ML092881096
| ML092881096 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/14/2009 |
| From: | Energy Northwest |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| DOE 618-11 | |
| Download: ML092881096 (21) | |
Text
DOE 618-11 Burial Ground -
Project Status October 14, 2009
2 October 14, 2009 AGENDA Purpose Overview / Review Analysis Methodology Regulatory Review ENW 618-11 Project Schedule
3 October 14, 2009 PURPOSE Provide NRC Staff an overview of the 618-11 Project, and related ENW activities 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
- Tri-Party Agreement between State of Washington, EPA, and the DOE
- 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)
15 October 14, 2009 ANALYSIS METHODOLOGY Gap analysis Physical Security Plan FSAR Emergency Plan ISFSI Radiation Protection Environmental Monitoring Industrial Safety Operations/Work Control
Developed Gap Matrix with actions
DOE REGULATIONS AND GUIDANCE 10 CFR 830, Nuclear Safety Management 10 CFR 835, Occupational Radiation Protection DOE-STD-1027-92, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23 Nuclear Safety Analysis Reports DOE-STD-3011-2002, Guidance for Preparation of Basis for Interim Operation (BIO) Documents 16 October 14, 2009
COLUMBIA REGULATORY REVIEW 10 CFR 50.54(q) - Emergency Plan 10 CFR 50.54(p) - Physical Security Plan 10 CFR 50.59
- FSAR Change (e.g., Industrial Hazards)
- Control Room Habitability (Radiological and Non-radiological) 10 CFR 72.48 (Dose Limits at ISFSI Boundary) 10 CFR 50.90 10 CFR 51 (Environmental Review) 10 CFR 100 (Exclusion Area Control)
Potential Radiological Effluent Monitoring Program Impacts 17 October 14, 2009
COLUMBIA REGULATORY REVIEW Licensing Basis Results (Phase 1)
- Physical Security Plan - No impact
- FSAR - Revision needed; No NRC approval (preliminary) o 618-10 and 618-11 evaluated o Control Room Habitability o Operational impacts
- Emergency Plan - New EALs proposed for NRC approval
- ISFSI - No impact (preliminary)
- Radiation Protection - No impact
- Environmental Monitoring - No impact
- Industrial Safety - No impact 18 October 14, 2009
COLUMBIA REGULATORY REVIEW Change Management Actions Identified (Phase 1)
- Physical Security Plan - Blue Badge DOE workers
- FSAR - Document only design change documenting all impacts
- Emergency Plan - Revision with associated procedure revisions
- ISFSI - Evaluate additional monitoring (preliminary)
- Radiation Protection - Additional monitoring
- Environmental Monitoring - Additional monitoring
- Industrial Safety - No impact
- Operations/Work Control o Memorandum of Understanding (MOU) with DOE Contractor o Communications plan o Training 19 October 14, 2009
COLUMBIA REGULATORY REVIEW Regulatory analysis will be repeated for each Phase of project Approach, schedule, evaluation results, and conclusions will be discussed with NRC staff as desired or applicable 20 October 14, 2009
21 October 14, 2009 ENW 618-11 PROJECT SCHEDULE
WCH prepare and provide to ENW:
Aug. 2009
- Emergency Preparedness Hazards Assessment
- Safety Analysis (Basis for Interim Operation)
Finalize Memorandum of Understanding (MOU)
Oct. 2009
ENW Submittal of EAL/EP Change to NRC Dec. 2009
ENW Design Change Issued 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