ML19309H742

Designation & Analysis of Compliance Re Radioactive Gaseous Releases Subsequent to TMI-2 Accident, Directed to Jr Kohr of Susquehanna Valley Alliance

ML19309H742
Person / Time
Site:	Three Mile Island
Issue date:	10/01/1979
From:	Kosarek L TRACE METAL DATA INSTITUTE
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NUDOCS 8005190664
Download: ML19309H742 (10)

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TRACE 3f ETAL DATA INSTITUTE, water Mution Assessment anons sisises-stn POST OFFICE Box 12457 - EL P ASO, TEXAS 79912 80 051@ ((y Designation and Analysis of Compliance regarding Radioactive Gasseous eleases subsequent to the TMI-2' Accident

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Jean R. Kohr Susquahanna Valley Alliance 121 East King Street Lancaster, PA October 1, 1979 ,

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by Louis J. Kosarek

! Director

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This document is concurrent with a request by Jean R. Kohr, letter dated September 6, 1979 concerning a review of the regulations which govern gasseous emissions at the Three Mile Island (TMI) nuclear power generating i L plant. The focus of this review is:to establish gasseous effluent discharge regulations in perspective with actual documented emissions which have oc-curred subsequent to the accident on March 28, 1979 at Three Mile Island -

Unit 2 (TMI-2).

The regulation of unrestricted gasseous effluent discharged fr a the two (2) Bt1 units is based upon the operating license, NUREG-0432 - Appendix B - section 2 (1), the. code of federal regulations Title 10 - Part 20 -

Appendix B - tkble 2 - column I (2), and all regulations superceded by the code of federal regulations Title 10 - Part 50 - Appendix A-Q (3). These regulations, as specified in the license, are to incorporate a gasseous dis-persion' factor (X/Q) of 6.7 x 10-6 sec/m 3 . The basis of.the regulations contained in the license are established fra CFR Title 10, Part 20 (2).

The means by which a maximuu allowable gasseous radioactive discharges are calculated is to maintain a s,n of the ratios of the radionuclide concen-tration to the maximum permissible concentration 0IPC) much less than one.

Table 1 lists various gasseous isotopes and the limits specified in CFR Title 10, Part 20. The limits are in engineering abbreviation to save space. ,

The valve "E( )#" expresses ten to the ( )# power multiplied by the first  !

numeral. An example is, 6E-9 equals 6x10-9 or is equivalent to 0.000000006 4

and is a very small number. Another example is, 2.8E+4 equals 2.8x10 or is equivalent to 28,000. The units of these regulations.are uCi/ml or Ci/m3 l which are both equal to each other.

l The maximum legally allowable radioactive gas discharge can be calculated by dividing the limit (Ci/m )l by the dispersion factor (sec/m 3) and the l

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resultant units are Ci/sec. B is maximum discharge rate when cultiplied by 1,000,000 equals uCi/sec. The value for the effluent limits pertaining to each gasseous radionuclide is listed in Table 1. As the effluent limits are averaged over a one year peri to optimize "a dependable source of power under unusual operating conditions;" the annual limits are also listed in I

Table 1. Rese gas discharge limits range from 9300 Ci/yr of Iodine-129 to  ;

190,000,000 Ci/yr for Tritium. -

ne operating license further defines the legal limits which designate compliant levels. Sectimt 2.1.2 segregates the isotopes listed in Table 1 as

1) halogen and other gasseous nuclides with half-lives in excess of cight (8) days, 2) gross gasseous activity except for halogens and isotopes with half-lives longer than eight (8) days, 3) and gross gasseous activity averaged 1

i over any calendar quarter. He instantanecus release regulations governing

1. 1 are contained in section b and are 0.3 uCi/sec. The , regulation pertinent l to #2 are in section a and relate to the sum of the ratios of the radionuclide concentration to the maximum pennissible concentration (MPC) being less than or equal to 1.5 x 105 m3/sec. The regulations associatad with #3 are in' section c and are that the sum of the ratios of the nuclide levels to the MPC shall be less than or equal to 2.4 x 104 m3 /sec. (Table 2).

The key to understanding the gasseous discharge limitations,is that the operating license contains suggested regulations while CFR Title 10, Part 20 (2) designates the ultimate limitations plus all gasseous discharge values can be averaged over an annual period. Because of the fact that gasseous discharges can be averaged on an annual basis, the amount of discharge which exceeds the regulation can only be evaluated on an annual basis.

Presently, each gasseous radionuclide which was reported to be released as an aerosol will be reviewed in Table 3 regarding the total quantity of

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Table 1. Gasseous radionuclide discharge limitations - CFR Title 10 Limits of Effluent Annual Isotcpe Half Life Category :10 CFR 20 Limits Limits Reference (uCi/ml)

Brcmine-82 35.1hr Halogen 6E-9 896uCi/sec 2.8E+4Ci 1,2,3,4,5

-83 2.41hr - - -

-84 31.8m - - -

-85 3.0m - - -

Iodine-129 1.7x107y Halogen 2E-9 296uCi/sec 9.3E+3Ci. 1,2,3,4,5

-130 12.5hr - - -

-131 8.06d IE-8 1493uci/sec 4.7E+4Ci

-132 2.3hr 3E-8 4478uCi/sec 1.4E+5Ci

-133 20.8hr 7E-9 1045uCi/sec 3.3E+4Ci

-134 52.4m 1E-7 14925uCi/sec 4.7E+5Ci

-135 6.7hr 1E-8 1492uCi/sec 4.7E+4Ci Krypton-83m 1.86hr Noble Gas - - -

1,2,3,4,5

-85m 4.4hr 1E-7 14925uCi/sec 4.7E+5Ci

-85 10.3y 3E-7 44776uCi/sec 1.4E+6Ci

-87 75m 2E-8 2985uCi/sec 9.4E+4Ci

-88 2.8hr 2E-8 2985uCi/sec 9.4E+4Ci

-89 3.2m - -

-90 33s - -

Ruth 2-nium -103 37.5d Volatile 2E-8 2985uCi/sec 9.4E+4Ci 1,2,3,4,5

-106 .569d 3E-9 448uCi/sec 1.4E+aci Tritium 12.26y Liquid Gas 4E-5 5970149uCi/sec 1.9E+8Ci 1,2,3,4,5 Xenon -131m 11.80d Noble Gas 4E-7 59701uci/sec 1.9E+6Ci 1,2,3,4,5

-133m 2.26d 38-7 44776uCi/sec 1.4t+6Ci

-133 5.4d 3E-7 44776uci/sec 1 4Et6Ci

-135m 15.8m - -

-135 9.14hr 1E-7 14925uci/sec 4.7E+5Ci

-137 3.8m -

-138 17m

-139 43s - -

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Table 2. Licensee Regulations for airborne radioactive discharges (1)

Limit for licensee to Instantaneous Quarter notify NRC Limiting Eiffluent Calender (calendar quarter Isotcpe Half-Life Regulation Iimits Average Limits average)

Bremine-82 35.1hr 3 -

144uci/sec -

-83 2.41hr 3 - -

-84 31.8m 3 - -

-85 3. &n 3 - -

Iodine-129 1.7x107y 1 0.3uci/sec 0.024uci/sec 0.006uCi/sec -130 12.Shr 3 - -

-131 8.06d 1 0.3uci/sec 0.024uCi/sec 0.006uCi/sec -132 2.3hr 3 -

720uCi/sec - -133 20.8hr 3 -

168uCi/sec - -134 52.4m 3 -

2400uci/sec - -135 6.7hr 3 -

240uci/sec -

Kryp- -

ton -83m 1.86hr 2 - -

-85m 4.4hr 2 15000uci/sec 2400uci/sec 600uCi/sec

-85 10.3y 1- 0.3uci/sec 0.024uci/sec 0.006uci/sec

-87 75m 2 3000uCi/sec 480uCi/sec 120uCi/sec

-88 2.8hr 2 3000uci/sec 480uci/sec 120uci/sec

-89 3.2m 2 - -

-90 33s 2 -

Ruthe-nium -103 37.5d 1 0.3uCi/sec 0.024uCi/sec 0.006uCi/sec -106 369d 1 0.3uci/sec 0.024uCi/sec 0.006uci/sec Tritium 12.26y 1 0.3uci/sec 0.024uCi/sec 0.006uCi/sec Xenon -131m 11.80d 1 0.3uCi/sec 0.024uCi/sec 0.006uCi/sec

-133m 2.26d 2 60000uCi/sec 7200 1800uCi/sec -133 5.4d 2 60000uci/sec 7200 1800uCi/sec

-135m 15.8m 2 -

-135 9.14hr 2 15000uci/sec 2400uCi/sec 600uci/sec -137 3.8m 2 -

-138 17m 2 -

-139 43s 2 -

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Table 3. Documented gasseous C acharges Discharge Level Reported .

Relative to Isotope Half-Life Discharge (Ci Regulation Duration References Bromine-82 35.1hr - - - -

-83 2.41hr - - - -

-84 31.8m - - - -

-85 3.0m - - - -

Iodine -129 1.7x107y - - -

-130 12.5hr - - - -

-131 8.06d 14.1/26.84 low 3/28-4/30/ 6,7,9/6 3/28-4/12 -

-132 2.3hr - - -

-133 20.8hr 2.6 Icw 3/28-4/30 7,8

-134 52.4m - - - -

-135 6.7hr - - - -

Kryp- -83m 1.86hr - - - -

ton -85m 4.4hr - - - -

-85 10.3y - - - -

-87 75m - - - -

-88 2.8hr 6.1E+4/5.5E+4 0.65 3/28-3/29 6,8/7

-89 '3.2m - -

-90 33s - - - -

Ruthe- -103 37.5d - - - -

nium -106 36.9d - - - -

Tritium 12.26y - - - -

l Xenon -131m 11.8d - - - -

-133m 2.26d 1.7E+5/1.1E+6 0.12 3/28-4/6 6,8/7

-133 5.4d 8.3E+6/9.2E+6 5.7 3/28-4/30 , 6,8/7 1

-135m 15.8m 1.4E+5/1.7E+5 1.0 3/28-3/31 6,8/7

-135 9.14hr 1.5E+6/1.5E+6 3.2 3/28-4/3 6,8/7 l i

-137 3.8m - - - -

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-138 17m - - - -

-139 43s - - - -

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c!scharge, the duration of discharge, and the discharge level relative to CFR Title 10, Part 20 (2). The only gassecus halogen which was reported to

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be released was iodine. The two isotopes of iodine which were reported were I-131 and I-133. As designated in Table 3, a total of approximately 14.1 Curies of I-131 and 2.6 Curies of I-133 were reported to be discharged from March 28 to April 30. There is contention regarding a report documented in hUREG-0600 (6) which suggests a total discharge of 26.84 Ci. If the level of 14.1 I-131 release was averaged over its duration of release, this accrues to a value of 4.8E-6Ci/sec. This value multiplied by the dispersion factor (x/Q) results in a product of 3.2E-11uci/ml. This value is within the specified l limits of IE-8uci/ml. Utilizing a total discharge cf I-131 at 26.84Ci over 16 days, the final value is 1E-10 which is within specified limits (2).

The total release of I-133 took place over a period of thirty-four days.

H e accumulated release was 2.6 Ci and resulted in a discharge rate of 8.9E-7 Ci/sec and an overall value of 6E-12, which is within regulated guidelines (2).

H e release of the noble gas Krypton-88 was detected in gasseous effluents using thermoluminescent dosimeters (IDL's). The actual total amount l of Kr-88 which was discharged on the first day of the accident varies depend-ing on the source, but has been reported as either 6.lE+4 or 5.5E+4 Curies.

1 The discharge rate of Kr-88 calculates to either 0.70 or 0.64Ci/sec. Incor-parating the dispersion factor (x/Q), this results in a discharge value of either 4.7E-6 or 4.3E-6uCi/nl. This gasseous discharge value exceeds the dis-charge limitations by a factor of either 235 or 215. However, when the gasseous  ;

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discharge of Kr-88 is averaged over only an annual period, the levels of dis-  !

charge do not exceed the regulated guidelines (2).

The noble gas which was measured to be discharged in the greatest quanti-ties subsequent to the TMI accident was Xenon. Again, the documented levels of this noble gas varied with the source of documentation. To simplify matters, the icwest total values will be used to establish the strongest argument. The total quantity of Xenon gas which was released subsequent to t

the accident totalled to an exces) of 10 million Curies. Of the 10 million Curies of Xenon which were releashd, the majority was as Xenon-133.

The quantity of Xenon gas released between March 28 and April 30, was measured as being 8.3E+6 Curies. This radioactivity was measured by thenno-luminescent dosimetry. Integrating this gasseous discharge over the duration of the release, the release rate was 2.8Ci/sec or an annual rate of 0.26Ci/sec.

Applying the dispersion factor, the actual release concentration was 1.9E-5u-C1/ml and the annual release level is 1.7E-6uCi/ml. Caparing these values to the regulation of 3E-7, the annual gasseous discharge rate exceeds the annual regulations by a factor of 5.7 (2).  ;

The isotope Xenon-133m was also reported as an effluent gas subsequent to the accident and the total release of Xenon-133m over a ten day period was 170,000 Curies. This amount of radioactivity when averaged over ten days resulted in a release rate of 0.2Ci/sec or an antal rate of 5.4E-3Ci/sec.

Applying the dispersion factor (x/Q), this equals an annual value of 3.6E uCi/ml which is in compliance.

The fission product Xenon-135 was monitored using TDL's and the total amount discharged over a seven day period was 1,500,000 Curies. The actual discharge rate is 2.48Ci/sec with an annual rate of 4.7E-2Ci/sec. The annual x gasseous discharge rate multiplied by the dispersion factor results in a value of 3.2E-7 which is 3.2 times larger than the regulated limit of IE-7 (2).

The final isotope of Xenon which was evaluated regarding a gasseous effluent discharge was Xenon-135m. The quantity of 140,000 Curies of Xenon-l 135m was released frcm March 28 to March 31, 1979. The actual release ; te l

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was 0.40 Ci/sec and the annual release rate was 4.4E-3Ci/sec adjusting for dispersion, the annual gasseous concentratien of Xenon-135m was 2.9E-8uci/mi which is within regulation specifications (2).

4 Individually speaking, the meahured radionuclides which exceeded the speci-fied regulations were Xenon-133 and Xenon-135. As the regulations state that all known isotope ratios are additive (2), the total release of gasseous isotopes that were directly a result of the accident added to an excess of 10 million Curies (9,10) while actually exceeded the legal requirements by only a factor of 10.4. The measured gasses which were the source of the violations were only noble gasses and the legal halogen levels were not exceeded.

The conclusions reached in this designation and analysis of ccmpliance regarding radioactive gasseous releases subsequent to the Three Mile Island Nuclear Power Plant Accident are concurrent with conclusions reached in the aforementioned references: 6, 7, 8, 9 and 10. However,.it should be noted that references 7, 8, 9, and 10 did not address the factor by which the dis-charges exceeded the regulations.

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References

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1. hbclear Regulatory Comission.. 1978. Three Mile Island hbclear Station Unit 2. Environmental Technicil Specifications - Appendix B. NUREG-0432. {

2. Code of Federal Regulations. k978. Title 10, Part 20, Appendix B, Table 2, columa 1. pp 202-211

3. Code of Federal Regulations. 1979. Title 10, Part 50, Appendix A-Q, pp. 350-392.

4. Rowe, W.D. 1973. Environmental Analysis of the Uranium Cycle - Part II, NTIS #PB-235 805 (EPA 520/9-73-003-C).

5. Lederer, C.M., J.M. Hollander and I. Perican. 1967. Table of Isotopes 6th ed. John Wiley 4 Sons, New York, hY.

6. U.S. hbclear Regulatory Caraission. 1979. Investigation into the March 28, 1979 Three Mile Island Accident by Office of Inspection and Enforcement, hUREG 0600. July, 1979.

7. Metropolitan Edison Ccupany. 1979. Second Interim Report on the Three Mile Island hbclear Station Unit-2 (BfI-2) Accident. June 15, 1979.

8. Metropolitan Edison Ccupany. 1979. Third Interim Report on the Three Mile Island hbclear Station Unit-2 (BfI-2) Accident. July 16, 1979.

9. Civil Action #79-658. 1979. Defendant GPU's answers to Plaintiffs Interrogatories set #1. Attachment 1, July 18, 1979.

10. Civil Action #79-658. 1979. Defendant hbclear Regulatory Cmnissions' answers to Plaintiff's Interrogatories set #1. Tables 1 and 2.

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RELEJVtDJAN / 6 560 o

Dated: January 14, 1980 /

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) -

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR THREE MILE ISLAND ALERT, INC.

These interrogatories are filed pursuant to 10 C.F.R.

S2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation.

Licensee recognizes that Intervenor Three Mile Island Alert, Inc. ( " TM IA " ) may not now be able to ccapletely answer all interrogatories propounded below, since some areas are the subject of discovery by TMIA, although Licensee notes that it has already responded to two sets of TMIA interrogatories.

Licensee therefore requests that each of these interrogatories

, be answered within the time specified in 52.740b to the extent that responsive information is resenti av With respect to those interrog DUPLICATE DOCUMENT responsive information is not Entire document previously r'equests that revised answers entered into system under:

the discovery period establish ANO o O b December 18, 1979 First Specia No. of pages: hk[

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I Any reference to Intervenor Three Mile Island Alert, Inc.

("TMIA") shall be deemed to include all members of TMIA. When knowledge or information of TMIA is requested, such request includes knowledge or information of TMIA's members and, unless privileged, its attorneys. l The following definitions apply to each of the inter-rogatories below:

A. " Document" means all writings and records of every j type including, but not limited to memoranda, tapes, correspon-dence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, logs, speeches, articles, transcripts and all other records, written, electrical, mechanical or otherwise. I B. " Identify" means: l (1) With respect to a natural person, name, present or last known home or business address, present or last known job title or position, and the dates of tenure in that position, (2) With respect to a document, the type of document (e.g., letter, record, list, memorandum, memorandum of telephone or face-to-face conversation, etc.), date of the document, title of the document, subject of the document, name of person who prepared the document, and name of person for whom the document was prepared or to whom it was delivered.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1)

SERVICE LIST Ivan W. Smith, Esquire Karin W. Carter, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street Oak Ridge, Tennescee 37830 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township Washington, D.C. 20555 T.M.1. Steering committee 2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Commission Widoff Reager Selkowit: & Adler P.O. Box 3265 P.O. Box 1547 l Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105 !

• Person on whose behalf service is being made. Only Certificate of Service is enclosed.

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Ellyn Weiss, Esquire Chauncey Kepford Sheldon, Harmon & Weiss Judith H. Johnsrud Suite 506 Environmental Coalition on Nuclear Power 1725 Eye Street, N.W. 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16801 Steven C. Sholly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Holly S. Keck Marjorie M. Aamodt Legislation Chairman R. D. 5 Anti-Nuclear Group Representing Coatesville, Pennsylvania 19320 York 245 West Philadelphia Street George F. Trowbridge, Esquire York, Pennsylvania 17404 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Karen Sheldon, Esquire Washington, D.C. 20036 Sheldon, Harmon & Weiss Suite 506 Susan Barley 1725 Eye Street, N.W. 129 Cocoa Avenue Washington, D.C. 20006 Hershey, Pennsylvania 17033 Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218

• Person on whose behalf service is being made. Only Certificate of Service is enclosed.

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