BVY 16-021, Response to Request for Additional Information Related to 10 CFR 20.2002, Alternate Waste Disposal Request

Response to Request for Additional Information Related to 10 CFR 20.2002, Alternate Waste Disposal Request

ML16182A035
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/28/2016
From:	Boyle J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 16-021
Download: ML16182A035 (14)

Text

~Entergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd.

Vernon, VT 05354 802-257-7711 John W. Boyle Decommissioning Director 10 CFR 20.2002 BVY 16-021 June 28, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Response to Request for Additional Information Related to 1o CFR 20.2002 Alternate Waste Disposal Request (CAC No. L53116)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USN RC, "1 O CFR 20.2002 Request for Alternate Disposal at US Ecology Idaho, BVY 16-001, dated January 14, 2016 (ML16029A071)

2. Letter, USN RC to Entergy Nuclear Operations, Inc., "Request for Additional Information Related to 10 CFR 20.2002 Alternate Waste Disposal Request for Vermont Yankee Nuclear Power Station (CAC No. L53116) (ML16077A345}

Dear Sir or Madam:

By letter da~ed January 14, 2016 (Reference 1),,Entergy Nuclear Operations, Inc. (ENO) submitted a request for alternate disposal under 10 CFR 20.2002 of liquid low-activity .

radioactive waste from the Vermont Yankee Nuclear Power Station to the US Ecology, Inc.

(USEI) Resource Conservation and Recovery Act (RCRA), Subtitle C hazardous and low-activity radioactive waste treatment and disposal facility located near Grand View, Idaho. In Reference 2, the NRG requested additional information to complete review of the request. The additional information requested is attached .

.This letter contains no new regulatory commitments. Should you have any questions concerning this letter, please contact Mr. Coley Chappell at (802) 451-3374.

I JWB/tbs

Attachment:

Response to Request for Additional Information

• BVY 16-021 I Page 2 of 2 cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Sr. Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-8F5 Washington, DC 20555 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601

BVY 16-021 Docket 50-271 Attachment Vermont Yankee Nuclear Power Station Response to Request for Additional Information

BVY 16-021 I Attachment I Page 1 of 11 REQUEST FOR ADDITIONAL INFORMATION RELATED TO 10 CFR 20.2002 ALTERNATE WASTE DISPOSAL REQUEST FOR VERMONT YANKEE NUCLEAR POWER STATION (CAC NO. L53116)

Additional Information Required:

1. Comment: More information is needed on the inputs to the USEI Site-Specific Data Assessment (SSDA) workbook.

Basis: It is not clear what inputs and changes were made to the SSDA workbook other than those listed in Attachment 2 on the data input worksheet. For example, the number of trips for the long-haul direct truck drivers on the dose summary sheet appears to have been manually input instead of being calculated from the volume of the waste. This edit appears to be reasonable since the volume of water transported is less than the volume of waste ultimately disposed of. The NRC staff would like to understand if other edits were also made to the spreadsheet because the NRC staff would need to review any changes to the spreadsheet from the version the NRC previously reviewed.

Path forward: Provide a description of all inputs and changes made to the SSDA workbook other than those listed in Attachment 2 on the data input worksheet and the basis for those changes.

Response: USEI did amend the input for number of trips in the Vermont Yankee (VY) version of the SSDA workbook. This was due to the fact that trips will consist of water in tanker trucks (5,000 gallons each). However, the volume of waste to be disposed also includes the addition of solidification agent (i.e., clay) once the water has reached the USEI facility and has been prepared for land disposal. The number of trips therefore had to be amended manually such that the added waste volume from the solidification agent was not reflected in the required number of tanker truck shipments. No other changes to the internal calculation logic of the SSDA were made.

2. Comment: The potential doses to the excavator operator and the back-end truck drivers were not provided.

Basis: The description of the USEI Worker Dose Assessment in Section 4.2 states that the excavator operator removes the treated waste from the stabilization tank and places it into an on-site haul truck for transport to the disposal cell for burial. However, doses to the excavator operator and back-end truck drivers were not calculated by the SSDA workbook.

Path forward: Provide an evaluation of the doses to the excavator operator and the back-end truck drivers.

Response: Dose to the excavator operator in USEl's Treatment Building was captured in the SSDA workbook under the Function Name "Treatment Workers." However, the truck drivers that deliver the solidified waste from USEl's treatment building to the landfill were not accounted for in the calculations. A dose evaluation for these workers can be found on the dose calculation worksheet provided below, using the following information and assumptions:

BVY 16-021 I Attachment I Page 2 of 11 Water that has been solidified is transferred from the treatment pans into an awaiting dump truck for transit to the landfill for disposal. This task uses the same Microshield model as the "Back-End Dray Truck. Drivers" since the geometries are virtually identical. Each dump truck can carry 25 tons of solidified waste to the landfill per trip. Average transit time from the Treatment Plant to the landfill is 1O minutes. Two drivers perform this task at USEI with each assumed to receive equal portions of the total project dose. The VY project will require 100 trips between the Treatment Plant and the Landfill to dispose of the 2,500 tons of solidified water (and clay). The expected total effective dose equivalent (TEDE) to each truck driver is 7.76E-03 mrem.

ENO notes that the "Treatment Plant Truck Driver" function was not included in US Ecology's original SSDA workbook that was previously approved by NRC for use. Via communication between ENO and USEI, it has been identified that USEI plans to submit a revised SSDA Workbook and Technical Basis Document to NRC to correct this oversight.

BVY 16-021 I Attach ment I Page 3 of 11 USEI T&D Dose Calculation Worksheet Date: 611 612016 (for US NRG 20.2002 Alternate Disposals Customer: ..,.E.,..n_te_r""'w'--.,..---..,,,....-----------

Project: Vermont Yankee Torus W ater I. Radionuctides of Concern - Provided by Customer Assumed in Waste Stream pCi/cm 3 for uCi/cm 3 for 1

Isotope pCi/ml Microshield Microshield 1 Co-58 0.09 9.00E-02 9.00E--08 Volume of waste (ft"): 80,000 (after solidification)

Co-60 6.9 6.90E+OO 6.90E--06 Waste Density (lb/ft"): 62.5 Cs-137 3.00 3.00E+OO 3.00E--06 Waste Density (glee): 1.00 Fe-55 0.10 9.50E-02 9.50E--08 Mass of Waste (lbs): 5,000,000 H-3 1870 1.87E+03 1.87E--03 Mass of Waste (tons): 2,500 Mn-54 0.47 4.70E-01 4.70E--07 Mass per Truck Trip (tons): 25 (post-solification)

Ni-63 0.79 7.90E-01 7.90E--07 Tc-99 3.89 3.89E+OO 3.89E--06 U-238 0.38 3.80E-01 3.80E--07 Zn-65 1.95 1.95E+OO 1.95E--06 II. Summary of Potentially Exposed Workers a) Total Project Dose No. Total External Total Internal Total Project Waste External Internal Required Dose per Dose per TEDE per No. Contact Time Exposure Rate Dose Rate Trips or Worker Worker Worker  % of Max Function Employees (hr) (mR/hr)1 (mrem/hr) Distance (m) Reps. 2 lmreml (mrem) (mrem) Annual Dose Treatment Plant Truck Driver 2 0.2 7.63E--04 1.30E--05 0.6 100 7.63E--03 1.30E--04 7.76E--03 0.16%

Tanker Truck Driver 8 78.4 3.29E--03 1.30E-05 3.3 40 1.29E+OO 5.09E-03 1.29E+OO 25.86%

b) Total Dose per Year # of proj . years : 1 No. Annual Annual Total Annual Waste External Internal Required External Dose Internal Dose TEDE per No. Contact Time Exposure Rate Dose Rate Trips or per Worker per Worker Worker %of Max Function Employees (hr) (mR/hr)1 (mrem/hr) Distance (m) Reps. 2 (mrem) (mrem) (mrem) Annual Dose Treatment Plant Truck Driver 2 0.2 7.63E--04 1.30E-05 0.6 100 7.63E--03 1.30E-04 7.76E--03 0.16%

Tanker Truck Driwr 8 78.36 3.29E--03 1.30E--05 3.3 40 1.29E+OO 5.09E--03 1.29E+OO 25.86%

Ill. Internal Dose Assessment Radionuclide Co-58 Co~ Cs-137 Fe-55 H-3 Mn-54 Ni-63 Tc-99 U-238 Zn-65 Ass umed Transport Class: y y D w vapor w w w y y Concentration in waste (pCi/ g) : 0.09 6.9 3.00 0.10 1870 0.47 0.79 3.89 0.38 1.95 Dose Conversion Factor (mrem/pCi)4 ' 1.09E-05 2.19E--04 3.19E--05 2.96E--06 6.40E--08 6.70E--06 2.30E--06 8.33E--06 1.19E--01 2.04E--05 Respirable dust loading (glm 3): 2.30E-04 Breathing rate (m3/ hr) : 1.20E+OO Dose per Hour per nuclide (mrem) : 2.70E-10 4.17E--07 2.64E-08 7.76E-11 3.30E-08 8.69E-10 5.01E-10 8.94E--09 1.25E-05 1.10E--08 Total dose per hour (mremJ:I 1.30E-05 Ir<-- For Use in Total Dose' calculations above)

V. Notes & Assumptions 1 All external dose rates calculated using Microshield ver 10.

2 It is assumed that the Treatment Plant dump trucks deliver 25 tons of solidified waste to the landfi ll per trip at an awrage trans it time of 10 minutes .

The number of tanker trips is based on transport of water from VY to USEI (=200,000 gal I 5,000 gal per tanker = 40 trips) 3 Tanker Truck Driver modeled using same model as in HBPP Alternate Disposal Authorization (ML12244A100) 4 Dose Conversion Factors taken from FGR-11 (1988) and converted to units of mrem/pCi.

BVY 16-021 I Attachment/ Page 4 of 11

3. Comment: Clarification is needed on the internal dose to the landfill cell operators.

Basis: The description of the USEI Worker Dose Assessment in Section 4.2 states that the internal dose to personnel working in the disposal cells is estimated to be the bounding dose calculated for a stabilization operator. However, the internal dose to the landfill cell operators in Table 2 is not the same as the stabilization operator dose.

Path forward: Clarify the method used to calculate the internal dose to the landfill cell operators.

Response : The method used to calculate the internal dose to the landfill cell operators is as described in Section 4.2. The referenced statement was in error and does not affect the calculated dose results .

4. Comment: Additional information is needed on the time the truck drivers spend in the truck.

Basis: It is not clear if the truck drivers spend any other time in truck other than while driving , such as sleeping or taking breaks in the truck. It is unlikely that the driver would complete the 46.4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> trip without stopping.

Path forward: Clarify whether the truck drivers spend any time in the truck other than while driving. If the total time spent in the truck exceeds the 46.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> included in the dose calculation , provide an estimate of the potential dose to the truck driver from the total time spent in the truck.

Response: For the purpose of the SSDA calculations the truck drivers were assumed to spend nights in hotels away from the tanker trucks while not driving . However, ENO recognizes that this assumption may not be conservative, and that the Long-Haul Truck Drivers will not complete the trip from VY to USEI in a continuous run. To correct for the potential non-driving time in transit , an additional 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> has been added to the "Long-Haul Direct Truck Drivers" function in the SSDA for a revised total postulated exposure time of 78.36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (46.36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> plus 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />). This accounts for 3 nights of sleep (at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per night) plus 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for breaks and other activities with the assumption that the truck driver remains in the truck. Utilizing this additional time , plus the .6 meter distance assumed in the SSDA, and the revised isotopic make-up of the torus water described in the response to Question 6, the resulting TEDE to each truck driver is 3.13 mrem. This is considered to be a 'worse case' and is captured in the revised Summary of Project Alternative Disposal Dose Results table provided in the response to Question 6.

Additionally, the .6 meter distance between the "Long-Haul Truck Drivers" and the tank assumes a worse case day cab with no sleeper cabin . A truck that has a sleeper cabin adds shielding and increases the distance between the driver and the tank to at least 3.3 meters. For comparison, if the driver is assumed to be at 3.3 meters for 78.36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, the more realistic TEDE would be 1.29 mrem. It is noted that th is realistic model is identical to the one approved by the NRC as part of the Humboldt Bay Power Plant Alternative Disposal Authorization (ML12244A100). The results of this evaluation are provided under the function name "Tanker Truck Driver in the second part of the Dose Calculation worksheet provided in response to Question 2 above.

BVY 16-021 I Attachment I Page 5of11

5. Comment: The basis for the assumed tritium concentration is unclear.

Basis: The analytical results tor tritium have a qualifier that the value was estimated. The data exception report also notes that the sample container was preserved with nitric acid ,

which could cause the sample results to bias low.

Path forward: Provide a description of the method used to estimate the tritium concentration.

Response: In ENO's original submittal (Reference 1), the analytical results utilized a tritium concentration of 1.87E+03 pCi/cm 3 (or 1.87E-03 uCi/ml). The Part 61 analytical results tor tritium included as part of the original submittal did include a "Qualifier" which states "Result may be biased low due to the sample container being preserved with nitric prior to analysis."

While this qualifier exists, the results remain valid for several reasons . This input was based upon samples taken in November 2015 and was deemed to be representative based on additional sample results that were not included in the original submittal. The data below presents the results of routine samples of the Torus collected by qualified chemistry technicians and analyzed by task-qualified technicians at Vermont Yankee. In addition, a subsequent Part 61 analysis performed by the same lab identified a tritium concentration of 3

1.70E+03 pCi/cm (or 1.?0E-03 uCi/ml), and this sample was not preserved with nitric acid prior to analysis.

Tritium levels in the torus water have been on a gradual decline since radwaste was added to the torus due to two factors: the station no longer produces tritium, so losses through evaporation are not replaced ; and a significant volume of groundwater with low or less than minimum detectable activity (<MDA) tritium concentration was processed to the torus ,

thereby diluting the torus water. This is shown in the following sample results:

Torus Sample Data Sample SA-UF Tritium Sample Date Time {uCi/ml} {uCi/ml}

12/02/15 07:45 < 4.30E-06 1. 75E-03 12/09/15 12:50 < 4.30E-06 1.80E-03 12/16/15 07:30 < 4.30E-06 1.71E-03 12/22/15 13:20 < 4.30E-06 l .70E-03 01/06/16 07:55 < 4.40E-06 l .69E-03 01/13/16 08:15 < 4.30E-06 1. 72E-03 01/20/16 08:30 < 4.40E-06 1.69E-03 01/27/16 07:45 < 4.40E-06 1.67E-03 02/03/16 07:55 < 4.30E-06 1.67E-03 03/02/16 08:10 < 4.30E-06 l .71E-03 03/17/16 07:10 l .21E-05 1.71E-03 04/11/16 09:10 2. 55E-05 l .64E-03 04/28/16 08:20 l .84E-05 1.67E-03 05/12/16 14:00 1.09E-05 l .67E-03 06/ 07/16 13:50 3.83E-05 1.61E-03 Based upon the above information, the assumed tritium concentration of 1.87E+03 pCi/cm 3 remains conservative (from a dose calculation perspective) as well as representative .

BVY 16-021 I Attachment I Page 6 of 11

6. Comment: More information is needed on the characterization of the water and the uncertainty in the concentration of the radionuclides in the water.

Basis: The concentrations of the radionuclides in the water were based on data from a single sample. It is not clear if any other samples have been taken and, if so, what the range of concentrations observed was. Because the potential dose was estimated based only on one sample, the uncertainty in the concentrations, and therefore dose, may not have been adequately captured. Additionally, as noted in the previous comment, the reported concentration of tritium in the sample might not be representative of the actual tritium concentration .

Path forward: Provide information on any other samples taken of the water, including the range of concentrations observed for each of the radionuclides. Also, provide an assessment of the potential uncertainty in the concentrations , and therefore dose, as a result of basing the concentration on a single sample.

Response: The pumps associated with the torus water treatment system are typically run continuously, circulating 250 gpm through the system (50 gpm through the demineralizers).

System suction is from the original torus High Pressure Coolant Injection (HPCI) suction line and discharges via the original HPCI return line back into the torus. Maximum system flow rates create minimal (insign ificant) disturbance of sediments that would increase the likelihood of causing changes in the radionuclide concentrations or percent abundance of various radionuclides in the samples, as evidenced by the results shown below.

The torus water treatment system recirculates the torus volume (capacity 1.1 million gallons) approximately every 3 days, thus promoting a homogenous torus water volume.

Chemistry samples showed a steady decline in anion concentration after the demineralizers were placed in service. The steady trend in anion concentrations, vice erratic results, indicates the torus water volume is homogenous. While gamma isotopic analyses have not been performed regularly and may not be useful in determining homogeneity, gross gamma measurements have consistently been< MDA for the samples analyzed (<4.3 E-06 µCi/ml).

If the torus water volume was not being uniformly mixed, occasional spikes in activity would be expected.

BVY 16-021 I Attachment I Page 7 of 11 Torus Isotopic Trend 90.0 80.0 2 .Sl E-05

~ 70.0

~ bU.U ~""""'-------------....ii1~-----/J!\;__:!!~-~ 2.0lE-05

< 50.0 1.Sl E-05 ii 40.0

~ 30 .0 1..01E-05

-;;e. 1 0.0

5. lOE-OG 10.0 0 .0 ~~!'!!!!!!!!~~.............--------11~----------1. 1.00£-07

~<,

~'\,<:>

-r<;:j

~"');

...-% I otal Activity - Co-bu Activ'ity {µCifm'I) ....... spedfic Activitiy The trend above shows Co-60 activity and the percent of total activity contributed by Co-60 before and after the contents of the reactor pressure vessel were drained to the torus (during the period from early March to the middle of April). The trend data shows the total activity in the torus increased as expected when the reactor coolant was drained into the torus, and decreased as the torus demineralizers removed corrosion products from the torus water. Co-60 is the predominant isotope present before and after vessel drain .

The data below represents results from routine torus water samples taken at the Fuel Pool Make-Up Demineralizer Influent sample point. In addition to the routine torus sample results shown in the response to Question 5, gamma isotopic analyses were performed on several samples. A summary of the isotopic analysis for each sample is shown in Table 1 below. The samples were collected by qualified chemistry technicians, and the analyses were performed by task-qualified technicians.

Table 1: Torus Sample Isotopic Analysis Data Activ ity Nuclide Percent Sample Sample Date Spectrum# Isotope

(µCi/ml) Abundance K-40 2.868E-07 NORM not calculated Mn-54 5.817E-08 4.4 Torus 11/10/2015 SP-8553 Co-60 8.llOE-07 61.6 Zn-65 l.743E-07 13.2 Cs-137 2.727E-07 20.7 K-40 2.61E-07 NORM not ca lculated Ra-226 2.90E-07 NORM not ca lculated Th-234 2. 770E-07 NORM not calculated Torus 2/ 24/2016 SP-91 40 Co-60 2.198E-07 33 .5 Zn -65 5.258E-08 8.0 Cs-137 3.847E-07 58.5

_ __ ___ J

BVY 16-021 I Attachment I Page 8 of 11 Mn-54 4.143E-07 4.4 Co-60 7.174E-06 75.4 Torus 3/17/201 6 SP-9275 Zn-65 9.957E-07 10.5 Cs-137 9.328E-07 9.8 Mn-54 2.lllE-07 2.6 Co-60 5.870E-06 73.4 Torus 3/ 29/ 2016 SP-9340 Zn-65 7.028E-07 8 .8 Cs-137 1. 212E-06 15 .2 Mn-54 3.663E-07 1.4 Co-60 2.145E-05 84.1 Torus 4/11/2016 SP-9415 Zn-65 2.152E-06 8.4 Cs-137 1.552E-06 6.1 Mn-54 2.247E-07 1.6 Co-60 1.00SE-05 71.4 Torus . 4/28/2016 SP-9539 Zn-65 1.643E-06 11.6 Cs-137 2.167E-06 15.4 Mn-54 1.75E-07 1.6 Co-60 6.81E-06 63.6 Torus 5/12/2016 SP-9619 Zn-65 1.lOE-06 10.3 Cs-137 2.62E-06 24.5 NORM= Naturally Occurring Radioactive Material Since the submittal of Reference 1, the contents of several systems in the process of abandonment, including the majority of the liquid radioactive waste system, and the contents of the reactor pressure vessel have been drained to the torus. As a result of th is water add ition to the torus , the isotopic make-up of the torus water has slightly changed compared to information provided in Reference 1.

Based upon a recent Part 61 analysis of the torus water as well as samples analyzed by qualified site personnel, the Data Input Worksheet has been revised . Using the revised input data, updated exposure assessments have been completed using US Ecology's NRC-Approved Site Specific Dose Assessment methodology.

The revised Data Input Worksheet and the revised Summary of Project Alternative Disposal Dose Results showing a summary of the total doses for transporters and USEI personnel are provided on the following pages.

BVY 16-021 I Attachment/ Page 9 of 11 USEI Site-Specific Dose Assessment Workbook Re v. Date: 6/13/2016 Data Input Worksheet Customer: Enter WodssheetUserlnstructionsand Notes*

Project: Vermont Yankee Torus Water

1. Enter data into Yellow shadedc:ellsQtilY. All other Section I - Waste Stream Information cells i n the work book are auto mated and/or Maximum annual dose assumed for assessm ent ( mre m/ yr) : 5 protected .

3 2. Answer al l quest ions i n Section I - W aste Stream Vo lume of waste f cubicfe et lft }1 : 80,000 Informati on fi rst. Enter values in yellow cells or select 1

Vol ume of wast e fcubic vards (yd )1 : 2,963 answerfrom drop-down lists provided. Notes are also Volume of wa st e fcubic met ers {m 3}1 : 2,265 provided i n keycell s to assist the user.

Does wast e primarily co nsist of Soi l, Debris, o r a Mix of both? Soil 3. Enter co nce ntrations(in pCi/g} for all nuclides in Will s hiome nts be m ade bv rail, truck, o r a combinatio n o f both ? Truck your characterized waste stream into Secti on II

• Waste Profile Nuclide Evaluati on .

If Bo th, how ma nv mil es o f fro nt-e nd dray a re re quired? (N/ A if dire ct s hippe d) 0 l 0

4. The l'AaximumAcceptableConcen trationforeach Is wast e containerized or will it be shi ooed as bulk? Bulk nuclide is determined by either t he USEI waste If shiooed direct via t ru ck, how manv miles from oroi ect si te to USE/7 {N/A oth erwise ) 2550 l 2, 550 Acce ptance Cri teria (WAC) or a dose-based limit, Numbe r of years required to co mpl et e pro ject? 1 wh icheve r is lower. The dose-based li mit is tie d to t he Will wast e reauire RCRA t reatment? Yes Total Volume of Waste entered by t he user . Logic in Percent age of wast e vo lume reauirinR treatment ? 100% t he SS PA work book will auto matically choose the most Wast e Densitv (lb/ ft '): 62.5 appropriat e value fo r each nucli de .

5. USE! is limi t ed toa total of 3,000 pO/g o f source Wast e De nsitv (* !cm '!: 1.00 material summed ove r all parent & progeny nuclides Waste Mass (lbs): 5.00E+06 (Th+U) .

W ast e Mass (tonsI: 2.50E+03 6. US EI is limited to a total of 3,000 pCi/ g of 5NM Wast e Mass (g) : 2.27E+09 summed ove r all fissi le nudides an d t heir i sot opic Does t he wast e contain Sou rce Material I Urani um orTho ri uml? (Yes/Nol No mixtu re nuclides, i.e., U- 234, U-235, and U- 238 for Does the waste co ntain Special Nucle ar Material ? (Yes/No) No e nriched urani um.

7. Cross-checks against all USEI W AC limits are automatically calculated in the indicators below.

Section II* Waste Profile Nuclide Evaluation Customer Waste Maximum Profile Acceptable Concentration Concentration Ratio to USEI Max Nucli de (pCl/g) (pCJ/g) 4 Concentrati on Ac-227 3000 ~~

Ae-108m 3000 A** llOm £Vf_._, 3000 OK  : 3.13 Am-241 3000

,.,*_*.~

Am-243 3000 h f Al Au-195 3000 Ba -133

" 3000 0.631 Be- 7 le 3000 C-14 ',C" ,, 3000 Ca-41 '"Jo\!,. 3000 Cd-109 * '.t 3000 Ce-139 /' 3000 Ce -141 j<*

3000 Ce- 144 1'; *-**

3000 I OK Cf-252 Cl -36 """

<l~*!i 3000 3000 P' .,c Cm -242 3000 Cm- 243 ~~ **~* 3000 Cm -244 'l ~ ~* 3000 Cm -245 Cm-246

'"'"'"1

~>y'iJ!

3000 3000 ltQif; Cm-247 3000 *These cross -checks only apply to individual shipments Co-57 3000 f or US E/ WA C compliance purposes. Th ey are not Co-58 0.09 3000 0.000 intended fo r annualized safety assessment calculations Co-60 6.90 3000 0.002 tha t are dose-based.

Cr-51 3000 Cs-134 3000 Cs-135 3000 Cs -137 3.00 3000 0.001 Eu- 152 3000 Eu-154 3000 Eu -155 3000 Fe -55 0.10 3000 0.000 Fe- 59 3000 Gd-152 Gd-153 .. 3000 3000 Ge-68 3000 H-3 1870 3000 0.623 1-125 3000 1-129 3000 1-131 -:.i* 3000 lr-192 ******* 3000 K-40 3000 Mn -54 0.47 3000 0.000 Na-22 3000 Nb-93m 3000

BVY 16-02 1 I Attachment I Page 10 of 11 Nb-94 3000 Nb-95 3000 Ni-59 3000 Ni-63 0.79 3000 0.000 Np-237 3000 Pa-231 3000 Pb-210 3000 Pm-147 3000 Pu-238 3000 6

Pu-239 3000 Pu-240 3000 Pu-241 3000 Pu-242 3000 Pu-244 3000 Ra-226 500 Ra-228 500 Ru-103 3000 Ru-106 3000 S-35 3000 Sb-122 3000 Sb-124 3000 Sb-125 3000 Sc-46 3000 Sm-147 3000 Sm-151 3000 Sn-113 3000 Sr-89 3000 Sr-90 3000 Tc-99 3.89 3000 0.001 Te-123 3000 5

Th-228 3000 5

Th-229 3000 5

Th-230 3000 5

Th-232 55 Tl-204 3000 6

U-233 3000 5

U-234 3000 6

U-235 3000 5

U-236 3000 5

U-238 0.38 167 0.002 s

Natural Uranium 167 s

Refined Uranium 167 Depleted Uranium 169 Zn-65 1.95 3000 0.001 Zr-95 3000 otal Concentration (pCi/ g) 1887.6 Total Src Mat/ {pCi/ g) 5.32 Total SNM {pCi/ g) 0 Total Activity {µCi) 4.28£+06 SOR: 0.631

BVY 16-021 I Attachment I Page 11of11 USEI Site-Specific Dose Assessment Workbook Rev. _ _2_ _ Date: _ _6._/_13-'--/2_0_1_6 Summary of Project Alternate Disposal Dose Results Customer: Entergy I Project: Vermont Yankee Torus Water I Number of Project Years : 1 I Max Dose All owed (mrem/yr): 5 I a) USEI Worker Total Project Dose Total External Total Internal Total Project Minimum External Dose per Dose per Dose per Number of Waste Contact Exposure Rate Internal Dose Distance Total No. of Worker Worker Worker  % ofMax Function Workers Time {hr) lmR/hr) Rate lmrem/hr) (ml Repetitions (mre m) (mrem) (mrem) Annual Dose Front-End Dray Truck Drivers 4 0.00 8.00E-03 O.OOE+OO 0.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.00%

Long-Haul DirectTruck Dri vers 8 78.36 8.00E-03 O.OOE+OO 0.6 40 3.13E+OO O.OOE+OO 3.13E+OO 62.67"/o Gondola Rai I car Surveyors 4 0.33 7.46E-03 O.ODE+OO 1.0 0 O.OOE+OO O.OOE+OO O.OOE+OO O.OO'A.

Truck Surveyors 8 0.08 6.25E*03 O.OOE+OO 1.0 40 2.SOE-03 O. OOE+OO 2.SOE-03 0.05%

ln termodal Container Surveyors 8 0.08 6.25E-03 O.OOE+OO 1.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.00°/o RTF Excavato r Operator 2 0.75 4.33E-03 l.29E-05 2.0 0 O.OOE+OO O. OOE+OO O.OOE+OO 0.00°/o Gondol a Rai l car Cleano ut 4 0.16 2.09E-03 1.29E-05 0.3 0 O.OOE+OO O.OOE+OO 0.00E+OO 0.00°/o Rail Tran sfer Eouipment Operator 4 0.25 7.16E-04 O.OOE+OO 4.9 0 O.OOE+OO O.OOE+OO O.OOE+OO O.OO°A.

Back-End Dray Truck Drivers 10 0.75 O.OOE+OO O.OOE+OO 0.6 0 O.OOE+OO O.OOE+OO O.OOE+OO O.OO°A.

Treatment Workers 6 0.75 2.52E* 03 1.29E-05 2.0 so l .57E-02 8.08E-05 l .SBE-02 0.32%

Landfill Cell Operators 4 0.25 2.68E-03 1. 29E-05 1.0 so 8.37E-03 4.04E-05 8.41E-03 0.17",{,

bl USEI Worker Total Dose per Proiect Year (if applicable)

Annual Annual Total Annual Minimum External External Dose Internal Dose Dose per Number of Waste Contact Exposure Rate Internal Dose Distance Total No. of per Worker per Worker Worker  % of Max Function Workers nme (hr) lmR/hr) Rate (mrem/hr) (m) Repetitions (mrem) (mreml (mrem) Annual Dose Front-End Dray Truck Dri ve rs 4 0.00 8.00E-03 O.OOE+OO 0.0 0 O. OOE+OO O.OOE+OO O.OOE+OO 0.00°/o Long-Haul Direct Truck Drivers 8 78.36 8.00E-03 O.OOE+OO 0.6 40 3.13E+OO O.OOE+OO 3.13E+OO 62.67"/o Gondola Rai l car Surveyors 4 0.33 7.46E-03 O.OOE+OO 1.0 0 O.OOE+OO O.OOE+OO O.OOE+OO O.OO°A.

Truck Surveyors 8 0.08 6.25E-03 O.OOE+OO 1.0 40 2.SOE-03 O.OOE+OO 2.SOE- 03 0.05%

lntermodal Container Surveyors 8 0.08 6.25E-03 O.OOE+OO 1.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.00°/o RTF Excavato r Operator 2 0.75 4.33E-03 l.29E-05 2.0 0 O.OOE+OO O.OOE+OO 0.00E+OO 0.00°/o Gondola Rail car Cleano ut 4 0.16 2.09E-03 l .29E-05 0.3 0 O.OOE+OO O.OOE+OO O.OOE+OO O.OO'A.

Rail Transfer Equi pme nt Operator 4 0.25 7.16E-04 O.OOE+OO 4.9 0 O.OOE+OO O.OOE+OO 0.00E+OO O.OO°A.

Back-End Dray Tru ck Drivers 10 0.75 O.OOE+OO O.OOE+OO 0.6 0 O.OOE+OO O.OOE+OO 0.00E+OO 0.00°/o Treatment Workers 6 0.75 2.52E-03 l .29E-05 2.0 so l .57E*02 8.08E-05 l.SBE-02 0.32%

Landfill Ce ll Operators 4 0.25 2.68E-03 1.29E-05 1.0 so 8.37E-03 4.04E-05 8.41E-03 0.17"A.

c) USEI RESRAD Post-Closure Screening Dose 8.42E-02 ' mrem/yr J!IQ1il;

1. Tota l No. ofRepetitions (Tanker Tri ps)= 200,000 ga I / 5,000 gal per tanker= 40 d) lnadvertant Intruder Doses 2. Waste Contact Time fo r the Long-H~ul Truck Drivers has been adj usted to 78.36 hrs to account fo r potential rest time in truck . ..

(d) 1. Const ruction Sce nari o _ _2_ .0_l_E-_

O_l__ mrem/yr 3. Dose to Tr eatment Pl ant and Landfi ll Workers rep resents labor assoc ited wi th pos t-sol idifica ti on soils to landfil I.

(d) 2. We ll Drill er Sce nario _ _1_.0_7_E-_O_ l __ mrem/yr 4 . Transportation plan calls for 8 tanker trucks assigned to proj ect, wi th each truck making 5 trips .

(d) 3. Dri ll er Occupancy Scenario _ _1_ .3_0_E-_0_

2 __ mrem/yr 5. The Treatment pathway is turned on due to the need to solidify the water prior to disposal.