ML20140C749
| ML20140C749 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/13/1984 |
| From: | Teper D GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL, NUDOCS 8406190428 | |
| Download: ML20140C749 (26) | |
Text
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UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COFliISSION V
DOCKETED
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'843pl 19 pj gj In the Matter of GEORGIA POWER CO.
Docket Nos. 50-424 g g.
50-425 (OL)
(Vogtle Electric Generatin6 Plant, Units i and 2)
Enclosed please find the amended basis for GANE's Contention number 2, Cumulative Effects of the Savannah River Plant (SRP) and Plant Vogtle, and rationale supportin6 thedadrassibility of the late-filing there of, i
- 1. The information upon which CANE's Contention is hacec was previously
" institutionally unavailable".
GANE has good cause for late-fillinC this contention. The information upca which GANE bases this contention is contained only in the " Final Envircnnental Impact State-m:nt(FEIS),L-ReactorOperation,SavannahRiverFlant(SRP),Aiken,SouthCarolina" (DOE /EIS-0108). The DOE did not release the FEIS until approximately May 25,1984:
therefore William Lawless, on behalf of GANE, did not have an adequate opportunity to review the FEIS and to interpret the Statement concerning the cumulative effects of SRP and Plant Vogtle prbor to $he May 30, 1984M rchcaring Conference. Mr. Lawless did address the concerns included herein at the prehearing conference however: the enclosed elaborates upon and sets to paper these concerns.
- 2. The Licensing Hearing in the Proper Forum in 'which to Consider the Cumulative Effects of SRP and Plant Vodle Oberations.
The licensing hearing is the only fonm in which CANE tay raise issues relatin6 to the safety of Plant Vogtle operations. The incremental increase in radionuclide contamination over and above that already credited to SRP nuet be analysed when ecleulating backgrounddradiation. CANE conter.ds that combined activitics of Voctic and SRP will result in violation of radiatior, eniccions, therby endancoring public h:alth and safety. Therefore a review of cumulative effects of tie two facilitica lice OD within the jurisdiction of.th&4 board.
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1 M
- 3. William Lawless Has Technical Expertise and Exnerience Which Will Assist in Developing A Sound Record in the Hearing.
As the records from the Prehearing Conference will indiitate, Lawless, as former Senior Project Engineer of the 8RP's Nuclear Waste Management Branch is preeninately qualified to discuss the issues concerning the SRP on behalf of GANE. Because of SRP's close proximity to Plant Vogtle, the nuncrous dificiencies of SRP's operation will necessarily advercely affect Plant Vogtle. Thdrefore, Lawless' interpretation of the FEIS concerning th'e cumulative effects from tiic twoofacilities should be admitted in order to fully develope the record regarding this crue$al safety issue.
- 4. No other Party in the Licensing Hea" ring Reprecents CANE's Contention Concerning Violation of Radiation Standards Luc To Cumulative Effects.
GANE is the only party which raised the issue of cunklative effects at the prehearing conferenco..No oth(:r contention relates to this iccuel and the NRC staff does not adequately represent the'intM:dsts of GANE. The efob,'the Licensing Board chould
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admit this cors,ention to ensure that GANE's interests are fully represented.
/, 3. Admiscion of GANE's anended basin fer Coptention 2 Will not Broaden
'I The Rance of Envbronmental Impacts Which l?he NRC Should Coneider Nor Will It Delay The Proceeding.
The cumulative effects of the radicactive releasco from SRP and Plant Vogtle will
/
violate' emission standards set for'th in Contention 2. The violation of such ctandards is a matter that has been heard in other proceedinCs before this board. The amendment to thsb$cis, i clu: led} ore narrows rather than broadens iccuns previously alluded to in Contesion 2.'
This contention is lato filled within the tinc framecreco'nrended by the ASLB. Further-more, the Licensing Board must firct rule on caveral natters which were raised at the Prehearing Conference before it can even cct the dato for the hearings. Thuc, the admissiono6f this contention will not dolay the proceeding in.my manner. For these
/
reasons, GANE respectfully requests that the Licenring Board (in.it late-filled basis f..
.f6r CMiB Contenti:.5 Hunber Tuo.
HES.ECTFULLY SUB".ITTED,
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i SAVANNAH RIVER PLANT OFFSITE RELEASES COMPARISOM W. F. Lawless Assistant Professor, Mathematics Paine College June 7, 1984 1
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' Introduction
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The United St'ates Department of Energy's (hereinafter
" DOE")~ proposal to restart the L-Reactor at the Savannah River s
Plant (hereinafter "SRP"), a major DOE installation for the production of defense nuclear materials, has occasioned the
, publication of an environmente? impact statement entitled L-Reactor Operation Savannah River Plant, DOE /EIS-0108 (1984) / (hereinafter "SRP-EIS").
This publication has 1
provided a unique data base heretofore not available for
-research.
The SRP-EIS not only assesses the potential environmental effects of the major proposed actions regarding L-R'eactor, but it also provides important information on many SRP support activities.
Taken togedier, a critical analysis of the SRP-EIS calculations can be made an'd' compared.
The SRP-EIS also assesses cumulative radiological effects of all nuclear facilities within an 80-kilometer radius of SRP.
These include SRP, the Alvin W. Vogtle Nuclear Power Plant (hereinafter "VOGTLE") under the construction, the 5Barnwell Nuclear Fuel Plant (not expected to operate), and the Chem-Nuclear Services' low-leve radioactive disposal facility.
Quoting from the SRP-EIS:
Facilities currently operating at the Savannah
-River Plant include three production reactors [C, P and K; L-Reactor will join these three), two chemical separation areas (F and H], a fuel fabrication facility, waste management facilities, and o'ther support facilities.
Future projects (at SRP] include construction and operation of a Fuel
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' Mater ial Facility (FMF), to produce fuel forms for the naval reactor program, and the Defense Waste Processing Facility (DWPF), to be used to immobilize high-level radioactive wastes currently stored in tanks at the Savannah River Plant.
The FMF and DWPF are not expected to become operational until the latter half of the 1980s and will have no radiological impact during initial startup of the L-Reactor.
The Alvin W. Vogtle Nuclear Power Plant is being constructed by the Georgia Power Company about 15 kilometers southwest from the L-Reactor.
When completed, this plant will have two light-water cooled power reactors.
The Vogtle Power Plant is not expected to reach full operation until the latter part of the 1980s and also will have no
-radiological impact during the initial startup of L-Reactor.
The Barnwell Nuclear Fuel Plant is located approximately 19 kilometers northeast of L-Reactor.
The owners of this facility, Allied-General Nuclear Services, have announced that they do not plan to operate this plant.
The normal operation of the Chem-Nuclear Servies, Inc.
low-level radioactive disposal site does not entail discharges of low-level radioactive laaterials to surf ace waters or to the atmosphere.
The cumulative off-site radiation dose, therefore, is the sum of the doses from L-Reactor and its support facilities, current SRP operation with three reactors, the planned Fuel Materials Facility and Defense Waste Processing Facility at SRP, and the Vogtle Nuclear Power Plant.
The total-body doses to the maximally exposed off-site individual and to the population are summarized in Table 5-22 for the reference-case operation of L-Reactor.
[ Table 5-22 is reprinted on the following page 2A from the SRP-EIS]
. The maximum individual dose is conservative because the defined ' composite' individual would have to be a permanent resident of several different locations to receive the dose.
The doses shown are for the tenth year of L-Reactor operation when it is expected that all described facilities will be in operation and when radioactive releases from l
L-Reactor will have reached an equilibrium maximum.
2-
The composite maximum individual dose of 3.5 millirem for the reference case is 26 times less than the average dose of 93 millirem.
received by an individual living near the SRP site from natural radiation'.
The composite population dose of 165 person-rem is about 0.15 percent of the exposure of about 109,000 person-rem to the population living within 80 kilometers of the Savannah River Plant and the Beaufort-Jasper and Port Wentworth drinking-waggr populations from natural radiation sources.H
[SRP-EIS, pp. 5-35 to 5-36.)
The composite maximum individual dose of 3.5 millirem is about four (4%) percent of all the background radiation that individuals living within 80 kilometers of SRP are normally exposed to on the average.
If this composite of an individual's exposure is correct, the radiological health effects of SRP and VOGTLE on the populations at risk are trivial by comparison to background radiation.
VOGTLE is not operational, but a closer look at the impact of past and current SRP operations can aid in assessing the accuracy of this SRP-EIS prediction.
The SRP-EIS assurances notwithstanding, the monitoring data published in both exterior and interior SRP reports describe a much different environment.
Radioactive Cesium-137, in unacceptable amounts, has been released off the SRP sit'e.
l Turtles have'been found on the SRP perimeter that were grossly.
1 contaminated with Strontium-90.
Tritium oxide concentrations at the SRP perimeter exceed Environmental Protection Agency l
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(hbro'in'af t2r " EPA) drinking wctor ctandctdo by more than two
[Y times.- Ground water throughout SRP has been seriously contaminated to the extent that contamination has reached the
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Tuscaloosa acquifer.
The composite individual produced in the
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SRP-EIS is an individual who supposedly must live in more than one location to receive the maximum exposure to SRP releanes.
Howeve r, it appears that the locations specified for this
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composite individual in the SRP-EIS will not give maximum
,7 exposure.
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v-
_t Cesium-137 and Cobalt-60 From past SRP operations, significant amounts of Cesium-137 (hereinafter "Cs-137") have deposited off-site of thejSRP facility, and Cesium-137 and Cobalt-60 (hereinafter "d$f60") will be transported off-site and remobilzed from
.:az off-site locations as a result of the L-Reactor restart.
[SRP-EIS, pp. 4-32].
C. T. Hess, Professor of Physics, commented on the possible gamma exposures:
Most of the swamplands up to seven miles down
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stream from the plant range from 42-670
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millrem/ year for constant exposure according to exposgpecontoursreportedin1974 [by Dupont]
2-2
- ff
[ S RP -E IS, p. M-357.]
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In turn, the SRP-EIS responded that these areas were low n
.s ;
occupancy areas assuring that actual doses to individuals were elis 4/
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within applicable DOE and EPA dose limits.~
[SRP-EIS, p.
_4-l
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M-357).
However, this casts doubt on the purported conservative calculations in the SRP-EIS using a composite individual living in several locations in order to receive the maximum exposure of 3.5 millirem.
Strontium-90 Contaminated Turtles An informal 1982 internal DOE revealed four contaminated turtles had been found on the northwest SRP boundary.
The turtles had been contaminated with Strontium-90 with a maximum 4
uptake'of 20,900 pCi/g, the least at 3,900 pCi/g.
A turtle at background for comparative purposes was found and reported at 15 pCI/g.
The turtles were contaminated to more than 1,000 times background.
The maximum deer uptake publicly reported in 1977 was ' 4 pCi/g.
Airborne H-3 and Krytpon-85 Releases The SRP-EIS states that the Krypton-85 (hereinafter "Kr-85") incremental airborne increased emission will be negligible due to the L-Reactor startup and to VOGTLE, and that Tritium (H-3) will average 200 pCi/m at the SRP plant boundary from all sources.
A footnote explains this is equivalent to current operations and, thus, represents no increase. /
7
[SRP-EIS, pp. 5-52, Table 5-23].
This can be compared to a 1982 Dupont report showing a ca1culated average 3
110 pCi/m Tritium concentration at the plant boundary.~/
The annual total SRP releases 'are reported to 8
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T be 400, BOO curies of Tritium and 840,000 curies of Kr-85 in u..
1981;. increases of Kr-85 are negligible for L-Reactor and are expected to be 141,000 curies of Tritium for L-Reactor af ter 9/
startup.-
.It is difficult to back calculate the concentrations
' released and make meaningful comparisons because releases 7,..
usually occur as plumes, whereas published data is reported in average concentrations at the plant boundary.
Useful assumptions, however, can be made.
First, stack flue rates are provided in both the Tritium production facilities located in
- LL.
H-a'rea", and the F-and H-Canyon reprocessing facilities where Kr-85]isreleased.
Assuming constant releases, the avera' e concentrations of released Tritium and Kr-85 are g
- =&=&
provided in Table 1.
Then, heretofore internal SRP information i= ry caN[he3 integrated with data from the SRP-EIS:
- =
= 2:;
.- ym
- x.t fgi The normal; background in the SRP [ burial ground new ground water, approximately plant center and
~~.f approximately 30 feet beneath the surface) area is
. g;; about 150 pC1/ml. 1/
' :'s.n.;.
jsy At Par Pond pumphouse well the green clay also
'+F=:
supports a.large head difference and the water
- yf pumped.from the Congaree Formation shows no i2EF evidence of tritium contamination, even though
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tritium concentrations in the pond were measur~ed at 27,000 pico-curies per liter.
Water pumped from the Congaree by the pumphouse well exhibited
-11;-
tritium concentrations of 170 picuries per liter "f5 or less, compared to concentrations of 260 = 60
-. ~
picoeuries per liter in off-site well water 12/
TSRP-EIS, pp. 5-6; emphasis supplied.]
y 6-
Par Pond received Tritium oxide (HTO, T 0) from 2
P-Reactor in small amounts from the P-Reactor seepage basin and from P reactor effluents; but it can be assumed to be primarily contaminated from airborne P-Reactor emissions.
These internal SRP Tritium data can be plotted against E.
I.
Dupont deNemours
& Co.'s (hereinaf ter "Dupont") measured and calculated Tritium emission data.
The 150 pCi/ml Tritium release concentration is 3
higher than the average 96.9 pCi/M Tritium release but can be accepted because the stack releases are an average of the releases (e.g.,
the highest reading reported in 1977 from a 3
single well in the SRP burial ground was 3900 pCi/M, or 26 times the average background).
The SRP burial ground is two kilometers west of the H-Area Tritium facilities and north of the C and K-Reactors, roughly centered from the Tritium generators especially under the generally light and mostly variable winds at SRP.
[The predominant wind is to the north east with a secondary maximum to the southwest.
Tritium is release as Tritium gas (HT or T2) and or Tritium oxide (HTO or T 0).
The fractional' emissions of 2
either are generally not published.
However we know that 1975 SRP routine tritium releases to the atmosphere totalled 306,000 Ci (excluding the December 31, 1975 accidental release of 182,000 Ci of Tritium, mostly as Tritium gas with 0.6%
Tritium oxide).
Of the 306,000 Ci released in 1975, 262,000 Ci i
-7.
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were in the oxide form. 15/
In this study, 85% of the routine airborne Tritium releases will be assumed to be in the oxide form.
The burial-ground ground-water concentration divided by the Par Pond concentration equals a straight line concentration reduction factor of 0.4 per kilometer.
The reduction factor plotted will provide a crude approximately at the SRP plant boundary for the average airborne Tritium concentration and a check on other calculations.
In Figure 1, the Tritium data is plotted with natural logarithm concentrations on the ordinate against distances in Kilometers on the abscissa.
The data plots as a straight line implying that tritium oxide concentrations are exponentially reduced and approximated by the equation:
18.8 -.1x y=e
[1]
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3 y = tritium oxide concentrations in pCi/m x = distance in kilometers The SRP plant boundary airborne tritium concentration from 3
equation [1] is calculated to be 14.9 pCi/m at 19 kilo-meters from the burial ground and compares to the 100 3
pCi/m calculated by Dupont for the average SRP plant 16/
boundary tritium concentration.-
The difference between these two calculations is about five orders of magnitude.
However, the straight line calcultion mentioned above provides a crude estimate of 10.8 pCi/m3 in good agreement with the exponential reduction equation [1].
The SRP PPSPU off-plant monitoring annual report for 1982 provides what appears to be part of the answer.
[ Care in using the DPSPU series of reports should be exercised.
It has been observed that the DPSPU published data in the past has been incomplete and significantly under-reported maximum observations.)
Most sources do not discriminate between Tritium. oxide or Tritium gas, and the difference can be significant.
The Tritium gas is regulated to a limit of 40 PCi/m, whereas the Dupont Tritium oxide concentration guide inhalation and skin absorption limit is 0.2 3 18/
Quoting from a Dupont report:
PCi/m.--
The concentration guide for tritium oxide is several hundred times less than that of the elemental gas form because almost all of the oxide form (water vapor) that is inhaled is absorbed in the lungs and enters the body water pool, and all the body tissues are exposed.
In addition, almost as much tritium oxide is absorbed through the skin as is absorbed during inhalation.19/
The average biological half-life of unreplenished Tritium in the body from one exposure is between 9.6 to 19 days; the figure of 12 days is used for most calculations.- /
20 The 1982 Annual Report data fer airborne Tritium ranges from 2.6 to 3
3 480 pCi/m with an arithmetic mean of 8.2 = 14 pCi/m (two standard deviations).-~/
21 But, in addition, atmospheric moisture for Tritium is also shown, the data in g-
pCi/ml.. Converting to cubic meters, at the SRP boundary, Tritium oxide moisture concentrations ranged from 0.36 to 60 3
3 pCi/m with an arithmetic mean of 8.1 = 14 pCi/m (two standard deviations).- /
This agrees closely with the 22 value of 14.9 pCi/m calculated from equation [1].
LFu'r the r, extending the collection range out to 40 kilometers,
' focusing on the northeast quadrant from SRP, Tritium oxide moisture measurements were reported by Dupont to range from 1.
3 32 0!O7 to.32 pCi/m with a mean of 3.25 pCI/m,_3/
2 equation [1] provides an estimate at 40 kilometers of 1.07
~f 3
PC1/m, in good agreement with the Dupont data.
py jf There is reason to believe, on the basis of calculations 77 using equation [1] to fit the data, on the basis of
-82 AjmostphericmoisturedatapublishedbyDupont, the off-plant
..x
}s{fborne Tritium releases are too low by.two or more orders of
' 'et 3 magnitude.
In the SRP-EIS, the EPA found the opposite to be
'Q-i t!. e:
u
- M-
"SEE field surveys were conducted by EPA to
- I3E determine radioactivity in air emissions from the IEEi plant site by direct measurement.
Although the MjRI report of this' data is still in preparation, EPA's
))7 monitoring data appear to be within a few percent E
of DOE's results.24/
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[SRP-EIS, p. M-272.1 r
The[EPAdoesnotspecify'what agreement with what species, and
-(hfisentirelypossiblethatTritiumoxidewasoverlooked.
In esr addition, a review of two accidental SRP Tritium gas releases, i
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v.
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in 1974 and 1975, points out how difficult it is to find and measure plume passages.
Such has been found to be the case with Kr-85 releases and may similarly hold for Tritium releases.
The SRP burial ground, ground-water background, Par Pond levels for Tritium and the Tritium atmospheric moisture releases measure at the SRP perimeter can be explained by a plume release model that achieves a steady state, exponentially decreasing concentration similar to equation [1].
The Krypton-85 emission source term was calculated in similar fashion to that of Tritium and is displayed in Table 1.
Krypton-85, however, was actually measured off-site during plume passage in Fayetteville, N.C.,
300 kilometers away from 25/
the SRP plant center.--
Fitting the data results in the equation:
8.1265
.0219x Next, postulating that Krypton-85 releases are emitted in plumes and remain coherent under non-turbulent wind flow situations in order to be recorded as a single plum in Fayetteville, then it seems reasonable to assume that these emissions are unique events with major excursions taking place once per month simultaneously for both SRP reprocessing canyons.
Such a supposition changes the y intercept and slope of equation [2] to become:
11.56
.0335X l
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1.,
$~~
The effect of releasing once per month in equation [3] provides a slope for Krypton-85 that Lagins to resemble the slope for the. Tritium exponential plume decay in equation (1) when using common logarithms.
The Dupont average SRP plant boundary emission concentrations for Krypton-85 is 230 pCi/m and is
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shown, along with equations [2] and [3), in Figure 2.
The difference between the SRP boundary Krytpon-83 average
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concentration from equation [2] and the Dupont calcuation is five orders of magnitude.
I M-Area Seepage Basin There are 26 open and six (6) backfilled radioactive 26/
seepage basins at SRP.--
Of these, the one seepage basin in M-Area and the eight in F-and H-Areas have. been extensively moni[5oredandstudied.
The M-Area seepage basin has
'1 been_ contaminated with,degreaser solvents, lead, mercury, and 28/
numerous other contaminants;--
of 29 contaminant catbgories with listed drinking water standards, over a recent one-hearperiod, 150 readings in the SRP-EIS exceeded a 29/
drinking water standard in 15 of the 29 categories.
These data are from eight monitoring wells surrounding the M-Area basin and an overflow, adjacent lake.
These data are from eight monitoring wells surrounding dae M-Area basin l
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and.'an ' overflow, adjacent lake.~~
For example, lead
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excee{dedthedrinkingwaterstandardineachoftheeightwells i
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m m
m
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at-least.one time during the year. 3y other data indicate that the Tuscaloosa Aquifer has been contaminated in at least five wells, two of which are drinking water supply production wells.
One of'the production wells produced drinking water until Ap'ril, 1983, even after unacceptable levels of chlorinated hydrocarbons had been discovered in July, 1981.
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34 The M-Area cleanup is planned to take 40 years and will remove and clean about one billion gallons of water.
Ground water will be pumped into an air stripper that will
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release airborne emissions of approximately 30 tons of L
36 chlorinated hydrocarbons per year.
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These emissions could produce deadly phosgene gas, a by-product of the decom' position of chlorinated hydrocarbons, yet no discussion of
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3 this was found in the SRP-EIS. y The SRP-EIS did report off-site emissions would be satisfacotry and implied that emis[sionswouldoccurinM-Area, near the populous
=
administration-manufacturing areas; no estimate of employee up-fake due to airborne emissions was included.
This could be of serious concern since nd airborne analysis of the water vapor emissions was included.
Water vapor, over 600. tons per year, will be emitted by the air stripper pumped from the ground-water under M-Area.
This water vapor may contain dangerous levels of mercury'and lead and other
conttaincnts. 39/
Alco of concern, the 30 ton per year chlorinated hyderocarbon emission rate is based on a source average concentration of 38,600 ppb organics; however, concentrations can rise to levels many times that average concentration with maximum reported concentrations of 234,000 ppb organics.
In M-Area, the ".
. green clay is discontinuous and the tan clay has disappeared entirely. Thus, there is less impedance to downward vertical flow within the tertiary sediments."
[SRP-EIS, pp. 3-29.]
The ground water under M-Area has been severly contaminated.
The Tuscaloosa acquifer itself has been contaminated.
Water production wells between the M-Area and the Savannah River may intercept contaminated water.
However, the government had always intended to return this land back to public use:
Release of seepage basin sites for public ownership or occupancy assumes that land use restrictions can be maintained for up to three centuries to block potential. exposure pathways from fission products.
. release of land with restrictions is.
a viable alternative to maintenance of government ownership.43/
Discussion l
Predicted radioactive releases from VOGTLE and SRP are expected to be within about three (3%) percent area radiation background levels based on calculations using a hypothetical, l
t
- 14'-
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c2xicn11y expossd in'dividucl in the SRP-EIS.
If such were the case, the operations of both would hardly be noticeable.
Unfortunately, it does not appear so.
Heavily contaminated turtles roaming the SRP northwestern boundary and damaging off-plant SRP releases of Cs-137 indicate releases may be much higher in other areas also.
Tritium releases carried by the wind should disperse rapidly, but Tritium oxide, released in an environment where winds are often light and variable, can behave much differently than other airborne contaminants.
For one thing, Tritium oxide competes with water vapor; for another, the movement of water vapor can be even more complex than the movement of airborne contaminants that are foreign to the atmosphere.
Water vapor may move up and down as easily as horizontally.
The result may be contminations of water vapor in excess of acceptable If. nits.
The published maximum SRP perimeter reading of 50 pC1/ml exceeds the liquified drinking water standards and the water vapor concentration guide.
It may be argued that the 50 pCi/ml should be reduced to one to two (1%-2%) percent equivalent to ambient water vapor readings before comparing to the latter concentration guide; nonetheless, the reduced value would still be unacceptable.
SRP releases already exceed seceptable airborne releases; VOGTLE releases so close to the SRP will further add to unacceptable levels.
1 t
1 It may not be appropriate to reduce the Tritium oxide to the water vapor loading.
To do so assumes that Tritium oxide very quickly enters a state equivalent to existing water vapor.
Naturally, Tritium oxide is emitted from the stacks at concentrations greater than the average atmospheric water vapor loadings per cubic meter and as such should be treated as a I
plume release until it has been absorbed into the atmosphere.
3 For instance, using the ICRP method of 6 ml/m average water vapor atmospheric loading, maximum atmospheric moisture concent' ration of tritium in 1981 of 220 pCi/ml from H-Area gave 3
an H-Area average moisture loading of 1,980 pCi/m, far below average stack emissions in H-Area.
Supporting this rainwater Tritium concentrations in H-Area and at the plant perimeter are within one order of magnitude of Tritium air moisture readings.
In fact, rainwater concentrations collected 3
in H-Area average 130 uCi/m (where u =
).
The average SRP Tritium oxide in 1982 release of f-site was 4
3 8.1 14 uCi/m.
Assuming a two (2%) percent water vapor I
atmospheric loading, the average concentration is approximately at the concentration guide for tritium oxide; however, as noted above, this is likely an-incorrect assurption.
Thus, it appears that the Tritium oxide releases exceed = acceptable f
standards because Tritium oxide released from SRP will exceed i
average atmospheric water vapor loadings until plume 4
i
-e----
4
.m
dissipation.
Further, to put this into perspective, quoting from Dupont's 1982 annual SRP-vicinity monitoring report:
The maximum tritium concentration in rainwater (6 pCi/ml at the East Talatha station) represents only 1.2% of the CG [ concentration guide] for drinking water.44/
The DOE concentration guide is listed by DuPont as 3,000 3
uCi/m ; however, the EPA drinking water standard of 20 3
45/
uCi/m is listed correctly in the SRP-EIS.--
3 Converting 36 pCi/ml to 36 uCi/m, the rainwater exceeded the EPA. drinking water standard by 1.8 times at the SRP perimeter alongside the Talatha Public Park.
The M-Area seepage basin at SRP illustrates another problem.
The 1973 Atomic Energy Commission radioactive waste regulations specified:
As soon as technically and economically practical, the use of natural-soil columns (such as Cribs, seepage ponds, and similar facilities) for liquid streams that exceed established standards for release of radioactivity to uncontrolled areas O ~~
shall be replaced with other treatment systems.46/
At'SRP, many basins are still in use and will continue; current plans are to stop operations of only nine of 26 radioactive 47/
liquid waste seepage basins at SRP.--
The cleanup of just one of these basins will take 40 years, remove one billion i
gallons of water, cost millions of dollars, and expose many individuals to airborne releases of contaminants.
Antiquated technology at the Savannah River Plant should no longer be l
17 -
ellswad.
Quoting from the DOE Counsel for the Environment in 1980:
DOE's record of performance in [ environmental affairs], particularly with regard to AEA [ Atomic Energy Act] activities involving occupational health and safety, has been exemplary.
DOE's management of hazardous waste, including waste associated with AEA activities, will be designed to be equally successful.48/
How best to judge the DOE and Dupont assurances to the public of their purportedly extremely low offside does commitment of 3 mrem /yr from SRP operations?
Probably in light of past assurances.
In a 1976 letter to the DOE manager of the i
SRP, C.H. Ice, the director of the DuPont managed SRP laboratory, stated "the large Tuscaloosa aquifer is 300 feet deeper than the near-surfaced ground-water, separated by several nearly impermeable clay barriers, and is at a higher artesian pressure than the ground-water exposed to the waste tansk.
Thus, flow of contaminated ground-water could not reach the Tuscaloosa aquifer.
Radionuclides that enter the near surfaced ground-water would decay to permissible levels before reaching the nearest creek because of low ground-water velocity and ion exchange characteristics of the soil."
The Tuscaloosa Aquifer has been contaminated.- /
50 Groundwater above the Tuscaloosa Acquifer is severely contaminated and further movement into the Tuccaloosa cannot be 51/
prevented.~~
Finally, SRP contaminant flow into the 18 -
4
naarost creeks occurs so often and under such gross loadings or concentrations that the EPA states that it ".
demonstrate (s) a method of discharging pollutants to a stream without a permit by using the ground-water as the medium of transport."
/
52 4
(SRP-EIS, M-270.]
I -
REFERENCES 1.
L-Reactor Operation Savannah River P] ant, a U.S. D.O.E. Environmental Impact Statement Report DOE /EIS-0108, 3 vols.(1984) 2.
Sr-00 In Turtle Carapace, DOE Savannah River internal memorandum, (1982).
3 Vaste Management Operations. Savannah River Plant, a U.S. ERCA Environmental Impact Statement Report EROA 1537 (1977).
4 Dukes, E.K., Benjamin, R.W., Savannah River Plant Airborne Emissions and Controls, DupontRep.DPST-82-1054(1982) 5
" Issues PertiEent to the Long-Term Operation of the Burial Ground," letter from R. Maker, Dupont Program Mana6er, to J. B. Hindman, Director, DOE-SR Waste Mana6ement Project Office, June 30, 1981.
6.
Eenimore, J.W., Radionuclides in 643 Groundwater-1971-1976, an internal Dupont Savannah River Laboratory Memorandum report to E.L. Albenesius, Nov. 23,1977 7.
J.W. Fenimore, R.L. Hooker, The Assessment of Solid Low-Level Waste Mana:ement At The Savannah River Plant Dupont Savannah River Laboratory Rep. DPST-77-300 (1977),.
8.
W.R. Jacobsem Environmental Effects of a Tritiun Gas Release From the Savannah River Plant on December 31.1975. Dupont Savannah River Laboratory Rep. LP-1415(1976).
9 W.L. kkiter Environnental Effects of a '"ritiun Can Release Pro". The Savannah River Plant On'May 2.1974 Dupont Savannah River Laboratory Hep. Dr' _- 1369 (1974).
20.
Environmental Monitoring In the Vicinity of the Savannah River Plant Lupont Savannah River Plant Rep. DPSFU 83-30-1 (1983).
81.
W. F. Lawless Savannah River Plant (SRP) Burial Grour.a Buildine L43-G Manarerent Appraisal Report Appraised June 2-13, 1980. Internal B M draft report (1982).
12.
J. F. Schubert, J.L. Heffter, G.A. Mead, Atlantic Coast Unique Regional Trace Experiment (ACURATE), Dupont Interim Rep. LP-1651 (1933).
23.
W.L. Marter New Criteria For Seepage Basin Use Dupont Rep. LFST-77-444 (19717) i 3,4 J.L. Steele, D.E. Gordon Technical Summary of the A/M Area Groundwater ( AMGW)
Remial Action Procram Dupont draft report (Ca. March 6,1984) 15 p sessment of the Presence of Volatile Organic Comtonnds in Water-Supply Well 53-A A-M Area. E vAnnah River Plant. Geraghty & Miller contracted report to Dupont, Atomic E*,crgy Division (1983).
- 16. Radioactive kante Management AEC Regulation 0511(1973).
17 S.H. GreemleiEh, DOE Assistant General Counsel for Environ ent, " Compliance with EPA Hasanlous h.ste Regulations." A LCE review r.corandun (Nevenber 17,1980)
REFERENCES
-18.
C. Ashley, CC Zhigler Environmental Monitoring At The Savannah River Plant Annual Report for 1981. Dupont Report EpE LFSPU 82-302 (1984).
C.H. Ice, Dupont Director Savannah River Laboratory, Letter to N. Stetson, Manager, 19.
ERDA Savannah River Operations. Office, "Conments on Technical Issues IN NRDC suit"
- p. 8 Sept. 29,1976.
FOCfrNOTE3 i
Footnote Refers To Reference 1 If Not Otherwise Noted Text supplies sone References fn.5-rf. 2 fn.6-rf. 3 fns. 8,9,10. - rf4 fn.11-rf. 6 fns. 13,14.- rf.7 fns.15, 20. - rf.8 fn. 19 - rf. 9 fns. 21,22,23 -rf. 10 fn. 25 - rf.12
h[f[0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAM JllN In the Matter of L F;c :
DOCE{ Ting *k W.
Docket Nos. 55 42, S5d 50-425 Geoggia Power Co., et al.
(Vogtle Electric Generating Plant, Units 1and2)
CERTIFICATE OF SERVICE This is to certify that copies of the foregting " Amended Basis For CANE Contention Number TWO" were served by deposit with the United Postal Service with first-class postage prepaid this thirteenth day of June, 1984, to all those on the attached service list.
Dou61as C.
per Georgians Agiintt Nuclear Enercy e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
')
GEORGIA POWER CO., et al.
)
)
Docket Nos. 50-424 and 50-425
)
(Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Board Atomic Safety & Licensing Appeal U.S. Nuclear Regulatory Comission Board Panel U.S. Nuclear Regulatory Commission
)
Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris Atomic Safety & Licensing Board Docketing and Service Section U.S. Nuclear Regulatory Comission Office of the Secretary Washington, D.C.
20555 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Mr. Gustave A. Linenberger.
Atomic Safety & Licensing Board Bernard M. Bordenick, esq.
U.S. Nuclear Regulatory Comission Office of the Executive Legal Washington, D.C.
20555 Director U.S. Nuclear Regulatory Comission J
Washington, D.C.
20555 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Comission Tim Johnson Washington, D.C.
20555 Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.
Laurie Fowler & Vicki Breman Atlanta, Georgia 30303 Legal Environmental Assistance Foundation 1102 Healey Building /57 Forsyth Street George F. Trowbridge Atlanta, Georgi: 30303 Ernest L. Blake, Jr.
David R. Lewis l
James E. Joiner Shaw, Pittman, Potts & Trowbridge l
A Sumner.C. Rosenberg 1800 M Street, N.W.
t Troutman, Sanders, Lockerman & Ashriore Washington, D.C.
20036 127 Peachtree Street, N.E.
Ruble A. Thomas 3
Atlanta, Georgia 30303 Southern Company Services, Inc.
P.O. Box 2625
,2 Birmingham, Alabama 35202 3
s sa 52
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