ML060870601

Memo from Lemoine Cunningham to Brian Holian, Subject: Request Under 10 CFR 20.302 to Retain Contaminated Soil at Palisades Plant

ML060870601
Person / Time
Site:	Palisades
Issue date:	03/21/1991
From:	Liza Cunningham Office of Nuclear Reactor Regulation
To:	Brian Holian Office of Nuclear Reactor Regulation
References
FOIA/PA-2005-0293, TAC 67408 NUDOCS 9104010386
Download: ML060870601 (10)

Text

4 RCa UNITED STATES I

• NUCLEAR REGULATORY COMMISSION WAS4INGTON. D.C -' '0555

• MAR 21 1X1 MEMORANDUM FOR: Brian E. Holian, Project Manager Project Directorate III-I Division of Reactor Projects, Ill, IV,V, and Special Projects, NRR FROM: LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness, NRR

SUBJECT:

REQUEST UNDER 10 CFR 20.302 TO RETAIN CONTAMINATED SOIL ONSITE AT PALISADES PLANT (TAC NO. 67408)

References:

(1) CPCo's letter, T. C. Bordine to NRC Document Control Desk, November 12, 1987 and January 29, 1988.

(2) Memoranda from L. J. Cunningham, DREP to T. R. Quay T. V. Waambach, "Request for Additional Information (RAI),"

March 15, 1988, April 7, 1989, and January 12, 1990.

(3) CPCo's supplement to Reference (1), J. L. Kuemin to NRC Document Control Desk, June 27, 1988.

(4) CPCo's supplement to References (1, 2), G. B. Slade to NRC Document Control Desk, August 31, 1990.

(5) CPCo's letter, T. P. Neal to B. Holian, October 13, 1990.

(6) E. F. Branagan, Jr. and F. J. Congel, 'Disposal of Slightly Contaminated Radioactive Wastes from Nuclear Power Plants," presented at CONF-860203, Health Physics Considerations Decontamination Deconmnissionin2, Knoxiille, TN, February, 1986.

By letters dated November 12, 1987 and January 29, 1988 (Reference 1) the Consumers Power Company submitted a request pursuant to 10 CFR 20.3024a) for the disposal of contaminated soil onsite at Palisades Nuclear Plant. we have completed our review of the request and find the licensee's procedures with commitments as documented in Reference l to be acceptable, provided that References 1-5 are permanently incorporated into the licensee's Offsite Dose Calculation Manual (ODCM) as an Appendix and that future modifications of ADOCK 910321 05000255 Ql

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these commitments be reported to the NRC in accordance witt the applicable ODCM change protocol. We further find that the radiological environmental impact of the proposed action meets the staff criteria as reflected in Reference 6. Our Stifety Evaluation Report is enclosed.

11; is my understanding that you will prepare, as is customary in support of this type of evaluation, the appropriate Federal Register Notice and submit it for publication at the time the enclosed SER is sent to the licensee. If my understandinq is incorrect, please let me know. Our SALP input is also enclosed (Inclusure 2).

This completes our review under TAC No. 67408. The cognizant reviewer is I John Minns, X21084.

IS/

LeMoine J. Cunningham., Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness, NRR

Enclosures:

1. SER

2. SALP Distribution:

hongel LlCunningham TI ssig J14igginton VJlinns LRGreger RIII EWBrach (encl 2 only)

L13Marsh GCarpenter JAustin Central Files PRPB R/F OFC EPB:DREP:NRR :C. *

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fT1elAL RECORD COPY Document Name: HOLIAN MEMO

SArETY EVALUATION REPORT IN THE MATTER or THE PALISADES NUCLEAR PLANT TO RETAIN CONTAMINATED SOIL ONSITE INI RODUCT ION In reference (1), Consumers Power Company (CPCo) requested approval pursuint to Section 20.302 of Title 10 of the Code of Federal Regulations (CFR) for the dis-posal of licensed material not previously considered by the NRC in the Palisades Final Environmental Statement (FES), dated June 1972. The petition submitted contains a detailed description of the licensed material (i.e., con-taniinated soil) subject to this 10 CFR 20.30? request. The 6,000 cubic feet of onsite contaminated soil contain a total radionuclide inventory of 5.1 mCi, ba!;ed ott radioactive material that was deposited in the soil due to the flooding of the South Radwaste Building. The contaminated area is located inside the sec~urity fence, and is on company's controlled land. This area (South Radwaste Area) is fenced in within the plant's south security fence. Thus it is iniccessible to the public.

In the submittal (References 1-5), the licensee addressed specific information requested in accordance with 10 CFR 20.302(a), provided a detailed description of the licensed material, thoroughly analyzed and evaluated the environmental efl'ects relative to the retention of the contamination soil onsite, and committed to follow specific procedures to minimize the risk of unexpected exposures.

Although the environmental impact of the proposed action is well within the do!;e criteria contained in the Commission's Below Regulatory Concern (BRC)

Policy Statement, dated July 3, 1990, the licensee has not requested, and the stiff has not considered, the actions described herein to be exempt from D1RC re'gulation.

CP1Co plans to dispose of 6,000 cubic feet of contaminated soil onsite pursu-ant to 10 CFR 20.302. The area known as the South Radwaste Area has been con-taininated by several cooling tower overflows (three times in an eight-year period) and redistributed by heavy rain showers. The flooding was due to instrument failures that caused the cooling tower bypass valve to open during normal operation. This valve is now electrically isolated during cooling tower operation. The licensee conducted a soil survey because the South Radwaste Building was in the main path of water overflows from the cooling tower. In the survey, the licensee found that radioactive material was deposited irA the soil because of the flooding (associated with these cooling tower overflows) of contaminated areas inside ,-he South Radwaste Building. Although the majority of the radioactive md:erial has been packaged as radwaste and will be subsequently shipped offsite (16 boxes each having a volume of 98 cubic feet) containing 85% of the estimated activity), a large volume of low level contami-nated soil is contained in the fenced area described as South Radwaste Al-ea (Area B). The South Radwaste Area is located directly south of the plant;'s south security fence (see Figures 1 and 2).

The specific area contaminated is noted as Area B on the survey grid map. The to'~al activity of this area (5.1 mCi) is based on 6,000 cubic feet of soil contaminated with the spoils from the South Radwaste Building. Table I lists the principal nuclides identified in the contaminated soil. The activity in this table is based on measurments in 1987, and in a recent submittal (Reference 5) the activity concentrations in the contaminated area are noo showing a 10 percent drop in activity. The radionuclide half-lives, which are dominated by 30-year Cs-137, meet the staff's 10 CFR 20.302 guidelines (6) which apply to radionuclides with half-lives less than 35 years.

The contaminated soil has a six-inch layer of clean topping material (gravel) to prevent migration of the radioactive material via wind erosion. The approval to retain the soil in place will be ducumented in the licensee's FSAR and ODCM.

Table 1 Average Nuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 0.05 0.079 Cs-137 30 5.0 Total 5.079 RAD)IOLOGICAL IMPACTS The licensee has evaluated the following potential exposure pathways to members of the general public from the radionuclides in the contaminated soil:

(1) external exposure caused by direct radiation from radionuclides in the soil; and (2) internal exposure from inhalation of resuspended radionuclides. The staff has reviewed the licensee's calculational methods and assumptions and finds that they are consistent with NRC Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,' Revision 1, October 1977; the staff finds the assessment methodology acceptable. The dose assessments are based on the following:

1. 5.1 mCi of contaminated soil distributed over 12,000 square foot planar source having a thickness of 0.5 feet (6000 cubic feet source volume).

3-

2. Direct radiation exposure of 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year.

3. Inhalation exposure based on 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year is minimized due to six-inch layer of gravel (which inhibits wind erosion.)

4. Groundwater not considered because there are no domestic wells in the area down-gradient from the plant.

i Doses calculated from these pathways shown in 'ible 2. The total dose of 0.85 mrem per year is within the staff's guideline of I mrem per year (6).

Tablo 2 u

Whole Body Dose Received by Maximally Exposed Individual Pathway (mremlyear)

Groundshine 0.85 Inhalation 0.00081 Groundwater Ingestion 0.0 TOTAL 0.85 The above doses are a small fraction of the 300 mrem received annually

• 1 by members of the general public in the United States and Canada from sources of natural background radiation (7).

Based on our review of the proposed disposal of contaminated soil onsite, we conclude that:

(1) The radioactive material will be disposed in a manner such that it is unlikely that the material would be recycled; (2) Doses to the total whole body and any body organ of a maximally exposed individual (a member of the general public or a non-occupationally exposed worker) from the probable pathways of exposure to the disposed material will be less than I mrem per year; (3) Doses to the total whole body and any body organ of an inadvertent intruder from the probable pathways of exposure will be less than 5 mrem per year since the burial location is on company-controlled land;

(4) The radiation exposures to the nuclear station workers are small compared to the routine occupational exposures at the Palisades Nuclear Station; (5) The possible radiation risks to members of the general public as a result of such disposal are well below regulatory limits and small in comparison to the doses they receive each year from natural background radiation.

The licensee's procedures and commitments as documented in the submittal are acceptable, provided that they are permanently incorporated into the licensee Offsite Dose Calculation Manual (ODCM) as an Appendix, and that future modifica-tions be reported to NRC in accordance with the applicable ODCM chance protocol.

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REFERENCES (1) CPCo's letter, T. C. Bordine to NRC Documert Control Desk, November 12, 1987 and January 29, 1988.

(2) Memorandam from L. J. Cunningham, DREP to 7. R. Quay, T. V. Wambach, "Request for Additional Information (RAI)," March 15, 1988, April 7, 1989, and January 12, 1990.

(3) CPCo's supplement to Reference (1), J. L. Kuemin to NRC Document Control Desk, June 27, 1988.

(4) CPCo's supplement to References (1, 2), G. B. Slade to NRC Document Control Desk, August 31, 1990.

(5) CPCo's letter, T. P. Neal to B. Holian, October 13, 1990.

(6) E. F. Branagan, Jr. and F. J. Congel, "Disposal of Slightly Contaminated Radioactive Wastes from Nuclear Power Plants," presented at CONF-860203, Health Physics Considerations Decontamination Decommissioning, Knoxville, IN, February, 1986.

(7) National Council on Radiation Protection and Measurements, "Exposure of the Population in the United States and Canada from Natural Background Radiation," NCRP Report No. 94, Bethesda, MD. December 30, 1987.

II 'l IN [I . .5I_ _____'

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ENCLOSURE 2 l .z

..I, PALISADFS PLANT FACILITY NAME: Palisades

SUMMARY

OF REVIEW/INSPECTION ACTIVITIES l Consumer Power Company (CPCo) submitted by letter dated November 12, 1987 a request pursuant to CFR 20.302(a) to retain contaminated soil onsite at the l

I Palisades Plant.

NARRATIVE DISCUSSION OF LICENSEE PERFORMANCE - FUNCTIONAL AREA RADIOLOGICAL l

CONlTROLS The licensee has not demonstrated a high degree of management control and involvement in the following initial 10 CFR 20.302(a) request. Specifically, responding to the staff's RAIs of April 7, 1989 and January 12, 1990, the licensee did not provide the information needed on the inhalation path-ay and the condition of the contaminated soil surfaces for the staff to complete its review. This information was eventually provided on August 31, 1990.

I Author

J. L. Minns February 28, 1991 s'

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