ML050470301

Supplement to the Request for Proposed Procedures in Accordance with 1OCFR20.2002

ML050470301
Person / Time
Site:	Yankee Rowe
Issue date:	02/07/2005
From:	Jesse Rollins Yankee Atomic Electric Co
To:	Document Control Desk, NRC/FSME
References
+KBR1SISP20050413, BYR 2005-011
Download: ML050470301 (6)

Text

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- YANKEE ATOMIC ELECTRIC COMPANY Telephone (413) 424-5261 49 Yankee Road, Rowe, Massachusetts 01367

~Y NKEE US Nuclear Regulatory Commission Attn: Document Control Desk Washington, D C 20555 February 7, 2005 BYR 2005-011

Subject:

1. License No. DPR-3 (Docket 50-29)

2. Letter, YAEC to NRC, "Yankee Nuclear Power Station - Request for Approval of Proposed Procedures in Accordance with 10 CFR 20.2002," dated December 22, 2004, BYR 2004-136 Supplement to the Request for Proposed Procedures in Accordance with I OCFR20.2002 In the Reference 2 letter, Yankee Atomic Electric Company (YAEC) requested the NRC's review and approval of the use of an alternate disposal procedure for certain decommissioning wastes.

YAEC therein demonstrated that the exposure to a member of the public would not exceed a few millirem from the alternate disposal procedure. The alternate procedure involved the transport of certain decommissioning wastes in intermodal shipping containers from the Yankee Rowe site to a rail transport facility in Palmer, Massachusetts from which the containers would be further transported by rail to the Waste Control Specialists (WCS), LLC Facility, located in Andrews, Texas, for offload and disposal.

In this supplement to the initial request (Reference 2), YAEC provides (see Attachment) an evaluation of an additional transportation option for the transfer of the wastes to the WCS site.

This option involves offloading of the material to a gondola rail car at a facility in Worcester, Massachusetts. The Attachment demonstrates that the conclusions from the initial request remain bounding with respect to the dose to members of the public (less than 5 mrem). Accordingly, YAEC requests that the NRC review and approve this supplement such that this additional transportation option may be used for the decommissioning wastes. Note: It is anticipated that both transportation plans will be implemented.

Based on discussions with the NRC following the initial submittal (Reference 2), YAEC requests that the NRC complete its review and approval of both the initial request and this supplement by February 28, 2005. This schedule will support YAEC's decommissioning activities at the Yankee Nuclear Power Station (YNPS).

Should you have any questions regarding this supplement or the initial request, please contact the undersigned at (413>.424-2300.

Sincerely, YANKEE ATOMIC ELECTRIC COMPANY Regulatory Affairs Manager H M5 I

Document Control Desk BYR 2005-011 /Page 2

Attachment:

Evaluation of the Supplemental Transportation Plan for Yankee Decommissioning Waste through the Worcester, Massachusetts Transload Facility cc:

S. J. Collins, NRC Region I Administrator J. Hickman, NRC Project Manager, Division Of Waste Management and Environmental Protection, NMSS R.R. Bellamy, Chief, Decommissioning and Laboratory Branch, NRC Region I D. Howland, MADEP R. Walker, Director, MADPH

ATTACHMENT Evaluation of the Supplemental Transportation Plan for Yankee Decommissioning Waste through the Worcester MA Transload Facility.

1.0

==

Introduction:==

The initial transportation plan for this waste included the transport of the waste in intermodal containers from YNPS to a rail site in Palmer MA. Once in Palmer, the intermodals would be relocated to a rail transport car where it would be transferred to the WCS site in Texas.

The radiological analysis for this original transportation plan evaluated the potential dose to all workers involved in the waste transportation including the vehicle drivers and the waste handlers at WCS. This original analysis concluded that the highest exposed person was the waste handler at WCS for an annual exposure time of 936 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.56148e-4 months <br /> at a conservative exposure rate of 0.553 uR/hr (corresponding to a distance of 5 feet from the center of the loaded container).

This evaluation provides an analysis of the potential exposure of workers involved in activities to support the waste transportation and handling at the Transload Facility in Worcester, MA.

2.0 Operation of the Transload Facility The Transload Facility is operated by MHF Logistical Solutions Inc. The purpose of the facility is to receive and dump loads of materials into rail cars for transport. The waste material from the YNPS is proposed to be hauled to the Transload Facility in trucks (intermodals, roll-off and/or dump trailers). The transit time from the YNPS to Worcester, MA is approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Once at the Transload Facility, the trucks would dump each load into a gondola rail transport car using the following process.

• The materials are unloaded directly into a strong tight sealable container within the gondola railcar as the dump or intermodal roll-off trucks back up the ramp and discharge thru an open directional hopper and into the railcar.

• Loads are then groomed and adjusted as needed using a backhoe attached to the rear of the hopper.

• The strong tight container is sealed and surveyed for transport.

• No material is ever unloaded onto the floor of the facility and the hopper is not an accumulation bin.

Figures 1 through 6 provide a view of the facility and the approximate sequence to be used.

The Transload Facility crew consists of two to three people that will consist of a crane operator and one or two ground individuals. It will take approximately 60 to 90 minutes to load a gondola railcar. Approximately 510 rail cars are assumed to be required to ship 84 million pounds of material at 75% capacity for each load (full capacity is I 10 Tons). It is anticipated that 50 loads per week will be transferred using eight truck drivers. Each load will weigh nominally 40,000 pounds. Using an estimated total weight of D&D waste of 84 million pounds, this corresponds to approximately 2100 truck trips to Worcester, or 5250 p-hours, or 656 hours0.00759 days <br />0.182 hours <br />0.00108 weeks <br />2.49608e-4 months <br /> per driver.

Figure 1: Transload Facility, Worcester, MA Figure 2: Truck Entering Facility I

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Figure 3: View from Inside Facility Figure 4: View of Hopper

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F Figure 5: Truck Preparing to Unload Figure 6:

Gondolas and IM Truck Removed 3.0 Exposure Analysis The initial transportation exposure analysis provided dose rates from an intermodal-type container at the following three configurations:

• three feet from the side of the container, five feet from the side of the container, and 10 feet from the end of the container.

The exposure rate calculation for the intermodal container is a reasonable representation of the rail car since each container and distances assumed are considered reasonable representations of each exposure geometry.

Two types of workers and exposure rates will be considered for this analysis: a driver who will be 10 feet from each load, and, a waste handler who will be conservatively assumed to be 5 feet from each load.

.4 As discussed above, each driver is assumed to be exposed for 656 hours0.00759 days <br />0.182 hours <br />0.00108 weeks <br />2.49608e-4 months <br /> for the entire transfer campaign. Each waste handler is assumed to be exposed for 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per gondola car. For a total of 510 gondola cars, an exposure time of 765 hours0.00885 days <br />0.213 hours <br />0.00126 weeks <br />2.910825e-4 months <br /> is assumed.

From the above, Table I provides the estimated exposure rates for a concentration of I pCi/g for both Co-60 and Cs-137.

Table 1: Exposures from I pCi/g Co-60 and Cs-137 Co-60 Max Co-60 Cs-137 Max Cs-137 Maximum Hours Exposure Annual Exposure Annual Exposed Per Rate Exposure Rate Exposure Individual Year (mrem/hr)

(mrem/yr)

(mren/hr)

(mrem/yr)

Driver to Transload Facility 656 0.000238 0.156 0.0000455 0.030 Handler at Transload Facility 765 0.000553 0.423 0.000106 0.081 MEI from Prior Analysis 936 0.000553 0.518 0.000106 0.099 The data in Table I demonstrate that the Exposure of the Maximum Exposed individual from the prior analysis is larger than the workers considered for the trainload facility.

The potential for internal exposures from inhalation was considered. This exposure pathway was eliminated from further consideration at the WCS facility due to a predominance of historical airborne monitoring. Likewise, the operation at the transload facility is similar to WCS and therefore may be eliminated on the same basis.

4.0 Conclusions This analysis demonstrates that the exposure to workers involved in the use of the transload facility for the transfer of waste from the YNPS to WCS is bounded by the analysis performed for the prior evaluation where the maximally exposed individual is at the WCS facility.