ML17341A229

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Affidavit That NRC Does Not Believe Public Health & Safety Necessitates Imposition of License Amend Conditions Re Onsite Storage of Low Level Solid Waste Generated from Proposed Repairs of Steam Generators
ML17341A229
Person / Time
Site: Turkey Point  
Issue date: 06/09/1981
From: Grotenhuis M
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17341A228 List:
References
NUDOCS 8106160113
Download: ML17341A229 (10)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

FLORIDA POWER AND LIGHT COMPANY

)

)

(Turkey Point Nuclear Generating Unit Nos.

3 and 4)

Docket Nos.

50-250 50-251 (Proposed Amendments to Facility Operating Licenses to Permit Steam Generator Repair)

AFFIDAVIT OF MARSHALL GROTENHUIS ON LOW-LEVEL SOLID WASTE MANAGEMENT I, Marshall Grotenhuis, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a

Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation.

2.

I am the Project Manager assigned to the Turkey Point Plant steam generator repair program.

3.

The Board, in its Memorandum and Order of May 28, 1981 requested "detailed information concerning the handling, storage, transportation or other disposition of low level solid waste that may be produced at the Turkey Point Facility as a result of the proposed steam generator repairs."

Order at 42.

The Board expressed a particular interest in the onsite storage of low-level solid waste in drums, a subject introduced in affidavits which accompanied the Intervenor's-response to the Staff's final summary disposition motion.

The Board also directed the parties to "state their positions as to whether the Board can or should take any action regarding solid waste resulting from steam generator repairs at Turkey Point, including the imposition of license amendment conditions."

Order at 43.

The Staff position on this matter follows.

4.

The handling, storage, transportation or other disposition of low-level solid waste from the steam generator repair will be the same as the processing of such waste during normal operation.

Indeed, with the unit.under repair not producing waste from normal operation, the total waste from the plant (two units) is approximately the

.same during repair as during normal two unit operation.

(FES, 54.1.2.2).

5.

This waste, in the form of gloves, clothing, rags, etc.

wil-1 be stored in large drums or steel lined crates.

However, contrary to the position taken in the affidavits accompanying the Intervenor's response to the Staff motion for summary disposition of Contention 4B, the onsite e

storage does not pose an undue risk to the health and safety of the public, even in the event of a hurricane or tornado at the site.

In fact, the potential offsi.te radiological consequences were the drums to be somehow breached, are within permissible levels.

6.

It is true that hurricanes and/or tornados may blow the solid waste storage drums and could damage them.

l1an-made errors can do the same.

Our accident analysis (FES, Section 4.4 and 8.6.5) considered a

range of accidents and enumerated only the limiting cases.

However, if we were to consider the waste storage in an extremely conservative accident (over estimated),

we would have:

270 Curies (maximum amount from the repair of one unit)

I 33.5 15 mrem, 1.5 mrem (ratio of activity in drums to the activity released from the SGLA drop)

(ratio of meteorological condition from "average" to "stormy" weather)

(dose at the site boundary from SGLA drop)

41 This is the site boundary dose due to all the low-level solid waste from one unit repair being, released in one accident.

This is clearly an overestimate and is clearly bounded by the SGLA breach. accident, the limiting accident for purposes of evaluation.

7.

Similarly, should we postulate the release of all this same waste in one accident and have it wash into the canals, the concentration would be:

270'uries x

1 7x10 ft x 10 uCuries/curie x

1 ft3

~30. 5 cm

= 1.4 x 10

~ucur'es cm

'(maximum amount from the repair

,of one unit)

('olume of canal)

This is wi,thin 10 CFR Part 20.Appendix B standards for drinking water..

In the Staff affidavit of Richard B..Codell on contention 4A, it was concluded that such radioactivity from, the SGLA.breach, would be discovered by the well monitoring program long before, the radioact'ive ground water.would excape into the environment.

8.

The problem of low-level waste disposal is a generally acknowledged problem that has been delegated to the States with the Department of Energy as the lead agency to prepare a preliminary assessment pertaining to the development of regional sites.

(see
FES, Section 8.6.9).

9.

The steam generator lower assemblies presented, a different problem and thus were treated independently (FES, 54.1.2.3).

We

41

evaluated several possibilities and concluded that either offsite shipment and burial (FES, Appendix C) or onsite storage (FES 55.5) were equally acceptable.

As far as low-level waste is concerned, this does add an additional 270 m

and 750 Ci more per unit.

The onsite storage option would eventually (30 years) reduce the activity to less than one percent

(-6 Ci).

In terms of the eventual decommissioning of the

reactors, both the volume and the activity would be a small portion of the total plant.

10.

The Applicant has 'been improving the volume reduction aspect of the low level waste packaging process.

Data from the past few years indicates the magnitude of the improvement.

The actual low level waste volume* from the Turkey, Point Plant Unit No.

3 and 4 has been as follows:

Year Vo'lume

,Barnwell limit 1978 1979 1980 1981 62,000 ft 32,000 26,000 22,000**

1750m 900 740 790m3 620 (estimated) 680m ll.

In summary, the handling, storage, transportation or other disposition of low-level wastes (other than the steam generator lower assemblies) will be at about the same rate and in the same manner as for normal operation of the two facilities.

Handling of low level waste wil.l be by the same procedures and facilities as for normal operation.

Storage f

This does not include about 1300 drums (270m

) of contaminated dirt.

    • 'epair volume (estimated at 1100 m

per unit without most recent compacting gains) is not included.

0 4i "f1 k

until transported will be the same.

Transportation will be controlled by

,the same Department of Transportation controls.

Recently the Applicant has been able to improve the reducing and. compacting operation and reduce the volume of the waste.

In addition, the waste container with the highest activity may be shipped first.

Thus, even though the volume problem may remain, the total activity in storage could be minimized.

12.,

The Staff does, not believe that the public health and safety necessi,tates the imposition of any license amendment conditions concerning the, onsite storage. of low-level solid waste generated as a.

result of the proposed repairs.

dM~~

arsha Gro en ups l

Subscr,ibed and sworn to before me this ~day of o

ry Pu sc Hy Commission expires:.

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