ML17306A957
| ML17306A957 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/08/1992 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC |
| References | |
| FRN-57FR29105, REF-WM-3 102-02270-WFC, 102-2270-WFC, 57FR29105, NUDOCS 9209170125 | |
| Download: ML17306A957 (7) | |
Text
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ACCESSION NOR 9209'170125 DOC. DATE: '72/09/08 NOTARIZED:
NO DOCKET 5 FACIL:STN-50-528 Pala Verde Nuclear Statiani Unit li Arizona Pub li 05000528 STN-50-529 Pala Verde Nuclear Statiani Unit 2i Arizona Publi 05000529'TN-50-530 Palo Verde Nuclear Statiani Unit 3i Arizona Pub'li 05000530 AUTH. NANE AUTHOR AFFILIATION CONMAYtM. F.
Arizona Public Service Co.
(formerly Arizona Nuclear PauJer REC IP. MANE REC IP IENT AFFILIATION NRC No Detailed Affiliation Given
SUBJECT:
Comments on proposed revision entitled>
EProposed3 "Technical Position on Concentration Averaging h
Encapsulation.
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NOTE TO ALL RIDS" RECIPIENTS:
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Arizona Public Service Company P.O. BOX 53999
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PHOENIX, ARIZONA850724999 WILLIAMF. CONWAY gXECUTIVEVICEPRESIDENT NUCLEAR 9209170125 92090S PDR PR NISC 57FR29105 PDR 102-02270-NFC/GAM September 08, 1992 Chief, Rules and Directives Review Branch U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Sir:
Subject:
CD
- g n
CD Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Comments on Proposed Technical Position on Concentration Av@ygtng; and Encapsulation File: 92-056-026'2-010-026 The 1992 Federal Register, page 29105, dated Tuesday, June 30, 1992, announced the availability of and solicited comments on a proposed revision, in part, to the 1983 Staff Technical Position on Radioactive Waste Classification.
The revision is entitled
[Proposed] "Technical Position on Concentration Averaging and Encapsulation."
Comments from Arizona Public Service Company on this proposed revision are enclosed.
Ifyou should have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely, WFC/8AM/pmm Enclosure cc:
J. B. Martin J. A. Sloan
COMMENTS ON [PROPOSED] TECHNICALPOSITION ON CONCENTRATION AVERAGINGAND ENCAPSULATION Arizona Public Service Company (APS) supports the establishment of standard criteria to provide consistency in waste classification practices throughout the industry. However, APS has identified some concerns regarding specific criteria proposed by the NRC in the
[Proposed] Technical Position on Concentration Averaging and Encapsulation.
The methodologies proposed in the Proposed Technical Position regarding mixing of similar homogeneous waste streams may require extensive system modifications.
APS is currently unable to obtain samples of spent ion exchange resin until they are transferred to a disposal container, making representative sampling of the matrix difficult, especially when individual resin beds which vary in radionuclide concentration are stratified within the disposal container.
To properly classify ion exchange resin under the Proposed Technical Position, APS willhave to modify current plant systems to allow either a) individual ion exchanger sampling at the inlet of the storage tanks, or b) mixing and batching of spent resin storage tanks to eliminate stratification in the disposal container.
To compensate for sampling inadequacies, APS often characterizes resin containers by gross radioactivity measurements in accordance with section 1.C of the 1983 Staff Technical Position on Radioactive Waste Classification.
Although this section remains unrevised, this methodology is prohibited under the Proposed Technical Position, which creates a regulatory conflict. APS recommends that the Proposed Technical Position be modified to allow classification of similar homogeneous waste streams using the average concentration of radionuclides over the volume or the weight of waste in the disposal container.
This will allow utilities to perform waste classification using direct sample or gross radioactivity measurement techniques.
APS agrees that the mixing of waste streams should not be performed solely to lower the classification of the disposal container.
The proposed guidance regarding mixing of activated or contaminated components will render most in-core instrumentation and other irradiated components unacceptable for disposal.
This willhave a severe impact on high activity waste storage capabilities as well as general area dose rates in such areas.
Consideration should be given to the inherent physical stability of such material, the relatively low volume of such waste material, the additional controls provided by packaging, and segregation of Class C waste at the disposal facility. APS recommends that the Proposed Technical Position be modified to allow classification of such material based on the volumetric - or weight - averaged concentration of all radionuclides contained in all of the material within the disposal container.
Utilities should be required to show, by documentation, that individual components were not mixed solely to lower the classification of any single component (prior to the cutting) to Class C.
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I Finally, our concerns regarding the proposed guidance for mixing dissimilar waste streams are based largely on ALARAconsiderations.
To properly classify containers, as proposed, a separate waste classification willhave to be performed on each component placed in the disposal container.
This will require additional handling and exposure to what are often highly contaminated articles.
Additionally, it will be difficult to justify radionuclide distributions used to classify such components ifthey are of unknown origin or from specialized systems not adequately represented by established waste stream sample databases.
This will result in additional surveying and sampling at significant exposure and expense.
Such articles could be placed in stabilized disposal containers with higher activity waste streams (e.g., filters). Their relative contribution to the activity of these containers would be negligible, and due to the stability provided, potential for differences in interaction with the disposal environment would be minimized.
APS believes that the Proposed Technical Position, revised as outlined above, willprovide consistent guidance without unnecessary exposure and economic burden to implement.
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