986 report.
7 JUDGE BLOCH: Yes.
8 MS. SKOLNIK: # hat I'm t rying to establish is that 9 the samples were not just taken prior to the 1986 report, 10 that certain locations had been taken in 1983 and 1985 11 JUDGE BLOCH: Okay. So you want to ask whether 12 some of the data in Table 1 was taken in 1983 Mr. Harner.
13 do you know if that 's true, that some of the data from Table 14 1 was taken in 1983?
15 THE WITNESS: CHarner) Yes, it was.
16 JUDGE BLOCH: And is it also true that some of it 17 was taken in 1985?
18 THE WITNESS: (Harner) Yes, it was.
19 JUDGE BLOCH: Now, do you need more?
r MS. SXOLNIK:
20 That 'a fine. Thank you.
21 BY MS. SKOLNIX:
22 Q Is it true that since those analyses have been 23 done, that future cleanup at TMI Unit 2 has continued?
24 A (Harner) Yes. We are continuing with cleanup at 25 TMI-2.
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() 1 11 Is it true also that since 1983, major cleanup 2 activities have been undertaken at Unit 2 which might affect 3 the content, the tritium content of this water?
4 A (Harner) No. There have been no activities since 5 1983 that will af fect the tritium content, total tritium 6 content of the water.
7 Q Of each location?
8 A (Harner) Each location may have changed. But the 9 total tritium has not been affected by cleanup activities.
10 Q When did defueling begin at 'IMI Unit 2?
11 A (Harner) I believe it was 1985 12 Q' When was the plenum removed?
13 A (Horner) I can 't answer that.
14 Q If the plenum had been removed after 1983, is it 15 possible that because the water in the coolant system was 16 oxygenated, that there was a possible increase in the 17 radionuclide content in the water?
18 MR. BAXTER: Is this tritium n w?
19 MS. SKOLNIK: Yes.
20 THE WITNESS: (Harner) No. Oxygenating the 21 reactor coolant system would not increase the tritium.
22 BY MS. SKOLNIX:
23 Q Is it true that following the beginning of 24 defueling certain radionuclides the tritium could have 25 leached irom the fuel?
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() 1 A (Harner) If any tritium was tied up in pockets, 2 so to speak, that were sealed, it is possible that some 3 would have been, could have been released from those 4 pockets.
5 Q Is it possible then that some of these containers 6 which have not been sampled since 1983 could contain that 7 additional amount of tritium?
8 MR. BAXTER: I 'm sorry. The record shows they 9 weren 't sampled from '83 to the time of the report.
10 JUDGE BLOCH: Do you know what happened with the 11 water from the fuel?
12 THE WITNESS: CHarner) The fuel -- the reactor 13 debris is located in the reactor vessel. Water recirculates O 14 through the reactor vessel at all times. Some of that water 15 is removed from the reactor vessel and put into other 16 storage locations. Water from other storage locations gets 9 17 moved into the reactor vessel, so there is a constant 18 communication of water in and out of the reactor vessel and 19 therefore surrounding the fuel at all times.
20 JUDGE BLOCH: Does that water become added to the i 21 inventory of accident generated water? l 22 THE WITNESS: CHarner) The maj ority of it is I
23 accident-generated water. We process it and then re-use the j 24 water again so that it is a constant in use, cleanup, back j 25 in use, cleanup.
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/~x,
(_) 1 JUDGE BLOCH: And do you periodically mearure that 2 for tritium?
3 THE NITNESS: (Harner) Continuously.
4 JUDCE BLOCH: Continuously. And there has been --
5 was your testimony that there was no increase in the level 6 of tritium since 1983?
7 THE WITNESS: (Harner) My testimony was that 8 there was no increase in the total amount of tritium in the 9 accident-generated water since the time of the report in 10 July of 1986.
11 JUDGE B' OCH: How about just focusing on this 12 water that 's been recirculated through the fuel. Was there 13 any increase in the tritium in that?
14 THE WITNESS: CHarner) From the data that we sce, 15 I would have to say no, there has been no increase.
16 JUDGE BLOCH: So there is a theoretical 17 possibility that stuf f could be released from within the 18 fuel rods but you haven 't measured it. Is that correct?
19 THE WITNESS: CHarner) We have not seen it. We 20 measure tritium all the time. We have not seen an increase 21 that would indicate --
22 JUDGE BLOCH: You haven 't seen it in your 23 measurements?
24 THE WITNESS: (Harner) -- that a hypothetical 25 accident would have happened. Or whatever you want to term i
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(~
(,)/ 1 it.
2 JUDGE BLOCH: Does that clarify it for you, Ms.
3 Skolnik?
4 MS. SKOLFIK: Yes.
5 BY MS. SKOLNIK:
6 Q Would you define reactor coolant system and tell 7 me which parts, what are the components of the reactor 8 coolant system?
9 MR. BAXTER: I don 't obj ect. Is this the -- I 10 mean. I obj ect. Is this to test the witness ' knowledge or 11 does this have some bearing --
12 JUDGE BLOCH: Is it going to lead to something?
13 Because that 's a f airly widely known definition.
14 MS. SKOLNIK: Is it?
15 JUDGE BLOCH: Yes.
16 MS. SKOLNIX- . Maybe to you it is. Okay.
17 BY MS. SKOLNIK:
18 Q The reactor coolant system consists of the reactor 19 vessel and other parts. Is that correct?
20 A (Herner) Yes. Was that a question?
21 Q Yes.
22 A (Harner) Yes.
23 Q Okay. When you take a sample from the reactor 24 coolant system, are you taking a sample from the reactor 25 vessel and f rom each of the other components that make up O Heritage Reporting Corporation (202) 628-4888 I
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() i the reactor vessel?
2 A (Herner) The water in the reactor vessel is 3 circulated as it is filtered so that the water is well mixed 4 and we then take a sample from the area of the reactor 5 vessel and that 's known as our reactor coolant sample. And 6 the water as it recirculates and moves touches the 7 components of what we call the reactor coolant system -- the 8 piping, the vessel itself.
9 Q You mean when you circulate the water in the 10 reactor vessel it circulates through all the pipes?
11 A (Harner) Through pipes and other components of 12 what is known as the reactor coolant system.
13 Q In other words, you only need to draw one sample i 14 of water from the reactor vessel and that is representative 15 of the reactor coolant system?
16 A (Harner) Yes.
17 Q Could you please explain, just really briefly, how 18 are the contents of the reactor vessel circulated?
19 A (Horner) Well, I don 't know, I 'm not an engineer, 20 I didn 't design the system. But it is basically a pump that 21 takes water from one location, recirculates it through a 22 pipe and deposits it in another part of the system, i
23 therefore setting up a circuit inside the reactor coolant 24 system.
25 Q Presently, there is work going on to remove the ;
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() 1 grid over the lower core support assembly so that the 2 cleanup team can get into the bottom of the reactor vessel?
3 A (Harner) Yes.
4 Q Is there fuel in the bottom of the reactor vessel?
5 MR. BAXTER: Obj ect ion, Mr. Chairman. Could we 6 get back to the testimony and the subj ect matter of the 7 heering, which is the proposal to dispose of accident-8 generated water. and these witnesses are testifying on water 9 analysis and sampling?
10 JUDGE BLOCH: Can you relate this to something 11 about sampling?
12 MS. SKOLNIK: Yes. I will.
13 JUDGE BLOCH: Okay. I 'll let you go for a while O 14 to see how we 're going to link it up to the sampling 15 questions.
16 MS. SKOLNIK: Okay.
17 BY MS. SKOLNIK:
18 Q How do you sanple the bottom part of the reactor 19 vessel which has not yet been entered?
20 MR. BAXTER: Sample it for water?
21 MS. SKOLNIK Yes.
22 THE WITNESS: CHarner) It 's the method I j ust 23 explained to you where the water is circulated using the 24 pumps. Therefore, the water is flushed through that system 25 and re71rculated through the lower portion and then Heritage Reporting Corporation (202) 628-4888
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() i recirculated throughout the whole reactor vessel. So by 2 being recirculated, it is one homogenous system, the water 3 system. And we can sample at any location and know the 4 characteristics of the reactor coolant system.
5 BT MS. SKOLNIK:
6 Q How many samples do you take from the reactor 1 7 vessel?
1 8 A (Harner) We sample it daily for liquid samples.
9 Q From how many different sample points?
10 A CHarner) One sample point that is known is 11 reactor sample system. We also sample it again where we 12 sample the recirculation system. We sample an enfluent and ,
13 an effluent sample to the filters. So that would total,up 14 to three samples of the reactor coolant system. And we 15 sr.mple that enfluent and effluent twice a day So that 16 totals up to two, four, five samples of reactor coolant 17 water per day. ;
18 Q Is it possible to circulate the contents of the 19 basement, the water in the basement? l 20 A (Harner) We do not have anything currently set up
< t 21 to do that?
22 JUDGE PARIS: You mean the basement of the f 23 containment building? :
24 MS. SKOLNIK: Yes. l
- 25 BY MS. SKOLNIK:
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-( ) 1 Q How much water is in the basement, approximat ely_?
2 A (Harner) Approximately 40,000 gallons.
3 Q Could you explain your sampling procedures for the 4 basement?
5 JUDGE BLOCH: Ms. Skolnik, are you finished with 6 the coolant system itself? Because you are now in a 7 separate area, right?
T10/Bla8 It just makes it easier for me to follow if I ;
9 know.
10 MS. SKOLNIX: Yes.
11 JUDGE PARIS: I take it the sump pump in the 12 basement of the reactor vessel building has been turned off.
_ 13 Is that right?
N 14 THE WITNESS: (Harner) Yes.
15 JUDGE PARIS: Okay.
16 THE WITNESS: (Harner) The installed sump pumps.
17 JUDGE PARIS: The installed semp pumps.
18 THE WITNESS: (Harner) Is that what you 're 19 referring to?
20 JUDGE PARIS: Yes. The ones that originally 21 pumped it over into the auxiliary. ,
' I 22 THE WITNESS: (Harner) Right. They are no longer
! 23 in service.
I 24 JUDGE PARIS: All right.
j 25 MS. SKOLNIK Okay. I 'm going to move to the Heritage Reporting Corporation (202) 628-4888
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(_,) 1 basement. Reactor building basement.
2 JUbGE BLOCH: So that means there is nothing that.
3 I see wrong, you haven't shown anything wrong with the way 4 they sampled the primary coolant. Right? There 's j ust l
5 nothing wrong with what they 've done. l l
6 JUDGE PARIS: Where do you take the samples of the I
_l 7 water that 's circulating through the reactor vessel daily?
8 THE WITNESS: (Harner) We have a pump located in 9 tht react'>r vessel at?a. It takes its suction from the 10 reactor sessel and then 'ransfers the water out of the 11 reactor tui! ding over liitc a cample area inside the 12 auxiliary building of U .c planc in a shielded, protected 13 sampling system area. And that 's where the technicians draw 14 the sample then coming from the reactor coolant system.
15 JUDGE PARIS: I see. Okay. Thank you.
16 BY MS. SKOLNIX:
17 Q So could you please state again how many sampling 18 points there nra for the reactor vessely 19 A (Harner) I thought we were in the basement.
20 Q No, I 'm sorry.
21 A (Harner) Are we back?
22 MS. SKOLNIX: I 'm sorry. I haven 't clarified.
l 23 beceuse I didn 't realize that I was only strictly here to 24 point out mistakes or some kind of errors. I was just 25 trying to get information for myself. So I will continue
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() 1 and try to clarify.
2 JUDGE BLOCH: The purpose of the sampling 3 discussion here is for you to show that the sampling that 4 the applicants did was not reliable in some way that affects 5 their evaporation alternative. That 's the only purpose of 6 it. It 's not to find out things for historical purposes.
7 MS. SKOLNIK: No, I 'm not trying to do that. I 'm 8 trying to understand also exactly what the procedures are l
9 for taking the water out of the reactor vessel to the point '
- 10 where it 's going to be in the evaporator. I 'm trying to 11 understand the characterization of the water and the meanc
12 by which that water was characterized.
13 JUDGE BLOCH: The characterization of the water is C) 14 an issue, to the extent you can show that it was improperly 15 characterized in a way that will affect the validity of the i i
4 16 evaporation alternative. How the water gets into the 17 evaporation procedure was not raised by you as an issue. j j
l 18 MS. SKOLNIX: No. I know. But it still doesn't l 19 affect my need for an understanding of it.
20 JUDGE BLOCH: We only need to understand the i 21 issues that are in contest.
22 BY MS. SKOLNIK:
- 23 Q Mr. Harner, I really need clarification about not 24 so much the sampling as the points from which you draw the 25 samples.
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i 232 7.
(_) 1 MR. BAXTER: Could you ask a question, please?
2 BY MS. SKOLNIX:
3 Q How many points in the reactor vessel do you draw I
4 samples from?
5 JUDGE PLOCH: This is repetitious now. You did 6 say that already. I believe.
7 MS. SKOLNIK And what was the answer. p. ease?
8 JUDGE BLOCH: He said it took it from one place in 9 the reactor vessel and then there were a couple of points 10 before and af ter filtration.
11 MS. SKCuNIX: Couple -- I 'm sorry. I didn 't hear 12 that.
13 JUDGE BLOCH: There 's filtration going on and they 14 do the input and the output from the filtration and the 15 total number of samples is five a day.
16 THE WITNESS; (Harner) From three different 17 locations.
18 MS. SKOLNIK: From three different locations.
19 JUDGE BLOCH: Yes. So there 's one on the input to 20 the filter, one on the output, twice a day, and one sample 21 from the reactor vessel. And it 's done every day.
22 (Pause) 23 JUDGE BLOCH: Ms. Skolnik, the problem I have in 24 that if you know what the errors are that you are trying to 25 find out through cross examination, you may be able to get O Heritage Reporting Corporation (202) 628-4888 m
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( 1 somewhere. I think it 's very unlikely that you 're going to
~
2 think of something new now that doesn't come from your 3 experts and that doesn't come f rom your prior information.
4 It 's j ust extremely unlikely you 're going to come up with an r
5 on the spot question that 's going to find something out that 6 you 're not prepared on. My sense is that you don't know 7 what the error is in sampling the primary system and that 8 you're just trying to think of something without knowing l 9 anything. It 's j ust not going to get anywhere.
10 MS. SKOLNIK I don't think it 's that I don 't 11 know. According to the procedures, multiple sampling points 12 is important. And I'm trying to establish whether or not t
13 the Licensee has sufficient sampling points to draw a
()
- 14 representative sample from the reactor vessel.
15 JUDGE BLOCH: Well, of course, they 're going to 16 say it 's adequate. Unless you have an expert that 's going 17 to say otherwise -- you could ask him, is it adequate? But 18 unless you've got an expert that 's going to say it 's 19 inadequate, it 's going to be his word for it.
l 20 MS. SKOLNIX: Okay. We move to the basement.
j 21 BY MS. SKOLNIK:
22 Q How many sampling points are in the basement?
23 A (Harner) There is not an exact sampling point in i
- 24 the basement. We do take basement samples. though. I t 's 25 not an installed system like it is on the reactor coolant
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2 Q Could you explain how you take samples f rom the i 3 basement? First of all, could you explain the size of the 4 basement? And did you already say how much -- well, did you 5 say how much water the basement contained?
6 A CHarner) I said there is approximately 40,000 7 gallons. I can't do any nore than that.
O MR. BAXTER: It 's on Table 1 of the testimony.
9 MS. SKOLNIK: Okay.
10 BY MS. SKOLNIK:
11 Q Could you -- how many sampling points are in the 12 basement? From where do you take samples?
13 A (Harner) We sample the water from the reactor <
14 building basement on the 305 elevation, which is the ground '
15 floor of the reactor building. We lower a sample line down 16 to the water, in the water level, in the reactor building 17 basement, recirculate it through a portable sampling pump 18 and then draw a sample off of that recirculation line.
! 19 That 's how we sample the reactor building basement water?
20 Q When you are trying to get a representative sample ,
i 21 of the basement, how many samples will you collect from the i
l 22 basement?
23 A (Harner) We sample the basement once per week.
24 Q At that point, do you draw one sample from the l 25 40,000 gallons?
l
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235 is _j 1 A (Harner) Yes.
2 JUDGE PARIS: Do you do a single analysis on that 3 one sample?
4 THE WITNESS: (Harner) Yes.
5 BY MS. SKOLNIK:
6 Q Are there sinks in the basement?
7 A (Harner) No, there are no sinks in the reactor 8 building basement?
9 JUDGE PARIS: What did you mean by sid(?
10 MS. SKOLNIK A concave area.
11 JUDGE PARIS: Okay.
12 JUDGE BLOCH: Is that what you understood by it.
13 Mr. Harner?
14 THE WITNESS: CHarner) No.
15 BY MS. SKOLNIK:
16 Q Is the floor level of the basement even in all 17 parts?
18 A (Harner) No, it is not level in all parts.
19 Q How would you determine that your sampling 20 instrument had taken a sample from one of those concave 21 areas? In fact. is it possible for you to lower your 22 instrument into the basement so that you may draw a comple 23 from the sink?
24 A (Harner) It 's possible. We have sampled the
, 25 lower sinks of the 66sement on occasion. The sample that we
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(_m 1 do on a weekly routine basis is not from these lower areas.
2 It 's more f rom the general reactor building basement area.
3 Q Was the sample that is presented in Table i from 4 the basement, was that from a general area?
5 (Pause) i 6 THE WITNESS: (Harner) That sample was probably 7 from the general area of the basement, and not one of the 8 lower areas.
9 JUDGE PARIS: Are these lower areas in the 10 basement sumps?
i 11 THE WITNESS: (Marner) Yes, the sump that you are 12 referring to with the pumps. There 's also a channel in the ,
13 basement where the in-core detectors come out of the bottom 14 of the reactor vessel. That 's another lower area of the 15 reactor basement floor.
16 JUDGE BLOCH: Do you believe that this basement i
17 area is homogenous for the purpose of taking a single (
i 18 sample?
A 19 THE WITNESS: (Harner) It is for the purpose that 20 we 're using the sample. There are a number of j obs that go 21 on in the reactor building basement such as a robot going l 22 around in there spraying water on walls, scaffolding. things 23 like tnat. So there is motion in the basement while work is 24 going on. Also, the chemical driving forces and 25 temperatures will tend to mix water.
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-() i Now, we have -- the basement water is fairly 2 stable. There is occasionally in-leakage that comes in from 3 condensation. And as that condensation comes in and we see 4 the level, the water volume increase, we also see the 5 parameters change that we analyze. So we can see that there 6 is changes in the parameters in the reactor building 7 basement, and are able to couple those to volume 8 differentials that we see also occurring for various 9 reasons.
10 So we 've been able to see that there is a great 11 deal of mixing in the reactor building basement.
12 JUDGE BLOCH: So is there some reason to believe 13 it is not homogenous?
14 THE WITNESS: CHarner) Not to my knowledge.
15 BY MS. SKOLNIK: ;
16 0 You a re saying that the water in the sinks will be 17 mixed thoroughly with the water on the other level?
18 A (Harner) It will be mixed to a great extent. I 'm 19 not going to say thoroughly. But again, we 're talking maybe I 20 1,000 gallons in the sinks versus 40.000 gallons in the 21 whole bauement. So there 's quite a large volume of water 22 that does get mixed very well versus a very small volume 23 that does not get mixed quite as well.
24 A (Horner) 25 G You 're saying that the sum of the sinks is 1,000 O Heritage Reporting Corporation (202) 628-4888
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(_ i gallons?
2 A (Harner) That 's on estimate. I don 't know 3 exactly what it is. I know it 's small, though.
4 JUDGE BLOCH: Mr. Horner, you said there were 5 separate samples taken. What was the difference in the 6 levels of radioactivity in those samples compared to the 7 rest?
8 THE WITNESS: (Harner) Again, we 've taken it at 9 various times for jobs that were going on and we've recently 10 sampled the elevator pit which is a lower section also I 11 forgot to mention. And the sample that we took from there 12 was slightly higher than the general basement area. The j ob 13 we were working on at the time --
14 JUDGE BLOCH: What is slightly higher? And by 15 magnitude, is it a quarter higher, a fifth higher?
16 THE WITNESS: (Harner) No more than a factor of 17 like 1.5 to 2.
18 JUDGE BLOCH: So it could be half again higher 19 than the remainder, but it 's a very small volume?
20 THE WITNESS: (Harner) Yes.
21 BY MS. SKOLNIK:
22 Q Nevertheless, the water ?n the sinks contains 23 radioactivity?
24 A (Horner) Yes.
25 Q It 's possible that it could contain tritium?
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() i A CHarner) Yes.
2 Q Is it possible that the tritium in those sinks hca 3 not yet been sampled?
4 A (Harner) No.
5 Q Why is that?
6 A (Harner) For one thing, tritium is going to be 7 the most mobile of anything in the water. It is water. And 8 it 's going to mix to. a great extent very rapidly by chemical 9 driving forces. And of any of the radionuclides, that would 10 be the least to be different.
11 JUDGE BLOCH: Ms. Skolnik, if it were different --
12 there is a bounding going on here. It might be as much as 13 half again higher than the average of the rest of the O 14 sample. But it 's a very small quantity compared to the 15 total volume. So it 's not going to af fect the overall 16 sampling very much. I 'm j ust stating the testimony. I 'm 17 not stating the truth. I 'm j ust stating what the testimony 16 is.
19 MS. SKOLNIK But it would be in addition to 20 what 's already there. So it may not be reflected.
21 JUDGE BLOCH: Yes. But the amount you are 22 concerned about has to be an amount that will somehow affect 23 the validity of the evaporation proposal. If I hear it l 24 correctly. it 's no more than a couple of percent. It 's not l 25 going to affect anything.
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() 1 MS. SKOLNIX: But it affects the total sum. And
- - 2 therefore, it would affect the release rate, it will affect 3 the dose.
4 JUDGE BLOCH: It will affect the amount of 5 radioactivity that would be released. And if you can 6 establish that the levels that the applicants are talking 7 about, that the Licensee applicants are talking about, that 8 might mean something. So you might -- I mean, maybe there 's 9 a 2 percent difference here?
10 MS. SKOLNIX: If there 's a 2 percent dif f erence 11 here, there 's other parts whers perhaps the same errors have l
l 12 been made.
13 JUDGE BLOCH: You have to show they are somehow
- '> 14 cumulative, that they add up.
15 MS. SKOLNIK: Yes.
16 JUDGE BLOCH: So show something else that has to 17 do with the basement water that goes more than 2 percent, or j 18 1 percent.
19 MS. SKOLNIK: Well, we 're saying 1 or 2 percent, 20 but it hasn 't really been established exactly what it is 21 because Mr. Harner doesn't know how much water is in those 22 sinks. And he doesn 't really know, either, just how much i
l 23 tritium would be in there.
24 JUDGE BLOCH: Please continue.
25 l
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2 Q Could you please explain the mechanism by which 3 the water is mixed?
4 A (Harner) Mechan!En?
5 : .
Yes. You said that the water would be mixed? ,
6 A (Harner) In a liquid. Ions that are dissolved in 7 the liquid such as sodiums, sulfates, hydrogens, hydroxides, 8 calciums, magnesiums, nitrates, all different types of 9 chemicals and compounds exist in water. They move around 10 and through electrical charges sometimes are repelled, ,
11 sometimes are attracted. These ions are in continuous 12 notion in a liquid. That is how the mixing of the water
, 13 takes place. Tritium, being the same as hydrogen, being i
14 light and also part of tritiated water, will move the n'ost iS rapidly and mix the easiest of any other of the on-ions or 16 cat-lons that may be in the water, any water, not j ust the i
, 17 basement, our basement water.
l 18 JUDGE PARIS: Isn 't there also physical movement, i l i 19 because you are circulating it, recirculating it?
20 THE WITNESS: (Harner) As we 're moving equipment 21 around, the other thing that affects it - temperature. As
(
22 water is warmer, it will rise. Colder water will sink. ,
23 That will also continually move water around in the 24 basement. :
25 I
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242 t l h. 1 BY MS. ST,OLNIK:
2 Q Su there is work going on in the ot.sement. there 3 is machinery in the basement? !
4 A CHarner) Robots. t End10 $ (Continued on the next ptge.) ;
6 :
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(~h Q Mr. Harner, have any of the tanks that are not x_j i 2 being used for storage. do they contain exactly the same 3 bt.'y of water that was -- since the water went into it !
4 originally?
l 5 A (Horner) I would have to say, no. No tank has 6 the original water in it. What 's your original date? I 7 mean what --
8 Q 1979?
9 A (Harner) No. No tank would have the original 10 water.
11 Q You state that -- let me see -- you state that the 12 120 curie estimate of tritium is conservative. Knat do you 13 mean by conservative?
O 14 A (Harner) Excuse me. Do you mean 1.020?
15 Are you talking about the overall tritium number?
16 Q Tritium, yes.
17 A (Harner) Yes, the 1.020 curier of tritium that 18 were estimated to be present 10/1/1988 is conservative due 19 to the fact it has decayed and also some of it is lost 20 through evaporative losses.
21 Q You don't have a copy of the GPU proposal?
22 A (Harner) Yes, I do.
1 23 Q Do you? Could you look a; Table 2-2, please, 2-2?
2A JUDGE BLOCH: If you would. I 'm going to look over l 25 tr houlders of one of the parties because I don 't have l
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2 And we're going to have to see. If you 're going 3 to ask questions about the table, we 're going to have to'see 4 somehow to get it in the record so that the record will be 5 intelligible.
6 THE WITNESS: CHarner) Yes.
7 BY MS. SKOLNIX: !
8 Q Okay. Table 2-2, there's a figure at the bottom i
9 of the page. January 1. 1986 corrected to 3/79 under figure 10 of 1,728.5 curies? !
11 A CHarner) Yes, t i
12 Q Could you explain -- you say that the estimate of 13 1,020 is a conservative estimate. And why is that figure, ;
14 1.728.57 Could you explain the difference between those 15 two? ;
16 A (Harner) Yes. in table 2-3. if you 'll turn to the f 17 next page. I 'm sorry. Table 2-4 on page 13 of the GPU, !
18 1986 proposal.
19 At the bottom you 'll see a number, 1.182 75 for i r
20 tritium total number of curies, about the middle of the !
r 21 page. i l
22 Q Uh-huh. l
! i 23 A (Harner) Okay. As of January 1. 1986 we took an 24 inventory of the water in the tanks as well as the analysis ;
25 of the tritium in the tanks and came up with a total curies
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() 1 of tritium present et that point in time as close as we 2 could get to it.
3 Now.that number totals up to 1.180. If you take 4 that number, that 's at a point in time. If you go backwards 5 to 1979, ther49 was more tritium present at that time because 6 it has decayed over the yeart 7 We have also lost tritium due to evaporative 8 losses over the years.
4 9 So that the number on table 2-2 of 1.728.5 is an 10 estimate of a calculation of the 1.182.75 decay corrected 11 back to 1979.
12 So that a number present now was bigger earlier in 13 time. It has lost some in that time due to decay, a 14 Q You say that, that 1.020 curies of tritium is in 15 1.9 was in 1.9 million gallons. Could you explain --
16 A CHarner) That 's not correct. The number on table 4
17 2-4 of tne July, 1986 proposal, the 1.182.75, that was the 18 amount of tritium in 1.9 million gallons of water.
4 19 The 1.020 curies of tritium is an estimate that 20 would be conteined -- it would have been in the 2.3 or the 21 2.1 million gallons of water.
22 The water that gets added does not have tritium in 23 it. So as the water increases, the tritium level does not 24 increase.
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) 1 million?
2 A (Harner) The water, we need water to do certain 3 functions for the defueling effort. The water that we use 4 comes from water that we make up to the plant. It 's known L 5 as demineralized water.- i 6 And that is clean water that is taken out of the f
7 Susquehanna River, processed and used.
8 Another big addition is when we run the coolira 9 systems inside the reactor building, during the summer 10 months when the air contains a lot of humidity as the air is 11 cooled going across the cooling coils, the moisture 12 condenses on the coils and then drops down into the basement !
13 of the reactor building. l O 14 And that is another big increase in the amovat of
{
15 water that 's added to the accident generated water. 4 l
16 Those two mechanisms continually increase the i 17 amount of water that we have.
18 Q What was the date of your proj ected 2. 3 million 19 gallons? I don 't quit.e remember that.
20 A (Harner) The 2.1 million gallons was proj ected 21 for 10/1. 1988. In -- l 22 Q I 'm sorry. Did you say a month? What date? I 23 A (Harner) 2.1 million gallons was projected for 24 10/1 1988 per table 2-8 of our July, 1986 proposal. !
i It was then adjusted since we knew we weren't !
25
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() i going to be doing anything with the water in October, 1988.
r 2 We also knew that we had continually, we are 3 continually increasing the water. We estimated an amount of 4 2.3 million gallons of water that might be added to the end .
S of the defueling project and we would need to get rid of it.
6 Q So in how many months will the water increase from 7 2 1 million gallons to 2.3 million gallons? -
The summer 8 A (Harner) That 's very flexible.
9 months, it increases a lot. The v11ter months it does not.
10 It 's a proj ection, an estimate.
11 Q Okay --
12 JUDGE BLOCH: Ms. Skolnik. I'm kind of lost. Is 13 this going somewhere?
14 MS. SKOLNIK: Yes, it is. And the amount of water 15 is relevant.
16 JUDGE BLOCH: But we knew for a long time that the 17 amount of water was increasing. This is not news. It 's all 18 over the record.
19 MS. SKOLNIX: I guess the point I 'm trying to mske
- 20 is perhaps it will increase more than, beyond on 2.3 million 21 gallons.
22 MR. BAXTER: But the witness has testified that 23 there is not being tritium being added in this new water.
24 MS. SKOLNIK But the quantity of water will 20 affect --
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() i MR. BAXTER: I don 't recall that there 's a genuine 2 issue of fact about there being more than 2 3 million 3 gallons. ;
4 There was nothing Jn your summary disposition ;
5 filings about that. l 6 JUDGE PARIS: I take it that when water is added l 7 it is clean, that is non-radioactive river water? l 8 THE WITNESS: (Harner) Yes.
i 9 JUDGE PARIS: And the result, it dilu*es the water ,
10 containing the radionuclides?
11 THE WITNESSi (Harner) It will dilute it, yes.
12 But that does not change the total quantity of tritium. It 13 will change the individual concentration per container but l 14 not the total curies.
15 BY MS. SKOLNIK: !
16 Q There is radioactivity coming in from the l
! 17 Susquehanna into TMI. Do you measure the amount of tritium 18 that comes in from the intake point into unit 1 and 27 i 19 A (Herner) No. In our laboratory in the plant, we !
t 20 do not analy=e that.
So then the additional water which will make up l
21 Q ,
22 the 2.3 million gallons will have radioactivity into it and !,
t 23 it will be adding to the inventory? j 24 A (Harner) It might be possible.
25 JUDGE BLOCH: Are you talking about the natural l
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() 1 level of tritium in the Susquehanna River?
2 MS. SKOLNIX: Yes.
3 JUDGE BLOCH: That 's correct. That will be added.
4 BY MS. SKOLNIK:
5 Q So that would be added for as long as the water is 6 being used for defueling, the inventory of tritium will be 7 increasing?
8 A CHarner) And decaying. i 9 Q And decaying? But it will increase?
10 A (Horner) And being lost by evaporation. l l
11 Q So the point is, there could be more than ).,020 l
< 12 curies of tritium? !
13 A CHarner) No way. The amount that is being added i
) 14 is no very, very, very small compared to the tritium that is 15 already there, it cannot be nore. j 16 Q How do you know -- how do you know it was very, ,
17 very small if it wasn't measured?
18 A (Harner) I said it was not measured by the i 19 laboratory inside the plant. It is measured by l
20 environmental laberatory, by the DER and by EPA.
21 I 've seen measurements for many of those (
22 organizations that the background tritium .evel of the ;
i i 23 Susquehanna River is known.
I 1
24 Q What is that background? Could you tell me? ;
! I
{ 25 A (Harner) Not by me unfortunately. j i ,
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() i Q Pardon?
2 A (Harner) I do not know.
t 3 Q But still you know it 's going to be small. I mean 4 you don't know the figure but you're willing to say that 5 it 's going to be a small addition to the total inventory?
6 A (Horner) Yes.
7 JUDGE PARIS: Is the tritium in the Susquehanna 8 River in equilibrium? That is. is it decaying and 9 evaporating so as to maintain a constant level for us?
10 THE WITNESS: (Harner) To my knowledge the 11 background level of tritium in the water or well water.
12 ground water. those types of things, the background levels 13 are fairly constant.
14 And to answer the question about how much it is. I 15 cannot give you an exact number, but I know it 's in the 16 picocurie range which is a very low range.
I 17 BY MS. SKOLNIK:
- 18 Q But isn 't it true it 's in the picocurie range
! 19 because of the EPA regulations? It 's not tust because it 's 20 a small amount. It 's because that is the way EPA must 21 measure the amount of tritium in the river?
- 22 MR. BAXTER
- I obj ect. I don 't understand the 4
23 basis.
24 JUDGE BLOCH: I do.1't understand.
! 25 MR. BAXTER: I don 't understand what you 're i
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2 MS. SKOLNIK: Well, Mr. Harner is saying that it 's 3 obvious that there 's not much tritium in the river because 4 it 's measured in picoeuries.
5 What I am saying is, it 's regulation that the i 6 tritium in drinkirg water supplies must be measured in 7 picoeuries per liter.
8 JUDGE BLOCH: But the fact that you measure it as 9 a certain number of picoeuries is a physical measurement. i 10 It has nothing to do with the regulation. L t
11 He 's saying that the measurements he 's seen show 12 that it 's in picoeuries. It 's not that it 's required to be 13 that way. It is that way.
14 BY MS. SKOLNIX:
1 15 Q Is it possible that there could be additional 16 tritium in the water at any point from a nuclear power plant ,
17 further up the river? -
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( 18 A (Herner) Yes, that 's possible. ;
r 19 Q How would you prevent that tritium from entering [
1 20 into the accident generated water? c 21 A (Harner) We have no mechanism to prevent that. t 22 Q So in other words, there is a possibility that ;
23 additional tritium could be added to the accident generated [
24 water which would be measurable and which could affect the i 25 total quantity?
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( i A (Herner) Again, it would be barely measurable.
2 Q Upon what basis do you make'that statement?
3 A (Harner) The closest nuclear power plant upstream ,
4 from us. I think is Berwick. For the tritium to get from 5 Berwick down to Harrisburg would see a tremendous amount of S water that contains background level or no tritium. ,
7 And that would be diluted tremendously before it r 8 would reach Three Mile Island.
9 Q But nevertheless, it would reach Three Mile 10 Island?
11 A (Harner) It 's possible. yes.
12 Q Is it also possible that there would be an 13 additional tritium, amount of tritium from the hospitals ,
O 14 which dump into the Susquehanna River?
15 A (Harner) I am not familiar with what their l 16 regulacions are, whether they 're allowed to put wastes into !
17 the river or not. I cannot answer that.
18 Q If they are permitted, isn 't it possible that !
l 19 their wastes could go into the accident generated water?
20 A CHarner> I cannot answer -- !
i 21 MR. BAXTER Obj ec t ion. i 22 THE WITNESS: (Harner) I cannot --
23 MR. BAXTER: Obj ection. Judge Bloch. We can add 24 speculations all day long about what might happen. And 25 there 's no showing of likelihood, probability that Ms.
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< 1 Skolnik has evidence that 's passed due.
2 But to sit here and just speculate all day about 3 what could happen to affect the background level of tritium 4 in the Susquehanna River which in turn might affect some way 5 the water content is piling speculations on top of 6 speculations.
7 JUDGE PARIS: I thought hospitals damped all their 8 wartes at sea.
9 JUDGE BLOCH: That will not be considered in 10 evidence.
11 BY MS. SKOLNIX:
12 Q Yes, Mr. Harner, on page five still in your 13 testimony, you say that, "in cordunction with the routine
- 14 samples analyzed by the GPU nuclear laboratory periodd, 15 independent quality controlled analysis are also performed"?.
16 A (Harner) Yes.
! 17 Q Could you explain who does the quality control and 18 in what way it 's independent?
13 A (Horner) We have a program set up with an 20 organization called, Analytics Incorporated, where they send 21 us samples on a periodic basis and we do rot know what the 22 concentrations are of those samples.
23 We analyze them onsite using our methods, send the 24 data back to them. They then look at our dets, compare it 25 to what their atandards were made up to be.
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() 1 And they send us a report telling how good our 2 result was or how bad our result was. ,
i 3 That 's one of the methods we use for doing the 4 check. That is an independent quality control check.
5 JUDGE BLOCH: Mr. Harner, do your analyste know l 6 which of the samples came from the plant and which came from i l
7 outside? l i
8 THE WITNESS: (Harner) No, I have my supervisors C
9 make up the unknowns, put them in sample bottles that are !
10 similar to the ones, the same type of bottles we use for all j 11 other samples. ,
12 And they then get them to aralyze as a blind ;
L 13 sample. I
- O 14 JUDGE PARIS: How do they do in general?
l 15 THE WITNESS: (Harner) Very good.
16 EY MS. SKOLNIK: i l' ,
17 Q Could you explain then on page six you have. "in :
> t 1
18 additien a sample was analyzed independently by GPU [
19 Nuclear 's chemist ry department".
T 20 Could you explain how a GPU nuclear chemistry
- 21 department is independent? !
4 22 A (Harner) Could you tell me which line you're i r
23 referring to?
J l i 24 Q Certainly. Line three. l 25 A CHarner) In tnat sense by the word, f i
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i 255 l 0 1 independently. I mean it was analyzed by GPU Nuclear. And ;
2 it was also analyzed by RESL Laboratory independently. two t 3 different locations. We didn 't look over each other 's f
4 shoulder or anything like.that. l 5 Q It was the same sample though of water? i 6 A (Harner) Yes, it was taken from the PWST-2 tank I i
7 and the sample was split in half. One half given to the NRC 8 and the other portion analyzed by our GPU Nuclear lab on 9 site.
10 Q Has RESL or the NRC sampled and analyzed any other j l
11 tanks other than the PWST-2? l 12 A (Harner) I think in the past we have done other l 13 analyses but I can " say exactly that we have.
O 14 I think since 1979 we have analyzed, we 've each 15 analyzed split samples. ,
16 Q When you say we, who do you mean? !
i 17 A CHarner) Between the Nuclear Regulatory l
i 18 Commission and GPU Nuclear. I think we have done samples in l l
19 the past but I cannot tell you what they were or what the l l
20 data was.
21 Q So the NRC has analyzed other samples? l 3
22 A (Harner) Not to my recollection.
23 Q Of the accident Eenerated water?
24 A (Harner) It was of water from TMI-2 This sample
} 25 that they analyzed from PWST-2 was what we refer to as i
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2 It is also accident generated water but it 's water 3 that has gone-through the EPICOR process and then stored.
4 Q Do you remember how of ten the NRC has analy=ed the 5 accident generated water? i I
6 A (Harner) No. It was infrequently.
7 Q Like what, every month or every year?
8 A (Harner) I can 't speculate without the data.
9 Q When the sample which we 're ref erring to here. the 10 PWST-2 sample, there are different bodies, the RESL and GPU !
11 Nuclear Laboratory and GPU's chemistry department analyzed 12 the sample, do you all use the same or different analysis !
13 procedures?
O 14 A (Harner) There are only two organizations. GPU f i
15 Chemistry and GPU Nuclear are the same body. They are the [
i
) 16 same laboratory. There 's two laboratories involved.
17 We use different procedures as a nuclear power ,
18 plant, we are required by the Nuclear Regulatory Commission [
- 19 to have written procedures for our analyses in the ,
20 laboratory. [
21 We write our procedures according to the method i f
5 22 and the instrumentation that we have available and that !
i 23 describes to a technician how to do the analysis.
(
24 Now a procedure such as that at another laboratory {
f i
25 would involve possibly a lit t le dif ferent technique and a f
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(_ i different piece of equipment that would take different 2 knobs, different settings, things like that.
3 So the procedures are rot the same at any two 4 laboratories. They are different 5 JUDGE BLOCH: Ms. Skolnin, it 's going very slowly.
6 MS. SKOLNIX: Yes.
7 JUDGE BLOCH: Part of the reason it is, is because 8 some of what you're doing is supposed to be accomplished 9 during the discovery phase of the hearing.
10 At this point you really should be knowing what
. 11 you 're trying to accomplish with your cross examination
( 12 line.
13 In fact, there 's a directive f rom the Commission
) 14 that we could ask for cross examination plans which is.
15 here 's what I 'm Eoing af ter. here 's what I 'm going to got.
16 And it really is your responsibility to know that.
17 If you were accomplishing something, we'd have no problem.
l j 18 We could sit here all day.
l 19 But this is going very slowly and I don't have a 20 sense that it 's got any purpose to it, i 21 MS. SKOLNIK: Well. I like to think it has a 22 purpose to it.
23 JUDGE BLOCH: Well, I know, but it 's not supposed 24 to be discovery.
25 MS. SKOLNIX: Right.
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"( ) i JUDGE BLOCH: The questions to find out things 2 should have been asked long ago and your experts should be l 3 telling ;<ou, if there are errors here, what are the errors?
4 You should i:now them and then just bring them out. ;
5 If we would take about a five minute break, could ;
6 you then look through the cards and be able to proceed more I 7 ef ficiently once we t ake the break? s 8 MS. SKOLNIX: I don't honestly know if it 's a lack 4
9 of efficiency. I think I do need to go slow because there 10 is such a lot of material and that 's just the point. L 11 And. Judge Bloch. I may be taking time but'you 12 know the cleanup has taken 10 years. And I think if I take j 13 an extra few minutes to try to get my questions all O 14 together. I can't see what dif ference it 's going to make. !
I i 15 JUDGE BLOCH: If you were getting somewhere INJ i l 16 understand that. but you 're supposed to be prepared and be 17 able to ask questions.
- j. 18 We 're not supposed to wait three minutes between }
19 each question. [
20 MS. SKOLNIK: Yes. I91 like to take five minutes.
21 please. f I
22 JUDGE BLOCH: We 'l l take a five minute break. :
I 23 It 's 4: 40 We 'll be back at 4:45. i
( 24 ( Whe reupon. a short recess was taken.) f l 25 (Continued on the next page.) f l
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259 O 1 aum e 8toCa. Beck on the record. now.
2 BY MS. SKOLNIX:
3 Q Mr. Harner, we are sti'l talking about the sample 4 that was taken from PWST-2. Could you explain, at the 5 bottom of Page 13. the agreement criteria which you used to 6 determine whether or not two values are close enough in 7 agreement?
8 A (Harner) When we are evaluated by the NRC in 9 inspections, a number of times they will bring samples with 10 them that we have to analyse. They are unknown to us, known 11 to the NRC inspectors. We then have to meet a set of 12 criteria that the NRC has developed that is representative 13 of two different laboratories analyzing the same sample.
14 That criteria is outlined in the inspection document that is 15 ref erenced on Page 13 the NRC document. It 's a simple two 16 mathematical step where you compare your number to their l
( 17 number. That gives you a ratio. You then go to a table 10 that says if your ratio that you've just calcuieted comes 19 between these two numbers, your number is it. ugreeraent with l
20 the referee number which is the NRC number. So that you can 1
21 compare or they compare your analysis capabilities to their l 22 analysis capabilities, and they are considered the experts 1 23 or referees. This is a common comparison that we live with
{ It 's an NRC tool that they use to 24 at the power plant.
l 25 evaluate us at the power plant. I use that same criteria to l O Heritage Reporting Corporation (202) 628-4888 1
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2 the results of that comparison are found in the table on [
l 3 Page 14. :
4 Q And the strontium 90 was not able to make that (
5 agreement criteria? (
6 A CHarner) Right. The strontium 90 did not fit !
l 7 into the agreement on that particular test. l I
8 JUDGE BLOCH: So what happened next? The NRC does ,
I 9 this test to calibrate how you're doing on the strontium 90 l r
10 that didn 't match. What followup occurred? l i
l 11 THE WITNESS: (Harner) This was not one of those i 12 tests. This was not done as an inspection. This was done. !
} 13 the NRC wanted to see for their own analysis what our 14 process water looked like to verify or validate the numbers i
] !
l 15 that we have been generating at GPU. They have been )
16 watching our data as we generated it over the last ten 17 years. This was a sample to referee. It was not an ,
18 individual inspection. If it were an individual inspection, f l 19 and one of the numbers was not in agreement, we would then L
20 go into a checking mechanism to see was it an individual j
- 21 error that was made in the analysis or was it something j o 22 systematic or whatever it might be. We would investigate ;
I 23 the problem until we found the reason for the inconsistency. !
t 24 JUDGE PARIS: Were you able to determine why their 3
25 estimate of strontium 90 was so much lower than yours? ,
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() i THE WITNESS: (Harner) One of the things that is .
2 outlined in the testinony is that our procedures have built-3 in error into them, uncertainty. or conservatism built into l t
4 the procedures. In normal strontium 90 analysis on a liquid l 5 done by a routine laboratory that does it on the outside. !
l 6 they use what is known as a 14-day method where you separate j 7 the strontium and the yttrium f rom each other and them you f 8 watch the yttrium, which is the daughter of strontium, grow ;
9 back in over a period of time. and you do a number of j 10 analyses. A 14-day method is not practical for us to use at !
t i
11 the plant, so we 've developed two shorter nethods that are [
i 12 not as accurate as the 14-day method so that we have some f
f 13 type of process control method at the site that we can use [
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( 14 for routine analyses. ,
i
- iS Our rapid turnaround analysis we consider having a
! 16 in the low levels that we 're looking at for this particular !
. i j 17 analysis, we consider it to have about 100 percent error. j i
. 18 So if the number would be 5 even minus, or let 's take an (
) [
19 easier number. 4 even minus 5, we would consider that a high l t
i 20 number and the value naybe being like 2 even minus S. So fi
! 21 we have an uncertainty, a very big uncertainty bar around f I
22 the number, but we always err on the conservative side so !
I
} that we know what we are -- we know where we are, even j 23
- 24 though we are not exactly accurate, and we know the nethod 25 is not an accurate methoo, so that we then, looking at the l
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() i data from RESL, we saw that their number was lower than 2 ours, which was not surprising. We then looked at some of 3 the reasons why it may have been even lower than what we 4 would have expected it to be and one of the factors that 4
5 could be involved would be particulate. There are small j 6 amounts of particulate in the accident-generated water which j 7 may be resin fines or zeolite fines which hold strontium or 8 cesium in the fines. And we have had to go to a couple of j 9 extra steps in our procedures to release that activity from f 10 those particular into the bulk liquid where it is then l 11 easier to be analyzed.
1 12 I do not know if RESL took those extra steps to {
j 13 look at that activity in the particulate. If they did not, O
1 v it that may be a possible reason for theirs being slightly 15 lower. When you go through the liquid extraction, you do 16 not do anything with the particulate. l 17 JUDGE BLOCH: If there is such a large error )
18 bound, why do you show it as plus or minus 0.2? i 19 THE WITNESS: (Harner) We report, this method was 20 done by the 72-hour method which is again in the procedure.
! 21 The rapid method we have a plus or minus 100 percent error ;
l l 22 bar on that method. The 72-hour method is a more accurate j f
23 method that we 're using. It 's still not as good as the 14-I I
- 24 day method. But we only attribute counting statistic error l I 25 to it and the reason, one of the reasons being to separate f i !
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() i it from the other method. It 's more accurate but we know 2 it 's not perf ect.
3 JtJDGE BLOCH: Is the error bound here correct?
4 Plus or minus 0.2?
5 THE WITNESS: (Harner) That is counting 6 statistical error. The other additional error is in the 7 procedure itself.
8 JUDGE BLOCH: Systematic.
9 THE WITNESS: (Harner) Systematic error in the
-10 method.
11 BY MS. SKOLNIK:
12 Q So because of these errors in analysis. are we 13 actually not being presented with a totally true value of 14 each of the, of the tritium?
15 A (Harner) This is strontium we 're talkinE about, 16 Q Okay. And the other radionuclides? So each time 17 we look at a figure, for any radionuclide. it 's not a true 18 value?
19 A (Herner) It 's an analytical measurement and there 20 are no true values when you do measurements. There is 21 always an uncertainty including measurements such as inch, 22 feet. mile, any type of measurement has an uncertainty l
l 23 associated with it. And when we do radioactivity type of 1
24 measurements. they will have an uncertainty. Radioactive 25 decay has a random type process. It 's never perfect ly the l
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() i same each time. You look at something. for every 60 seconds [
2 it 's not going to give of f five disintegrations. Sometimes !
i-3 it might be four, sometines it might be six. So there is an ;
4 uncertainty involved with radioactivity measurements. ;
i 5 always. And that error or uncertainty is reported in this (
l 6 table. [
t 7 Q So then with the total contents of the accident- !
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8 generated water, the errors from all -- the total quantity [
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. l 9 would contain the sum of all the errors that had been made !
L 10 along the way in analyzing the accident-generated water? j
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- 11 ' AR . BAXTER:
. I 'm sorry, but the term errors -- I l 12 thought the witness was talking about uncertainties. Are 13 you talking about something else?
O 14 BY MS. SKOLNIK j t
j 15 Q Uncertainties. I meant uncertainties. l t
16 A (Harner) The measurement has an uncertainty. The l I 17 measurement of the volume would have an uncertainty also. (
18 And they do add. yes. It 's not each individual one. though. !
l 19 It's more or less a general type of error for each type of !
I j 20 analysis. :
a 21 JUDGE BLOCH: I 'm not sure what you mean when you !
~
- 22 scy they do add. What do you mean by that? l 23 THE WITNESS
- (Harner) Well, if I took -- well. I j 24 guess -- I was looking at the volunes of each indi-idual (
25 tank. !
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() 1 JUDGE BLOCH: When you look at the table for 2 example on the tritium in your own testimony, would all of 3 the errors add up? Table 1. Page 19, 4 (Pause) 4 5 THE WITNESS: (Harner) There is an uncertainty 6 involved with the measurement of tritium when we come out 7 with a concentration of micro-curies or milliliters. You 8 will have an uncertainty associated with that. That 9 uncertainty, then, could be carried through your 10 calculations and the uncertainty of any other measurements 1 11 that you may have into a propagation of uncertainty and cone l 12 up with another uncertainty at the end.
1 13 JUDGE BLOCH: I was just concerned about what you O 14 said about adding. I t 's not like if there 's a 5 percent 15 overage in one place and 5 percent in another, now you 're 16 over 10 percent. and then you 're over 15 percent.
i 17 THE WITNESS: (Harner) I don't think they add 18 strictly one to the other.
29 JUDGE BLOCH: I just wanted to make it clear.
20 THE WITNESS: (Herner) There 's a formula that you 21 would have to go to for the propagation of error, or many
, 22 different measurements.
23 BY MS. SKOLNIK 24 Q But the conclusion is that the 1.020 curies of 1
25 tritium or the total amount of strontium 90 may not have
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2 JUDGE BLOCH: Do we know the error bounds around 3 the 1.020?
4 THE WITNESS: (Harner) No. we 've not calculated 5 it.
6 JUDGE BLOCH: Could it be an order of magnitude?
7 .THE WITNESS: (Hofstetter) No. I 've looked at the 8 errors associated with some of these measurements, and while t
9 you can't quantitatively determine the error in all cases j 10 because of the uncertainty of measuring the volumes. I think 11 we 're probably looking at a 10 to 15 percent error on the 12 total number of curies, for instance, as determined by this 13 method.
14 JUDGE BLOCH: Is it conservative to say that here 15 would not be more than 15 percent more than this?
16 THE WITNESS: (Hofstetter) And also 15 percent 17 less.
18 JUDGE BLOCH: Well, of course, we 're not worried 19 about the 15 percent less.
20 THE WITNESS: (Hofstetter) But the errors of 21 course are randomly distributed about their true value.
22 JUDGE BLOCH: Which means it is more likely that 23 it will be centrally tended, but there is a possibility of 24 whatever the error bound is that you could hit the upper 25 bound, too?
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'(_) 1 THE WITNESS: (Hofstetter) Yes. that 's right.
2 there is a possibility that you could hit. !
l 3 BY MS. SKOLNIX: ,
4 Q If you don't mind just goinC back to sampling, is 5 there an error involved when you are drawing a sample f rom 6 any location, is there an error involved in whether or not l 7 that sample would be representative of the total contents of j 8 any of the locations?
J 9 A (Harner) As I stated before, any measurement that 10 you do is going to have an uncertainty involved with it. We i
, 11 have written our prceedures around the best method to take a !
I i
12 sample based on ASTM standards and if you read through the l
ASTM standards. if you can recirculate or mix a volume to ;
13 3
() 14 take the sample, is the best way to take the sample, it is ;
15 then representative. In nost of our systems we can do that.
16 Another method is to take samples from various locations. ;
t 17 which we also do in some cases. And with that, is some type j
- 18 of uncertainty whether you nave an absolute representation
! 19 of the sample or of the source. l 1 .
20 Q So can you cireciate -- you said some of their !
21 tanks could be circulated and sone of them couldn't. Could I
22 you ident' fy the ones that couldn't be circulated? You l l l 23 could just use that Table 1 on the back of your testimony.
24 A (Harner) Do you want me to go down through the l
! 25 whole list?
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2 A (Harner) I 'm not sure. I can answer that 7 f
3 question. But I 'm not sure how you define "circulated. " I
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4 mentioned two different methods of taking samples that give l 5 you a representative sample. What e::actly are you talking ;
6 about? f f
r 7 Q I mean a mechanism by which you con make the 8 water, move the water around so that it, like if anything is ;
i 9 resting on the bottom. it can be circulated equally f I
10 throughout the water. ;
i 11 JUDGE PARIS: You 're talking about a mechanical 3 12 circulation?
l 13 MS. SKOLNIK: Yes. Thank you. ;
- I j 14 THE WITNESS: (Harner) The reactor coolant system j 15 can be rer.irculated. process water both process water t
- 16 storage tanks can be recirculated, cor.densate storage tank i
i 17 can be recirculated, evaporator condenaate test tanks can be i I 18 recirculated. EPICOR-2. nll spec.. EPICOR-2 cleaned, can be
! T 19 recirculated. Spent fuel pool B can be recirculated. SDS ;
l ,
20 monitor tanks can be recirculated. RC bleed holdup tanks can 1
21 be recirculated, borate water storage tank can be i'
22 recirculated, neutralizer tanks can be recirculated.
l 23 miscellaneous waste noldup can be recirculated, contaminated l 24 drain tanks can be recirculated. Chemical cleaning building j 25 sump cannot be recirculated, auxiliary building sump cannot l
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3 end of the transfer cenal can be recirculated.
4 BY MS. SK0LNIK ;
t 5 Q So the only three that can't be circulated is the j f
6 chemical cleaning building. the auxiliary building sump and l 7 the reactor building basement?
8 A (Harner) Yes. The sumps are small containers r 1
l 9 that do not have a recirculation system and of course the {
10 basement is not a holding tank, a designed holding tank that 11 has a recirculation system. We 've already discussed the i 12 mechanisms in there about mixing. l
. 13 Q W th regard to your analysis of carbon 14. there >
i 1
C:) 14 were three different values given.
l l 15 MR. BAXTER: Do you have a page reference. Ms.
- 16 Skolnik? l 9
- 17 MS. SKOLNIX: Page 15. i BY MS. SKOLNIXt 18 i
i 19 Q The last s t atement -- I 'n sorry. Turn to Page 16. f l
20 line that begins with the word "The" on Line 6. And you !
21 state that the carbon 14 values listed vary. but that GPU l
22 and the NRC appropriately have used the 1.0 E to the minus 4 (
23 Westinghouse average concentrations for the dose estimate.
24 so that you are saying that the 1.0 E to the minus 4 was i, t
20 used on Table 2. 2 by the NRC. But that wasn 't the O Heritage Repor t i ng Corporation (202) 628-4888
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- 2'70 0 1 we imanoe e veiue. rne *>etimauee e veive 3.0 e to the 2 minus 4. Could you explain?
3 JUDGE ELOCH: Could you refer to youc cource for l l
4 the Wentinghouse value, please? '
5 MS. SKCLNIK Yes. On Page 15.
l 6 BY MS. SKOLNIK:
1 Q And in fact, the value 1. 0 E to the minus 4 -- I'm l l
8 not sure -- is that GPU's value?
l 9 JUDGE BLOCH: First. Mr. Harner. could you explain l 10 l t if there is a dif ference between the 1.0 E to the minus 4 on i i
l 11 Page 16. Line 8 cnd Page 15, the fourth line :.0 Answer 15?
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. THE WITNESS: CHarner) No. There are two 2 analyses that we 're talking about. One is of a tank that 3 was done in.1985 by Wnetinghouse.
4 .Along with thet single analysis of PWST-2, three 5 other samples were also snalyzed of processed water.
6 They were the EPICOR, offspaking, clean, and the 7 other PWST tank I think.
- 8. PWST-2 from Westinghouse analysis was three even 9 minus four. The one unit of minus four on the following 10 page is a mathematical everage, an estimate of all the 11 processed water.
12 It .is not. 1-E to the minus 4 is not the enalysis 13 of PWST-2. It 's an average number based on the other
\ 14 san:ples clang with the PWST-2 sample that was analyzed.
15 So wt.at you 're looking at is a single sample of 16 PWST-2 whicn *ue 3-E to the minus / and a mathematical 17 average of other semples of 1-E to the minun 4.
18 Q Okay.
19 A (Harner) And the average had other lower numbers [
20 included with it so that the average is lower than 3-E to 21 the minus 4, 22 Q But the 3-E to the minus 4 is the amount of carbon 23 i m, : would be going into the evaporator from the PWST-2.
24 I- s3uld he 1.1 times 10 to the n.inus 4 It would 25 L; that Weat2r.ahouse value?
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) 1 A (Harner) That 's true.
2 Q Right.
3 A (Harner) That Single tank.
4 Q Right.
5 A CHarner) Has a number of 3-E to the minus 4. The 6 average used for dose calculation was 1-E to the minur 4.
7 Q But, the only -- you 've worked out the average 8 mathematically, but the only sample you have is 1.0 E to the 1
9 minus 4?
10 A (Harner) No, I said we had --
11 MR. BAXTER: Judge Bloch, this is being 12 repetitious and it 's explained in the first instance at the 13 top of page 16 clearly.
O' 14 It 's based on the average of analyses performed by 15 Westinghouse in early 1986 We 're going over what 's t. ceedy 16 stated in the directory. We 're going over it several times.
17 JUDGE BLOCH: The one number is a single reading 18 and the other is an average. So there is one tank that has 19 the single reading and the other is an average.
20 MS. SKOLNIK: Yes, and I think what I was trying 21 to -- what I was trying to put on the record was that, that 22 reading from the Westinghouse, from the PWST-2 would be the 23 actual concentration of carbon 14 that would be going into 24 the evaporator.
25 JUDGE BLOCH: From that one tank.
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(_) 1 MS. SKOLNIK: Yes.
2 JUDGE BLOCH: That 's correct.
3 MS. SKOLNIK* Yes. I wented te put that on the A record.
5 JUDGE BLOCH: Tha' 's t rue.
6 BY MS. SKOLNIK:
7 Q I'd like to address the issue of the --
8 JUDGE BLOCH: Ms. Skolnik, if you want to clarify.
9 if it 's in the testimony, it 's already in the record.
10 MS. SKOLNIK: Okay.
11 JUDGE BLOCH: You don't have to ask a question 12 about it.
13 MS. SKOLNIX: Yes.
() 14 JUDGE BLOCH: If it 's in there and it says so much 15 of the PWST. you don 't have to ask any questions at all.
16 You can make a finding about that.
17 MS. SKOLNIK: I want to address the sot Je term 18 for tritium, the issue, that 's still to be rssolved.
19 BY MS. SKOLNIK:
20 Q Mr. Hofstetter, you say that there is many 21 computational methods available in the literature. Does 22 anything make any of those computational methods wrong?
23 MR. BAXTER: What, where are we in +he test! mony.
24 please?
i 25 MS. SKOLNIX: I 'm sorry. Page six.
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(,) i 'THE WITNESS: .(Hofstetter) Your question was, is 2 there anything that makes ti.ese computational methods wrong?
3 MS. SKOLNIK Yes.
4 THE WITNESS: (Hofstetter) I 'm not sure that I 5 can answer right and wrong. I think that the computational 6 methods are different depending upon the intent. the purpose 7 to which they are to be used, the degree of complexity of 8 the models, and what input parameters are used will 9 determine how well these models in predicting the 'nventa'/y 10 of radionuclides that might be produced in a ra6:s uc.
11 BY MS. SKOLNIK:
12 Q Are you familiar with the origin-2 code?
13 A (Hofstetter) I have never run the origin-2 code 14 but I'm f amiliar with what it does, yes.
15 Q Are you familiar that it 's used because it 16 calculates the activation product?
17 A (Hofstetter) It is one of the codes that 's used -
18 - it does include calculation of activation products, yes, 19 that 's correct.
20 Q And tritium is an activation product?
l 21 A (Hofstetter) Tritium is both a fission product 22 and an activation product.
23 Q So when the origin-2 calculated that there was a 24 tritium inventory of 8,794 curies, could you address whether 25 that would be. why that might be incorrect?
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i 1 A (Hofstetter) Again, I think that it 's a matter of 2 how. accurately you 're able to input the parameters by which 3 these codes run.
4 Parameters like the radiation history, how long r( .
5 the isotopic enrichments were, the various core components, 6 how long the power was operating in the reactors, was it 7 full power, was it operating for long periods of time, was 8 it half power or one-third power operating for various 9 periods of time.
10 I think the important thing is that tritium is a 11 minor nuclide if I can use that problem or that word.
12 Minor in the fact that it is not produced ist high 13 yield. It is produced at only low quantities and 14 consequently the inherent errors in the model are such that 15 none of these codes are extremely accurate when you start 16 looking at the extremes, very low atomic number and very 17 high atomic number fissions, because they are not produced 18 frequently.
19 Perhaps one out of 10.000 fissions produced as a 20 tritium. So it 's a very inf requent process. And so the 21 error is large. larEer than something that would be produced 22 at high yield.
23 JUDGE BLOCH: If we have actual measurements, why 24 would we use a model?
25 THE WITNESS: (Hofstetter) Which is the point of l
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2 JUDGE BLOCH: 'I would like an answer to that 3 question. Is there some reason to use a model here?
4 THE WITNESS: (Hofstetter) Well, yes, there are.
5 There are ways for instance, you can use the model to 6 determine what are called isotopic ratios.
7 In our particular case at TMI, perhaps you can 8 take some core debris samples, determine accurately the 9 isotopic ratio of two isotopes of the same element for 10 instance and get some idea where that particular portion of 11 the core debris came from in the core.
12 But you 're looking at those things which are 13 produced in very high yield and av the accuracy is much 14 better.
15 So I think it 's a matter of the intent to which 16 you are trying to use these models.
17 In our case and as I say in my testimony, the j 18 model predictions really are not nearly as accurate nor as 19 relevant as the actual experimental measurements 20 inventories.
! 21 BY MS. SK0LNIX:
22 Q However, isn 't it true that GPU has used models in 23 order to plan for decontamination of the reactor?
l 24 A (Hofstetter) As I said, the models can be used in l
25 order to determine the estimated amounts of radioactivity l
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() 1 that might be expected to be encountered during various 2 defueling operations.
3 These are the ones that are produced in high yield 4 and that directly affect the defueling operations, cesium 5 and strontium, those things that are produced 10 percent of 6 the time perhaps for fission.
7 And_those are important from assessing what are 8 the various options insofar es defueling.
9 But in the case of tritium and those extremes, it 10 is much more accurate to get an inventory of the number of 11 curies for instance of tritium for this particular process, 12 the evaporation of it.
13 It 's much more accurate to do a tritium inventory 14 than to rely on a model prediction.
15 MR. BAXTER: GPU does use models to proj ect what 's 16 going to be done with work but as we get actual data then we 17 use the actual data which is more realistic or whatever work i
18 we happen to be doinE-19 So if you 're looking at something in the future.
'- you use a model and as you gain more and more information, 21 fill in with the current information that you know, and 22 therefore you have a much better handle on what you're doing 23 which is what we did with the accident generated water, 24 we 're using the actual analyses rather than the proj ections 25 that are coming off of a computer model.
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() 1 BY MS. SKOLNIK:
2 Q But doesn't GPU keep an inventory of all of the 3 radionuclides so that they car. determine exactly how much 4 has gone into the atmosphere and how much is still in the 5 reactor so that they know what they 're dealing with?
6 Obviously you have analysis of the accident 7 generated water for this point in time. But isn't there a 8 use for the model because it shows what was there at the 9 beginning?
10 A (Hofstetter) And we used the model initially to 11 know what was there at the beginning, but now as I said, as 12 we gain more information, more actual information, we use 13 that instead of the mode .
14 So the model said there may be X amount of 15 something there and we assumed that until we knew better.
16 And then once we knew better, then we used the 17 actual information.
18 JUDGE BLOCH: Is it in fact true, there was a 19 premise in the question. Is it true that the model shows 20 what was there in the beginning?
21 THE WITNESS: (Hofstetter) I think that initially 22 some of the models, origin-2 in particular to do a 23 reasonably job of estimating how much of the principal 24 fission product, cesium and strontium were there depending 2
25 again on how good you are at knowing the operating power i
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() 1 history.
2 And so it 's useful in that mode. None of these 3 models however, predict the conditions of or shortly after 4- the accident insofar as trying to get some idea of how much 5 was released.
6 These models basically don't address that 7 question. And so the amount that was released and what have 8 you if we can do a reasonably accurate inventory we can back 9 subtract and get some estimates of how much were released 10 using the model predictions for those things which occur at li high frequency.
12 JUDGE BLOCH: So less than the whole source term 13 was released?
14 THE WITNESS: CHofstetter) That 's correct.
15 BY MS. SKOLNIK:
16 Q So even though you might have a figure like, 8.790 17 curies of tritium and even though you have not finished the 18 cleanup at TMI, unit 2, you feel there 's no error in the 19 sampling analysis that you have a correct estimate of 1.020 20 curies even though obviously there was more in the core ,
21 after the term of the accident and even though you have not 22 released?
23 MR. BAXTER: Obj ec t ion. The questioner is 24 assuming that the models know reality. The witnesses have 25 testified that models predicted what might have been there I
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() 1. and as we gain analytical info *mation, we replace the 2 model 's predictions with the ant lytical information.
3 Ms. Skolnik keeps repeating as a model was --
4 that 's not what the testimony is.
5 JUDGE BLOCH: The obj ection is sustained. 'the 6 models predict and they then have to be refined in light of ,
7 the data.
8 MS. SKOLNIK: Yes, I guess with TMI 2 everything 9 has been refined since the time of the accident because it 10 is a research and development center.
11 So the point I'm trying to make is if the model 12 predicted a certain number of curies, how can they be sure 13 that all of those curies will not somehow find their way 14 into the water before the end of cleanup?
I 15 MR. BAXTER: Well, the entire testimony is 16 designed to establish why we have confidence in the amount 17 of tritium in the water. That 's what all of this testimony 18 is about.
19 JUDGE BLOCH: You 're correct in stating that there 20 was a theoretical estimate of a certain amount of curies.
21 But there is other testimony about direct physical 22 measurements. l 23 You 're stating your belief that if a theory said 24 there was a certain amount of curies, there had to be that l 1
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,- -t 281 I ,) 1 The testimony is otherwise. Theories are 2 sometimes wrong.-
3 MS. SKOLNIK:- Yes, theories are sometimes wrong R
4 and the point is GPU uses these theories to make decisions 5 on the cleanup of unit 2.
6 JUDGE BLOCH: Okay. If you have testimony that 7 would support your beliefs that there actually were 8,794 8 curies, you should produce it. These people aren't going to .
t 9 tell you that that 's true.
10 They're telling you the opposite, that, that was 11 an early estimate and that their physical estimates are very 12 different.
13 MS. SKOLNIK: Okay. I 'll try to re-word my 14 question.
15 JUDGE PARIS: Tritium decreases both because of a 16 physical decay. radioactive decay and because of 17 evaporation.
18 MS. SKOLNIK: Tritium, radionuclides have also
- 19 been released from the fumes and from the other means of 20 cleanup during the 10 years of cleanup.
21 So for example, in September, Krypton 85 was 22 recently released from the fume. So what I'm trying to get 23 to is, is it possible that tritium could be released during 24 the remainder of the cleanup?
25 JUDGE PARIS: Why don 't you ask him that?
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. 2 Q is it possible that tritium might be re: eased 3 during the romainder of the cleanup? l 4 A (Hofstetter) Into the water?
l 5 Q Into the water.
l 6 A (Hofstetter) Cer tainly it 's possible. I think 7 that we have not seen it to date with even the most 8 aggressive defueling that we have performed now which 9 includes underwater plasta arc torch cutting and the pretty 10 aggressive methods that we 've used to defuel. Core boring li' which generates certainly new surfaces and the like and the 12 nampling program that we had showed no increases in the 13 tritium concentration in the reactor cooling system as these 24 things were occurring.
15 To flat say, no, it 's not possible, I cannot say 4
16 that. But I think that the chances are very alim 17 considering what we 've done in the past.
18 Q But the chance isn 't completely ruled out? That 's 19 the point I 'm t rying to make.
20 JUDGE BLOCH: Should there be some technical ,
21 specification here that as the amount of tritium goes above 22 a certain amount that you 'd reconside r the alternative?
23 You actually found that there were 4,000 curies 24 instead of a 1,000, would you still go forward with the 25 evaporation? [
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283 (m_) 1 THE WIT 14ESS: (Hofstetter) Even the core debris 2 samples that we have taken and have destructively analyzed.
3 have not shown any significant quantity of tritium.
4 I didn 't answer your question but I think it 's 5 very remote, the possibility that in fact that we would see 6 large releases of tritium from the fuel or fuel bearing 7 components.
8 BY MS. SKOLNIK:
9 Q This may be remote but it 's possible and isn 't it 10 also true that -- I mean you haven 't penetrated the bottom 11 of the reactor vessel yet, have you?
12 A (Hofstetter) We 've taken semples.
13 Q But as you 're going in there, the material inside 14 there does break up and that was why the krypton 85 was 15 recently released?
16 JUDGE BLOCH: Do you know about that? Do you know 17 about the release of the krypton 857 Is it analogous? Is 18 there a possibility that in some way there 's also a large 19 amount of tritium that might be released?
20 THE WITNESS: (Hofstetter) Well, first of all 21 there was not a large amount of krypton 85 released. It was .
22 a very small amoant.
t 23 And we had not seen it, we have not seen the 24 krypton 85 being released previously with the defueling thut 25 we have done.
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,_j i There 's not a reason to believe that the fuel 2 that 's in the bottom of the vessel is that much different 3 than the fuel that has been up in the upper regions of the 4 vessel. ,
5 The krypton 85 that was trapped within pockets 6 were probabl.y very small on maybe on the molecular level in 7 the fuel.
8 The tritium may be there also but not being a gas, 9 it would have to be in a liquid form.
10 It 's not going to just exist as a pocket of gas as 11 tritium. It would astridiated water which would flow in and 12 out of the fuel pieces in the debris.
13 I wouldn 't expect tritium to be trapped in the 14 fuel. As Ken said, we have seen a number of samples. We 've 15 analyzed quite a few fuel samples from that region and also 16 all other types of core samples.
17 We have not seen any pockets of tritiated water in 18 the fuel. But if you 're playing what if. I guess it 's 19 possible.
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JUDGE BLOCH: Ms. Skolnik, let 's wrap this one t 1 2 subj ect up for this evening.
3 MS. SKOLNIK: All right.
4 BY MS. SKOLNIK:
5 Q In your statement. Page 7, bottom of the page, you 6 cay, since tritium is not produced in the fuel after the 7 fissioning process has stopped, there has been no tritium 8 added since March, 1979 Added to, you 're talking about the 9 accident-generated water?
10 A (Hofstetter) There 's no tritium produced.
11 Q Yes. Okay. But there has been an addition, has 12 there been an addition of the tritium to the water over that 13 time?
14 A (Hofstetter) Yes, there has been, tritium has.
15 there has been no additional tritium produced in the 16 reaction. The accident-generated water at that time I
17 certainly was nebulous and it 's not anything like the 18 characteristics of the present accident-generated water
$ 19 insof ar as where it 's located and those kinds of things. So 20 I guess it 's semantics about what you mean by released or 21 produced. There's been no additional tritium generated that 22 would go into the total tritium inventory. But its 23 positions and locations certainly have changed post 24 accident.
25 Q So it has moved out of some of the material into
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2 A (Harner) No. It has moved from one storage 3 location of water to another storage location of water.
4 JUDGE BLOCH: Ms. Skolnik, this paragraph only 5 relates to the upper bound tritium source term. It doesn 't 6 say what's in the water. It says no more was produced. ,
7 This doesn't relate to adding it to the water, as I read 8 this paragraph.
,9 MS. SKOLNIX: Well, I think the point I'm trying 10 to make is even --
11 JUDGE BLOCH: They 've talked about some additions 12 to the water.
13 MS. SKOLNIX: Yes.
14 (Pause) 15 MS. SKOLNIK I'm finished.
16 JUDGE BLOCH: Okay. Ms. Skolnik, if you find 17 things that are really important to you and that have to do i
18 with the merits of this case, I think you 'll find that the 19 Board will actually ask questions to assure the adequacy of ,
i 20 the record. But we do want time here to be treated as 21 precious, because it is, for everybody. And it really has 22 nothing to do with how long it 's taking to dispose of the 23 water. We watit the time to be spent together here to be 24 productive. So I just ask that you look at your questions 25 from that standpoint. Does it relate to the merits? Is it
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() 1 going to get us somewhere? And I know it 's hard for you.
2 because this isn 't your field. You studied hard into it.
3 But it 's important that the hearing be efficient, too.
4 I want to thank everyone. And if there is no 5 obj ec t ion, v>e 'll be resuming at 9:00 o ' clock. Yes?
6 MR. BAXTER: Do we need to discuss again who is 7 going to appear next? I t
8 JUDGE BLOCH: I think we 're going to continue with 9 these witnesses and then the staf f 's witnesses are next.
t 10 MR. BAXTER: Okay. Thank you.
11 JUDGE BLOCH: Off the record now.
12 (Whereupon, at 5:33 p.m., the hearing recessed, to 13 reconvene the following day. Tuesday, November 1, 1988, at
! 14 9:00 a.m., at the same location.)
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t ) CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name: General Public Utilities Corporation, et al.
Three Mile Island (Unit 2) License Amendment Application Docket Number: 50-320 OLA Place: Lancaster. Pennsylvania Date: October 31, 1988 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken stenographically by me and,
( -) thereaf ter reduced to typewriting by me or under the direction of the court reporting company, and that the 4
trLnscript is a true and accure.te record of the foregoing proceedings. s LaL OW' %
Signature typed: Juan Rose i
Official Reporter Heritage Reporting Corporation i
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