ML092881062

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Presentation Slides, Energy Re 618-11 Burial Ground Project Status
ML092881062
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Site: Columbia Energy Northwest icon.png
Issue date: 10/14/2009
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Energy Northwest
To:
Office of Nuclear Reactor Regulation
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Download: ML092881062 (39)
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DOE 618-11 Burial Ground -

Project Status October 14, 2009

2 October 14, 2009 AGENDA Welcome and Introductions 618-11 Overview / Review Analysis Methodology Challenges / Proposed Resolution Basis for Requested Licensing Action (RLA)

Proposed EALs RLA Submittal 10 CFR 50.54(q) Evaluation

3 October 14, 2009 PURPOSE Provide NRC Emergency Preparedness Staff an overview of 618-11 Project Update Staff on progress of Emergency Plan impact evaluations Discuss proposed EALs Reach agreement on:

  • Need for NRC approval
  • Nature of submittal
  • Decrease In Effectiveness (DIE) determination Identify questions/issues

4 October 14, 2009 OVERVIEW / REVIEW 618-11 BURIAL GROUND Operated from 1962 - 1967 Approximately 8.6 acres in size

~50,000 yd3 Waste Found in:

  • 3 trenches
  • 50 vertical pipe units (VPUs)
  • 5 caissons

5 October 14, 2009 OVERVIEW (cont.) / WASTE FORMS / POTENTIAL HAZARDS Irradiated fuel fragments Uranium dioxide powder samples High activity liquid laboratory waste/plutonium contaminated liquids concreted in barrels Cyanide Beryllium contaminated waste Thorium waste Contaminated lab/shop equipment, construction debris Sodium Potassium

6 October 14, 2009 OVERVIEW / REVIEW 618-11 PROJECT DRIVERS CERCLA Record of Decision for 300-FF-2 Op Unit signed in 2001

  • Remove waste from trenches, VPUs, and caissons; treat as necessary and dispose
  • Cap / leave in place option evaluated but not selected Hanford Federal Facility Agreement and Consent Order
  • Legally binding agreement with enforceable milestones o Complete all 300 area remedial actions (including 618-10 and 618-11 Burial Grounds) by Sept. 2018

7 October 14, 2009 OVERVIEW (cont.)/618-11 SITE VPUs Trenches Trench 1 Trench 2 Trench 3 5 - Caissons 50 - VPUs Circa 1964

8 October 14, 2009 618-11 ENW Leased Property Line CGS Security Barrier Protected Area 200 meters

9 October 14, 2009 OVERVIEW (cont.) / WASTE FORMS / VPUS CPT Points, 4 per VPU

10 October 14, 2009 OVERVIEW (cont.) / WASTE FORMS / CAISSONS CPT Points, 6 per Caisson

11 October 14, 2009 OVERVIEW / REVIEW Current Plan / Scope DOE to start with 618-10 to gain experience 618-11 Phase I - Non-intrusive Characterization

  • Radiological characterization of trenches, caissons and VPUs
  • Geophysical surveys including ground penetrating radar and EMI to locate VPUs and caissons
  • Drive Cone Penetrometers (CPTs) around perimeter of each VPU and caisson and along centerline of each trench (~350 Total)
  • In-situ radionuclide characterization using multi-detector probe inserted in CPTs
  • Soil samples adjacent to and below base elevations of the waste units

12 October 14, 2009 OVERVIEW / REVIEW Current Plan (cont.)

618-11 Phase II - Intrusive Sampling Activities (Not yet approved in DOE SER, not within scope of the RLA)

  • Caisson or VPU breached with CPT, solid sample extracted, and video camera or radiation monitor inserted
  • Split spoon core drilling system to remove a measured amount of soil/waste from trenches, VPUs, or caissons
  • Pits excavated by backhoe in trenches to remove a sample
  • Backhoe excavation of VPUs or caissons has not been evaluated 618-11 Phase III - Remediation (Not within scope of the RLA)

13 October 14, 2009 OVERVIEW - LONG TERM SCHEDULE Phase I (Non-Intrusive Characterization) 618-10 Characterization - August 2009 to March 2010 ENW Agreement to Proceed (Phase I) at 618 February 2011 618-11 Characterization (Phase I) - February 2011 to February 2012 Analysis of Phase I Results - Feb 2012-April 2012 Phase II (Intrusive Characterization)

Development of Plan for Phase II and Safety Analysis Feb -

Sept. 2012 Submit Path Forward to DOE/RL and EPA - Sept. 2012 ENW Agreement to Proceed (Phase II) at 618 TBD Phase III (Remediation)

Must be completed by 2018

14 October 14, 2009 ANALYSIS METHODOLOGY Regulatory requirements/guidance review 10 CFR, RIS, RG, precedent Developed Requirements/Guidance Matrix DOE document review Safety Analysis o Basis for Interim Operation (BIO) o DOE Safety Evaluation Report (SER) o Technical Safety Requirements (TSRs)

Emergency Preparedness Evaluation o Emergency Planning Hazards Analysis (EPHA) o 618-11 Emergency Plan (pending)

Gap analysis (emergency events)

Emergency Plan interface (& security events)

Table Top session(s)

Developed Gap Matrix

15 October 14, 2009 ENW 618-11 PROJECT SCHEDULE

WCH prepare and provide to ENW:

Aug. 2009

  • Safety Analysis (Basis for Interim Operation)

Finalize Memorandum of Understanding (MOU)

Oct. 2009

ENW Submittal of EAL/EP Change to NRC Dec. 2009

NRC Approval Dec. 2010

ENW Agreement to Proceed Feb. 2011

Perform Surface Geophysical delineation Feb. - March 2011

Perform Phase I Characterization March - Sept. 2011

Evaluate Results / Conduct Workshop Oct - Dec. 2011

WCH Submit path-forward to RL and EPA March 2012

16 October 14, 2009 CHALLENGES

1. Differing EAL entry criteria
2. Treatment of ENW employees as public vs co-located worker
3. Lead organization/Incident command role for security events
4. CGS ERO response/responsibilities
5. Postulated short duration puff release (vs.

CGS type events)

17 October 14, 2009 RESOLUTION 1.

Differing EAL entry criteria:

For toxic release from 618-11 NESP-007 structure for Hazards and Other Conditions will apply

For radiological release from 618-11 Two new EALs and Bases for Unusual Event and Alert Pattern new non-plant radiological release EALs after toxic release Dose limits utilize existing EAL ARM setpoints

18 October 14, 2009 RESOLUTION (cont.)

2.

Treatment of ENW employees as Public vs Co-Located Worker (CLW):

Initial BIO treated ENW employees as CLWs CLW risk goals and dose threshold values are higher than the general public SECY-98-038 says CLWs would be treated as public in future NRC licensing actions

Approved BIO recognizes CGS as Public Access Area Design Basis Accident - Caisson Penetration with Fire (Phase I)

Onsite unmitigated dose is 8.9 Rem Maximum mitigated dose is.00445 Rem Soil overburden credited for reducing releases

19 October 14, 2009 RESOLUTION (cont.)

3.

Lead organization/Incident command role for security events Controlled by Memorandum of Understanding (MOU)

DOE assumes lead responsibility for events arising from 618-11 efforts ENW assumes lead responsibility for events arising from operation of CGS 4.

CGS ERO response/responsibilities Keyed to regulatory responsibilities Controlled by MOU 5.

Short duration puff release (vs. CGS type events)

No physical or operational impact to plant No impact to timing or capability of Emergency Response Organization (ERO)

Dose limits considered for public at 618-11 boundary

BASIS FOR REQUESTED LICENSING ACTION (RLA)

Requested Licensing Action:

Approval of the revised CGS Emergency Plan, including revised EALs, addressing Phase I 618-11 Activities 20 October 14, 2009

BASIS FOR REQUESTED LICENSING ACTION (RLA)

New activity within the CGS Exclusion Area Change to existing Licensing Basis with respect to:

618-11 Hazards Scope / Review Exclusion Area responsibilities / control

  • Current Licensing Basis:

ENW sole agency responsible

  • Lead responsibility for all radiological events
  • Implement required actions, including required notifications and on-site Protective Action Recommendations (PARs)
  • Proposed Change:

DOE / designated contractor will have responsibility for safety and oversight of 618-11 Burial Ground, including required notifications and PARs for 618-11 events ENW retains sole responsibility for all operational decisions governing safe operation of CGS 21 October 14, 2009

BASIS FOR RLA Relevant Regulatory Requirements DOE standards and requirements

BASIS FOR RLA Relevant Regulatory Requirements 10 CFR 100.3 (Exclusion Area definition)

  • Activities unrelated to operation of the reactor may be permitted in an exclusion area under appropriate limitations provided that no significant hazards to public health and safety will result.
  • Treatment of 618-11 Workers
  • Considered members of the public, relative to events which may occur at CGS
  • Specific measures established for prompt notification of 618-11 workers regarding events at CGS 23 October 14, 2009

BASIS FOR RLA Relevant Regulatory Requirements 10 CFR 50.47(b)(4) and 10 CFR 50 Appendix E IV 618-11 Workers

  • protected as members of public by CGS Emergency Plan Treatment of Energy Northwest workers
  • Considered members of the public, relative to 618-11 events
  • DOE contractor will assume the lead responsibility and promptly implement any actions, including PARs for the public at CGS in accordance with the 618-11 EP 618-11 Project Safety Basis documents, plans, and procedures have been evaluated Methods approved by DOE provide a similar level of protection as the NRC rules governing CGS activities within the exclusion area 24 October 14, 2009

BASIS FOR RLA Establishment of a Memorandum of Understanding (MOU)

Delineates roles and responsibilities for an integrated response effort for emergency events which may occur within the CGS exclusion area 25 October 14, 2009

PROPOSED EALs Unusual Event 9

Hazards 9.3 Man-Made Events Release of radioactive materials from an event at 618-11 Burial Ground deemed detrimental to safe operation of the plant.

9.3.U.4 Report or detection of radioactive materials dispersed from an event at 618-11 Burial Ground that could enter or has entered within the Protected Area Boundary in amounts that could affect the health of plant personnel or safe plant operation.

OR Recommendation by 618-11 project officials for evacuation or shelter of CGS site personnel based on a 618-11 event.

26 October 14, 2009

PROPOSED EALs Alert 9

Hazards 9.3 Man-Made Events Release of radioactive materials from an event at 618-11 Burial Ground that has entered a CGS plant structure which jeopardizes operation of systems required to maintain safe operations or to establish or maintain cold shutdown.

9.3.A.4 Report or detection of radioactive materials dispersed from an event at 618-11 Burial Ground that has entered a Safe Shutdown Building, Table 5, in concentrations that will be life threatening to plant personnel or impede access to equipment needed for safe plant operation.

27 October 14, 2009

RLA SUBMITTAL

Characterization of submittal Determined to not be an Alternate Method Determined to not be a hybrid EAL Determined to not be a DIE Outside initial NRC SER review scope?

Other?

Request NRC agreement on:

Submittal characterization Governing regulations/guidance Supporting documents to be submitted 28 October 14, 2009

Questions?

29 October 14, 2009

10 CFR 50.54(q) Evaluation 30 October 14, 2009

10 CFR 50.54(q) EVALUATION Four Elements for Consideration 1.

Protection of 618-11 personnel from an event at CGS 2.

Protection of all ENW employees, contractors, and visitors (i.e.,

the public) from an event at 618-11 3.

Potential impacts to plant personnel and/or access to equipment required for the safe operation of CGS due to a release of toxic, flammable, and/or radioactive materials from 618-11 4.

Potential impacts on the timing and capability to activate and operate on-site Emergency Response Facilities (Control Room, Technical Support Center, Operations Support Center, and Emergency Operations Facility) 31 October 14, 2009

10 CFR 50.54(q) EVALUATION

1) Protection of 618-11 Personnel from an Event at CGS

618-11 Personnel will be issued ENW Blue Badge or Visitor badges Blue Badge training on ERO includes:

training on the purpose of the EP, event classification, emergency alarms / responses, personnel accountability, evacuation routes and offsite assembly area location.

ENWs policy concerning the release of information to the public and news media regarding an emergency.

Visitors receive a brochure at security checkpoint.

Satisfies provisions for evacuation, offsite assembly, and radiological monitoring of evacuees for Phase I of the 618-11 project.

Phase I project plan includes installation of a loudspeaker and hard line phone system at 618-11 site.

Steady tone for site evacuation can be heard throughout 618-11 site.

ENW Telecommunications responsible to test and maintain operation of the site evacuation siren, 618-11 PA and telephone system.

32 October 14, 2009

10 CFR 50.54(q) EVALUATION

2) Protection of ENW Personnel from an Event at 618-11

618-11 site personnel are subject to TSRs, including administrative controls established for their Health & Safety while working on the 618-11 project.

TSRs require establishment of administrative controls that include Safety Management Programs (SMPs). The SMPs include the 618-11 Emergency Plan.

TSRs identify necessary design features that provide preventive or mitigative functions, and whose failure could adversely affect safety.

For 618-11, the soil overburden is identified as a design feature. The DOE SER authorizing Phase I activities at 618-11 states: Removal of the existing soil overburden is prohibited.

DOE will oversee and regulate the DOE contractor(s) working on the 618-11 project. DOE will be responsible for the regulatory and contractual oversight of design, construction, operation, and 618-11 event response activities.

DOEs contractors will be responsible for implementing DOE requirements in 10 CFR 830, 835, and 851 for the safe remediation of 618-11.

Should conditions arise at 618-11 which exceed a DOE EAL, DOE will assume the lead responsibility and promptly implement any actions including PARs for the CGS public in accordance with steps set forth in the 618-11 EP.

33 October 14, 2009

10 CFR 50.54(q) EVALUATION

2) Protection of ENW Personnel from an Event at 618-11 (cont.)

An MOU exists between ENW and responsible 618-11 project personnel that delineates roles and responsibilities for an integrated response effort for emergency events which may occur within the CGS exclusion area:

618-11 personnel will continue to keep ENW informed of its plans, schedules, and other matters relating to the 618-11 Project which could potentially impact CGS operation or compliance with the NRC license or regulations.

618-11 personnel will provide ENW with the latest revision of the safety basis and supporting documentation, including hazards analyses, TSRs, administrative controls, and emergency preparedness program.

618-11 personnel will provide ENW with Emergency Preparedness Program documentation.

618-11 personnel will notify ENW if new or different hazards (or changes to the probability or magnitude of hazards), arise as compared to those discussed in the approved project basis.

This will include identification of Potential Inadequacies in the Safety Basis or positive Unreviewed Safety Question (USQ) emerging issues (DOE USQ process).

618-11 personnel shall directly notify the CGS Control Room of any emergency condition.

618-11 personnel will provide any necessary contamination monitoring and decontamination of personnel, equipment or personal property as the result of events at 618-11.

618-11 personnel will coordinate with Energy Northwest on all 618-11 spills and / or contamination events and associated recovery actions to minimize impacts on CGS.

618-11 project management will provide radiological protection support for the 618-11 site.

When within the CGS Exclusion Area, 618-11 personnel and visitors shall be subject to the orders of the Columbia Security Force.

34 October 14, 2009

10 CFR 50.54(q) EVALUATION

3) Impacts to Plant Personnel from a Release at 618-11

Two new EALs added for a radiological release from 618-11.

UE AEL added to address a release within the Protected Area Boundary in amounts that could affect the health of plant personnel or safe plant operation.

Basis for dangerous to life or limb is taken from existing EAL #5.2.U.1 (valid ARM reading > 5000 mR/hr).

Alert EAL is added to address a radiological release from 618-11 that has entered a Safe Shutdown Building in concentrations that would be life threatening to plant personnel or impede access to equipment needed for safe plant shutdown.

Basis for impeding access to equipment necessary for plant operation is taken from existing EAL #5.2.A.1 (valid ARM reading > 10,000 mR/hr, or > 15 mR/hr on ARM RIS-19).

Existing EALs address the report or detection of toxic or flammable gases that have entered the Protected Area (9.3.U.3) or a Safe Shutdown Area (9.3.A.3).

The bounding Phase I 618-11 event would not warrant an emergency response under the proposed revision of the CGS Emergency Plan. No radiological or toxic material would be released within the Protected Area Boundary in amounts that could affect the health of plant personnel or safe plant operation as a result of the bounding 618-11 accident due to the distance involved (> 200 meters). However, it is appropriate to introduce the new EALs now, to ensure impacts from events beyond those analyzed could be addressed by the CGS Emergency Plan.

35 October 14, 2009

10 CFR 50.54(q) EVALUATION

4) Impacts on Timing and Capability of ERFs

Safety basis documentation for the 618-11 project identifies four accident groups that are considered to be bounding, representative, or limiting accidents as required by DOE-STD-3009-94, Preparation Guide for U.S.

Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports.

Chosen to include a broad range of events.

Provide the framework for response planning to any declared emergency resulting from 618-11 activities.

36 October 14, 2009

10 CFR 50.54(q) EVALUATION

4) Impacts on Timing and Capability of ERFs (cont.)

A caisson or Vertical Pipe Unit (VPU) penetration with fire and explosion is the bounding accident scenario.

The worst case radiological consequence is less than 100 mrem.

This would not require an emergency declaration under the 618-11 Emergency Plan.

Beryllium is considered to represent the bounding non-radiological hazard. For this event, the beryllium concentration remains less than Protective Action Criteria PAC-1, and therefore does not warrant an emergency response under the 618-11 Emergency Plan.

The bounding 618-11 accident would not warrant an Energy Northwest ERO response under the proposed revision of the CGS Emergency Plan.

As such, no impact to timing or capability of response within the Protected Area Boundary would occur (Control Room, TSC, and OSC).

37 October 14, 2009

10 CFR 50.54(q) EVALUATION

4) Impacts on Timing and Capability of ERFs (cont.)

Basis for concluding that ERF activation and operation capability is not lost or degraded.

No analyzed event at 618-11 would require CGS ERO activation. Further, no analyzed event at 618-11 could be a precursor to an event at CGS. Therefore, the simultaneous occurrence of an unrelated activation of the ENW ERO concurrent with an event at 618-11 is extremely improbable.

All analyzed 618-11 accident scenarios constitute a puff release. If the 618-11 project personnel recommend localized sheltering in accordance with the 618-11 Emergency Plan, the event duration would not require sheltering for a prolonged period of time.

Due to the short time duration of analyzed events at 618-11 and the extremely improbable occurrence of events at 618-11 concurrent with an ALERT or higher being declared by ENW, it can be stated that ERO center activation and operation is not lost or degraded. The probability of CGS site access being impacted by events at 618-11 is no greater than currently exists for the improbable event of a transportation accident blocking traffic on the normal site access road concurrent with an event at CGS. Therefore there exists no increase in potential to impact, or frequency of impacts to, timing and capability to activate and operate on-site emergency response facilities due to the analyzed consequence resulting from the bounding 618-11 event.

Proceduralized compensatory measures already exist for these low probability events.

38 October 14, 2009

10 CFR 50.54(q) EVALUATION

4) Impacts on Timing and Capability of ERFs (cont.)

Potential impacts from low probability simultaneous events Minor contamination of access roads on the west end of the site could occur.

If the ENW ERO needed to activate concurrent with an event at 618-11, normal access to the CGS site via Check Point 21 and access to the EOF could be impacted until DOE field teams, aided by ENW field teams, assessed the levels of contamination, performed the necessary posting and decontamination in accordance with the Memorandum of Understanding, and established safe (clean) access routes.

Normal ingress and egress to the site could quickly be moved to the east end access roads by removal of the road blocks to avoid any west end contamination until accident cleanup and recovery operations were completed.

In this instance, removal of the road blocks may not be timely enough to allow for EOF activation by off site responders; however, the EOF function could initially be transferred to the Alternate EOF downtown.

Likewise, access to the Control Room, OSC and TSC from off site might be delayed until the alternate route (southeast) access road blocks were removed or DOE field teams determined normal access routes from Check Point 21 were clean.

39 October 14, 2009

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