ML17341A257
| ML17341A257 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/19/1981 |
| From: | Luebke E, Mark Miller, Paris O Atomic Safety and Licensing Board Panel |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| ISSUANCES-SP, NUDOCS 8106250239 | |
| Download: ML17341A257 (10) | |
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i TOMIC SAFETY AND LICENSING. BOARD Before Administrative Judges:
Marshall E. Miller, Chairman Ctp Dr.
Emmeth A.. Luebke Dr..Oscar H. Paris Pl g
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@~~g gag? 8 1981 In the Matter of FLORIDA'OWER AND LIGHT COMPANY (Turkey Point Nucl ear Generating, Units 3 and 4)
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Docket No
-250-SP>
56=25 1=SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs)
June 19, 1981 FINAL ORDER In the Board's May 28, 1981 Memorandum and Order granting summary disposition of all contentions, the. parties were directed to address the facts regarding the handling, storage, transportation or other disposition of low-level solid waste to be generated by the proposed steam generator repairs.
The parties were also asked to state their posi,tions on whether the Board can or should take any action regarding this matter, including the imposi-tion of license amendment..conditions (pp.- 42-43).
The Staff replied on June 12, 1981, taking the position that the Board possesses the authority to impose appropriate license conditions, but that the onsite storage of repair - generated low-l.evel solid waste does. not pose an undue risk to public health and safety, even in the event of a hurricane or tornado.
The.affidavit of the project manager, Marshall Grotenhuis, was filed in support of this conclusion.
81 06 P.50
The Licensee, FIlorida Power and Light Company (FPL), filed an affi'davit, by. Alan J. Gould, employed by.it as a Power Resources Radwaste and,.Radio-chemistry Specialist Detailed facts and conwIitiments concerning the handling, storage, 'transportation and di. position of low-level= solid wastes were set forth, supporting the conclusion that even if al~l the, drums in which such waste was stored were breached by a hurricane or tornado, the resultant doses would be below 10 CFR Part 20 limits.
The intervenor took the positions that FPL ~should be requir'ed to submi't an application under 10 CFR ii20.362 for its proposed disposal pro-
- cedures, with opportiinity for comment.
The Staff should be required to prepare an FES on generic low llevel waste disposal, with the repairs
The Staff should be directed to contact appropriate State of Florida agencies concernirig the compl,etion of certain low level waste disposal studies.
The repair should be prohibited because there is no legal manner in which to dispose of such low-level wastes.
Qiscovery should be reopened on thi. issue.
The Licensee has modified its low-level radioactive waste (LLW) manage-ment in view of the recent restrict.ions placed on storage at several burial
- sites, such as Barnwell, South Carolina.
Priority of offsite shipment is 1'/
to be given to materials with higher specific radioactivity, while materials retained at site will contain r'elatively low concentrations of radioactivity.
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Affidavit of Alan J. Gould, dated June 12, 1981.
FPL may also obtain additional burial allocation from the "first come, first serve" pool at Barnwell. It is expected that an additional allocation of between 700 cu-ft. to over 1,000 cu-ft wi:ll be availabl'e to FPL each month.
FPL is seeking a permit for shipment of LLW to an alternate waste disposal facility.
The solid low-,level waste generated by the steam generator repairs will be handled by the same procedures as low-level waste which is generated from routine plant operation and maintenance.
These provisions include the 1
compaction of dry radioactive compressible. trash, such as rags, paper and clothing, using.a highly efficient waste compactor in order to reduce the volume.
Waste which contains a relatively high concentration of radioactivity is kept inside the Turkey Point Radwaste Building during the brief period (2 to 3 months) it is on site pending preparations for shipment and transpor-tation.
All solid low-level waste located, on site will be monitored by portable monitors and swipe tests fol.lowing approved procedures.
Shipments offsite will comply with approved plant procedures and applicable Department of Transportation (DOT) and NRC regulations.
The low concentration LLW retained on site will be packaged as
'follows:
(1)
Compressible trash is compacted into wooden boxes 'known as LSA boxes.
These meet the criteria of a strong, tight package under 49 CFR Part 173.
These boxes are lined with steel plates and plastic liners.
The lids of filled boxes are nailed in place, and a steel lid cover is then
-=4-nailed over the previous lid.
TiIe 4nkire box is, cross banded with f'ive.teel straps. I -p/aktic cover is then placed over the, entire. box,. and the box is rebanded with another five steel straps.
(2)
Noncompressible solid waste with lok Concentration of radioactivity would.normally be packaged in steel drums
- meeting, DOT specifications for Type A packaging in.
accordance with 49 ClFR Parts,173 and 178.
Drum lids are clamped-into place and held securely by a bolting ring.
LSA boxes with relatively low concentrations of radioactivity, w'il'll b'e
'ied or banded togetlher in blocks of four,, providing a subassembly weighing approximately 16,000 lbs.
They will be stacked no.more than two high.
Plastic covers -and/or tarps will be used to protect these containers from storms.
Tie downs will be used for groups of these subassemblies to hold them in place in the event of hurricanes or tornadoes.
Drums containing LLW will be palletized and tied or banded together in groups of four.
They will be stacked no more than two high.
When stacked, the top and bottom subassemblies wi'll be tied or banded together, providing an assembly weighing approximately 4,000 lbs.
Tie down.
wil1l be used for these assemblies to hold them in place during storms.
All of the drum; which cannot be expeditiously shipped wil'I be located within the Turkey Point 3 and 4 Radiation Controlled Area (RCA) at, elevation 17.'!i't.
gLW and will be appropriately secured.
The total estimated volume of LLM with low concentration of radioactivity that might be retained on site during the repairs, including the 1,312 drums now on site, is approximately 45,600 cu-ft.
This represents a total estimated quantity of radioactivity of about 23.2 Ci.
This could be reduced by additional Barnwell burial allocation or disposal at an alternate site.
The protective measures noted above make it extremely unlikely that the packages would.be breached during a hurricane or tornado.
The Gould'ffidavit cites analyses of a hypothetical LLW container breach that show the radioactive disposal'onsequences to the public are insignificant because the concentrations are so low to begin with.
The Staff provided an affidavit by Marshall Grotenhuis, dated June 9,
- 1981, on low level waste management.
The handling,
- storage, transportation or other disposi.tion of low-level solid waste from the steam generator repair will be the same as the processing, of such waste during normal'peration.
With the unit under repair not:producing waste from normal operation, the total waste from the plant (two units) is, approximately the same during repairs as during normal two unit operation (FES,
- 54. 1.2. 1).
Reference was made to the Staff's accident analysis in FES, Sections 4.4 and 8.6.5,.which considered a range of. acci'dents and enumerated only the limiting -cases.
The hypothetical dispersal of LLW wastes was compared to the analysis of radioactive exposure consequences resulting from a steam generator lower assembly (SGLA) drop accident with the welded cover breaking loose.
Dispersal of radioactivity into the atmosphere and by water, pathway was considered.
The Staff estimated that a site boundary dose of'.5 mrem could result, from an accident which released into the atmosphere all of'he radioactivity in the LLW from the repair of one unit.
Whilie there is no specific regulation gover'ning a relea. e of this type we note that, a, release to the atmosphere giving a dose of 1.5 mrem i. well within the limits set forth in 10 CFR Part 50, Appendix I, governing the de ign objectives for yearly doses produced by the normal operat ion.of light-water-cooled power reactors.
The Staf F 2/
also estimated the concentration of radionuclides which would result if all the LLW were washed into the coolling canals.
The estimate of 1.4 x 10 uCi/cm is. within the limits set forth in 10 CFR Part 20, Appendix 8, forl releases to uncontrolled areas, as, the Staff observed.
Based upon the foregoing considerations, the Board concludes that the impact of a hurrica'ne or tornado on the LLM. produced by the steam generator repa.irs and stored temporarily on site at Turkey Point will not pos6 a
significant radio'logical hazard'-to the public.
The Board has rev.iewed the-12 statements of position filed by the Interv'enor, and considers that they are inapposite for the following reasons:
Position I.
This Board was constituted,to,rule on the application for admendmehts to FPL's OL.
We are not authorized to require FPL to apply for a l.icense pursuant to 10 CFR 20.302.
The Staff suggested that the 1.5-mrem re'lease to the atmosphere was accept-2/
able because it was "clearly bounded biy the SGLA breach accident, the limiting accident for purposes of evaluation" (Grotenhuis affidavit at 3).
However, the SGII.A drop accidlent was-judged to be acceptabl'e on the basis of a risk ana lysis, not.on the basis df konlseguences alone (SER, Section 3.4.2; FES, Section 4.4).
It is therefore deemed to be inappropriate and~
unacceptable for the Staff to attempt to, ccimpar'e the consequences of one accident with the risk analysis of another.
Position II.
Irrelevant, considering Posi'tion I.
Position III.
This is not a major federal action, and we 'have, no jurisdiction over the EPA.
Position IV.
Solid waste issue was addressed in the FES, Section 4.,1.2.2.
Position V.
Irrelevant considering Position IV.
.Position VI.
Irrelevant considering Position IV.
Position VII.
The Board has no. jurisdiction over disposition of low-level wastes -not generated by the repair itself, nor of matters within the sole purview of the State, of Florida.
.Position VIII. Part 61B fs:,.in'Rulemakin'g Status',
and:not" cognizable in this proceeding.
10 CFR 40. 11 and 70.
11 are not relevant to power stations.
10 CFR 30. 11 does not, require this license to "reveal" whether, it intends to apply for an exception.
Position IV.
The shipment of waste from this site is governed by the appropriate regulations.
The matter is not covered by the application for license amendments which is before this Board.
Position X.
Licensee has not proposed that it become a waste storage facility.
FPL has indicated that it has initiated plans to obtain additional burial allocation at Barnwel.l, on a "first come, first serve" basis.
Position XI.
The question of LLM disposal for the life of the plant is beyond the scope of this proceeding.
Position XII,.
The; Intervenor has had ample opportunity for discovery within the t.ime frame of all issues including LLM and his failure to ut.ilize it in a time'ly'fa'shion cannot now be asserted f'r purposes, of de'llay.
The Board has previousfly granted motions for summary disposition of al'1 contentions, and therefore canceled the evidentiary hearing.
Such actiion iis reaffirmed for the reasons set forth in our ttemorandum and Order entered May 28,,1981.
The parties were therein also directed to file detailed information. concerning the handling, storage,'ransportation or other dis-position to be made of,low ',level solid waste that might be generated bly-tahe'roposed repairs.
All of the parties ha've',now submitted such information.
For reasons discussed
- above, the Board h'as',co'ncluded that the impact of a hurricane or tornado on LLW to be stored at, Turkey Point during the prbpdseU repairs would not endanger the health and safety of the public.,
ORDER
,For all the foregoing reasons and based upon a consideration of the entire record in this matter, it is this '19th day of June,,
1981 Ordered That the evidentiary hearing previously scheduled concerning the Proposed Amendment to Facility Operating Licenses Nos.
DPR-31 and DPR-41 to Permit Steam Generator
- Repairs, is permanently
- canceled, and.the Director of Nuclear Reactor Regula.tion is authorized to-issue appropriate
.'iicense, a'mendments to permit the proposed steam generator repairs of Turkey Point
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Nuclear Units 3 and 4, in accordance with the commitments made. by the Licensee in its application and further described in the Affidavit of Alan J. Gould, dated June 12,,1981.
It is further Ordered, in accordance with 10 CFR 2.760, 2.762',
2.764, 2.785 and 2.786, that this Final Order shall be effective immediately and shall constitute the final action of the Commission forty-five (45) days after the issuance
- thereof, subject to any review pursuant to the, above-cited Rules of Practice.
Exceptions to this Final Order may be filed within ten (10) days after service of this Final Order.
A brief in support of any such exceptions must be filed within thirty. (30) days thereafter (forty (40) days in. the case of the NRC Staff).
Within thirty (30) days of the fil-ing and service of the brief of the Appel-lant (forty (40) days in the case of the NRC Staff), any other party may file a brief in support of, or in opposition to, the exceptions.
THE ATOMIC.SAFETY AND LICENSING BOARD Dr.
Emmeth A. Luebke ADMINISTRATIVEJUDGE Dr. Oscar H. Paris ADMINISTRATIVEJUDGE Marshall E. Miller, Chairman ADMINISTRATIVEJUDGE '
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