ML17129A322

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TSD-14-005, Rev. 0 - Backfill Material Specifications
ML17129A322
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 07/01/2015
From: Farr H
ZionSolutions
To:
Office of Nuclear Reactor Regulation
Shared Package
ML17129A311 List: ... further results
References
ZS-2016-0022
Download: ML17129A322 (9)
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Text

ZionSolutions, Inc.

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Technical Support Document ""ElwilY-~

TSD 005 BACKFI LL MATER IAL SPECIFICATIONS Revision 0 R.evie\Ver: ~-~~

Darlene Murphy 7 Date: /-(, -/s*-

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TSD 14-005 Revision 0 Summary of Changes in this Revision:

  • Rev. 0 -Initial issuance.

Page 2 of 9

TSD 14-005 Revision 0 TABLE OF CONTENTS

1. PURPOSE ............................................................................................................................... 4
2. DISCUSSION ......................................................................................................................... 4
3. EVALUATION ...................................................................................................................... 4 3.1. End Sate Requirements in Preparation for Basement Fill ...................................................... 4 3.2. Acceptable Candidate Fill Materials and Physical Attributes ................................................ 5 3.3. Radiological Requirements for Fill Material .......................................................................... 6 3.4. Environmental Requirements for Basement Fill End State (Candidate Fill Material and Remaining Basement Structure) ............................................................................................. 7 3.5. Testing and Approval for Off-Site Fill Material..................................................................... 8
4. CONCLUSION....................................................................................................................... 8
5. REFERENCES ....................................................................................................................... 8
6. ATTACHMENTS................................................................................................................... 9 TABLE OF FIGURES Figure 1 - Materials Acceptable for Basement Fill .................................................................................. 5 Figure 2 - Materials Not Acceptable for Basement Fill ........................................................................... 6 Page 3 of 9

TSD 14-005 Revision 0

1. PURPOSE This Technical Support document provides specifications for basement fill materials to guide the selection and use of materials in order to ensure regulatory requirements and commercial agreements are met and that end state modeling assumptions are valid.
2. DISCUSSION "Rubblization" involves: (a) removing all equipment from buildings; (b) some decontamination of the building surfaces (c) surveys to demonstrate compliance with the 10 CFR 20 Subpart E release criterion; (d) demolition and sizing of clean structures (e) placing the clean rubble into the below-grade structure; (f) demolishing the above-grade part of the structure into concrete rubble; and (f) covering, reading, and landscaping the site surface in accordance with Environmental permits. (1)

Item 8.5 under Article VIII of the Exelon and ZionSolutions Asset Sale Agreement (2)states, Tenant shall, at its expense, remove all improvements.... located at the Premises as of the Lease Commencement Date to a minimum of three feet (3') below the expected finished grade following site restoration or as otherwise required by Law, Permits or Environmental Permits and, except as otherwise required by applicable Law, Permits or Environmental Permits, back-fill such areas...

Thus concrete structures 3 feet below grade may remain on-site if allowed by applicable laws and permits and as authorized by the NRC for license termination in accordance with 10 CFR 20.1402.

Zion Nuclear Power Station Units 1 and 2 Amended Post-Shutdown Decommissioning Activities Report (3) states that, After the systems and components are removed and processed as described above, the remaining contaminated concrete and structural steel components will be decontaminated and/or removed. Contaminated concrete will be packaged and shipped to a low-level waste disposal facility. Remaining concrete will be decontaminated to meet the License Termination Plan (4) requirements for release of the site from NRC regulatory control.

Currently all structures will be removed at site with the exception of those portions of the Reactor Buildings (i.e., Containments), Auxiliary Building, Turbine Building including the Main Stream Tunnels, and Discharge Structures, Crib House and Forebay, Waste Water Treatment Facility (WWTF) and the Spent Fuel Pool and Transfer Canal. The building interiors will pass Source Term Survey (STS) (4) and then filled with clean fill which means that the material meets the MARSAME (5) requirement for unrestricted release in accordance with NRC guidance. Therefore the fill material will not be a source of licensed radioactivity since materials with positive identification of licensed material cannot be free released from the site under NRC guidance. The radioactive source term that will require fate and transport modeling is the residual removable and embedded contamination on the interior surfaces of the walls and floors..

3. EVALUATION 3.1. End Sate Requirements in Preparation for Basement Fill As noted in Section 5.1 of the Arcadis Report attached to the August 2014 submittal to the Illinois Environmental Protection Agency (IEPA) (6), only materials that are part of the structure (e.g.,

embedded) such as walls and floors may remain in the end state. (6) (7) Prior to backfill of end state structures, the subsurface commodities (e.g., components, ventilation, hangers, conduit, etc.) must be removed, the Source Term Survey (STS) must be completed and the ZionSolutions Page 4 of 9

TSD 14-005 Revision 0 Radiological/FSS and Environmental groups must authorize placement of the backfill materials.

Often regulatory inspections/verifications and approvals must obtained after the STS and Environmental confirmations are complete before an area can be backfilled.

3.2. Acceptable Candidate Fill Materials and Physical Attributes The concrete backfill material will be produced by crushing clean concrete candidate fill rubble generated by the demolition of other structures. Concrete processing or crushing will be used to size materials to less than a 10 diameter. The materials that can be placed in the basement structures are very limited. The materials described in Figure 1 can be placed in the basement structures:

ACCEPTABLE BASEMENT FILL MATERIALS Concrete, cinder block, stone, asphalt, material less than 10 inch diameter without protruding metal bars.

Unpainted concrete, or concrete with the paint removed, generated from the demolition of on-site aboveground structures , subgrade walls cut off for project purposes, and demolished sidewalks, driveways and parking lots that meet the radiological requirement of 3.3.

Painted concrete generated from the demolition of the aboveground structures or subgrade walls cut off for project purposes, if it meets environmental requirements discussed in Sections 3.3 and 3.4 Soil, stone, rock, bricks and asphalt generated from site demolition activities f it meets environmental requirements discussed in Sections 3.3 and 3.4.

Uncontaminated soil brought to the site from a commercial location following testing and approval in accordance with 3.5.

Figure 1 - Materials Acceptable for Basement Fill Materials that cannot be placed in the basement structures are those which would constitute waste disposal under Illinois law. The list in Figure 2 identifies categories of materials that cannot be placed in the basement structures.

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TSD 14-005 Revision 0 MATERIALS NOT ACCEPTABLE FOR BASEMENT FILL Any metal from the structures or equipment. This is true regardless of whether the equipment was previously inside or outside the basement structures. The only exceptions would be rebar within larger pieces of concrete, and rebar within the un demolished floors or walls and any piping or metal embedded in walls or floors or under floors that will remain in place.

Any plastic materials, including PVC piping (except for PVC piping embedded in walls or floors or under floors that will remain in place.)

Any paper products, such as office waste Any substantial vegetation, such as tree limbs or wood stumps (e.g., minimal vegetation such as grass that grows in while the material is stock piled is acceptable)

Any trash, garbage or other food waste Any oils or other liquid wastes Any transformer or transformer component Figure 2 - Materials Not Acceptable for Basement Fill 3.3. Radiological Requirements for Fill Material Fill material must be radiologically clean which means free of detectable quantities of licensed radioactive material and approved for use a backfill material. This is essentially the same requirement that is applicable to materials released from the site for unrestricted use. Acceptable methodologies include use of the MARSAME (5) process to release structures or materials (e.g.,

buildings, pavement, etc.) or unrestricted release process for soils and flowable solids in accordance with ZionSolutions radiological procedures. Process knowledge may also be used for material from non-impacted areas or that have been previously surveyed. The MARSAME process applies large volumes of material such as pavements, large excavations, etc. and employs statistically based survey plans, measurements and data evaluations to ensure data quality objectives are met. Smaller volumes of material may be surveyed, sampled and tested in accordance with site unconditional release requirements based on NRC HPPOS 072 (8) (9)which specifies detection sensitivity requirements for total contamination, removable contamination and for laboratory analysis of flowable materials such as soil, rubblized concrete, etc. Cs-137 and Sr-90 are licensed radioactive materials that are also present in background. Positive identification of Cs-137 or Sr-90 requires evaluation by the Final Status Survey or Radiation Protection group (depending on delineation of responsibilities at the time) to determine if levels are within the range of background for the material being analyzed. Positive identification of any other plant related radionuclide such as Co-60 indicates the material is contaminated with plant related nuclides and cannot be used as clean fill. Final Status Survey isolation and controls are normally established at the start of the survey/sampling process and remain in effect until the material is sued as clean fill in order to prevent cross contamination of the material.

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TSD 14-005 Revision 0 3.4. Environmental Requirements for Basement Fill End State (Candidate Fill Material and Remaining Basement Structure)

Clean construction or demolition debris (CCDD) is uncontaminated broken concrete without protruding metal bars, bricks, rock, stone, or reclaimed asphalt pavement generated from construction or demolition activities. When uncontaminated soil is mixed with any of these materials, the uncontaminated soil is also considered CCDD. Uncontaminated soil that is not mixed with other CCDD materials is not CCDD. What constitutes "uncontaminated soil" for purposes of CCDD and uncontaminated soil fill operations is defined in 35 Ill. Adm. Code 1100. (5) 35 Ill.

Adm. Code 1100 was last amended by the Illinois Pollution Control Board in its Final Opinion and Order dated August 23, 2012. These changes, which begin on page 6 of the Final Opinion and Order, became effective August 27, 2012 (7; 6; 13)

It has been determined that the CCDD regulations do not apply to the conceptual plan for the Basement Fill End State. (6; 7) This determination is based on the fact that this site is not a permitted fill Operation and we are not performing activities classified under Other Excavation requirements. (13; 11; 14) This determination was confirmed with the Illinois EPA. (7)

ZionSolutions received permission to utilize the regulatory framework of 35 Ill Administrative Code, Section 1100. (7; 6) .

ZionSolutions received a written concurrence from the Illinois EPA that the activities of placing CCDD materials are not waste disposal activities subject to Illinois solid waste regulations. (6; 7)

In addition to the Illinois EPA regulatory framework for Candidate Fill Material, ZionSolutions must comply with the TSCA regulations (40 CFR 761) for PCBs on painted concrete surfaces of CCDD and in the remaining basement structures. (9)

Under 40 CFR 761.3, PCB regulations differentiate PCBs in paint where the PCBs were part of the paint as a product from PCBs in paint that resulted from a spill or release. PCBs in paint, mastics, sealants, or adhesives as part of a product are defined as PCB Bulk Product Waste under 40 CFR 761.3 if the concentration of PCBs is greater than or equal to 50 ppm. If the concentrations are less than 50 ppm, then the PCBs are not regulated under TSCA. (9)

Paint containing PCBs that were added during its manufacture and are at concentrations 50 ppm at the time of designation for disposal are regulated for disposal as PCB bulk product waste. The concentration at the time of designation for disposal would be the concentration in the paint itself prior to demolition, not mixed or diluted with waste from the underlying wall or other debris from the building. The materials included in the definition of PCB bulk product waste are regulated as such only if their PCB concentration at the time of designation for disposal is 50 ppm. If the PCB concentration in paint is < 50 ppm at the time of designation for disposal and is not the result of a spill or release of regulated PCB, the material is not regulated under TSCA.

On October 24, 2012, USEPA issued a memorandum entitled PCB Bulk Product Waste Reinterpretation. When a structure is demolished, PCBs in paint that had been attached to the structure are evaluated based on the definition of PCB Bulk Product Waste. In other words, if the PCBs in the paint products were less than 50 ppm when the paint was on the wall, the demolition of the wall will not change the regulatory status of the PCBs. PCBs in paint as a result of a spill or release are regulated as Bulk Remediation Waste under 40 CFR 761.61. (9)

ZionSolutions developed a Sampling Plan for paints and coatings on building structures intended to be used as candidate fill material (above 588 feet) and sampling of paint and coatings in the major building basements, structures below 588 feet. (7)

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TSD 14-005 Revision 0 The proposed Basement Fill End State concept includes the use of Candidate Fill Material that complies with the CCDD regulatory framework (35 IAC 1100) and painted surfaces that do not exceed 35 Ill. Adm. Code 620.410(a), Groundwater Quality Standards for Class I: Potable Resource Groundwater for inorganic chemical constituents (for the applicable constituents or TSCA limits for PCBs. (6; 7; 11; 14)

The proposed closure strategy for the remaining basement structures will include a Self-Implementing option for removal of paint on surfaces that contain PCBs in paint and Risk Based option for some areas where painted surfaces contain PCBs with no potential for impact on human health or the environment. US EPA approval is being sought for these closure strategies.

3.5. Testing and Approval for Off-Site Fill Material Soils and materials procured from off-site locations require testing and approval to ensure they meet the requirement of the above sections. Radiological and environmental contaminant levels vary for different locations and care must be exercised not to introduce materials that could contain levels above site background levels and interfere with future monitoring and release of the site. Potential locations for off-site fill materials should be evaluated and approved by the ZionSolutions Environmental and Radiological/Final Status Survey groups prior to issuing purchase order for procurement of the material. Material stock piled on site should be subjected to the same isolation and controls to prevent cross contamination as the materials derived from on-site.

4. CONCLUSION Backfill materials must be properly sized and controlled in accordance with Figure 1 and Figure 2 requirements and radiologically and environmentally clean in order to meet Asset Sale Agreement, License Termination Plan and Illinois EPA requirements. Off-site source of backfill material should be approved by Radiological/FSS and the Environmental groups prior to procurement to ensure contaminants are not introduced to the site. Isolation and control measures are applied during the demolitions and stock piling process to prevent cross contamination of back fill materials.
5. REFERENCES
1. SECY-00-0041, Use of Rubblized Concrete Dismantlement to Address 10 CFR Part 20, Subpart E, Radiological Criteria for License Termination, February 14, 2000.
2. Zion Nuclear Power Station, Units 1 And 2 Asset Sale Agreement, December 11, 2007.
3. Zion Nuclear Power Station Units 1 and 2 Amended Post-Shutdown Decommissioning Activities Report March 17, 2008.
4. 415 Illinois Compiled Statutes (ILCS) 5/22.51 Sec. 22.51. Clean Construction or Demolition Debris Fill Operations.
5. Title 35: Environmental Protection, Subtitle J: Clean Construction or Demolition Debris, Chapter I: Pollution Control Board Part 1100 Clean Construction or Demolition Debris Fill Operations and Uncontaminated Soil Fill Operations.
6. TSD 024, Potential Impacts of Concrete on Groundwater Quality, October 2014.
7. Regulations for Clean Construction or Demolition Debris (CCDD) (Last Updated March 24, 2014), Illinois Environmental Protection Agency, Accessed July 28, 1997 http://www.epa.state.il.us/land/ccdd/.

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TSD 14-005 Revision 0

8. Title 35: Environmental Protection, Subtitle F: Public Water Supplies, Chapter I: Pollution Control Board, Part 620 Groundwater Quality.
9. 40 CFR 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution In Commerce, and Use Prohibitions.
10. ComEd Zion Station Historical Site Assessment, Version 1 - August, 1999.
11. 10 CFR 20 Standards for Protection Against Radiation, Subpart ERadiological Criteria for License Termination http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/.
12. 10 CFR 61.55 Waste Classification.
6. ATTACHMENTS None Page 9 of 9
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