ML18044A715

Environ Assessment,Steam Generator Replacement.

ML18044A715
Person / Time
Site:	Palisades
Issue date:	12/31/1979
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18044A714	List: ML18044A713 ML18044A715
References
NUDOCS 8004070322
Download: ML18044A715 (64)

Text

ENVIRONMENTAL ASSESSMENT PALISADES PLANT STEAM GENERATOR REPLACEMENT CONSUMERS POWER COMPANY December 1979 8004070 32..2_

PALISADES SGR-EA

• 1

SUMMARY

Consumers Power Company has applied for an Act 247 Permit to deliver two replacement steam generators to the Palisades Plant. From both an economic and a technical viewpoint, barge delivery is preferred with the replacement generators unloaded at a docking facility at the Plant. This facility includes offshore and onshore components. In this Environmental Assessment Report, general littoral drift characteristics and chemical analysis of bottom sediments are discussed as a description of the existing environment in the affected offshore area. Impacts associated with the temporary barge slip facility are related to construction, dredge spoil disposal, shoreline and visual aspects. While adverse, all such impacts are temporary and minimal.

Secondary impacts associated with the steam generatpr repair project are also addressed in this Report. Monitoring activities include an observation program for beach erosion and analysis of dredged material. Appropriate State agencies would be consulted prior to taking mitigative measures that would involve additions to or changes in movement ~f beach material.

Various alternatives to the preferred barge delivery method were considered.

Truck transport from the fabricating shop is not feasible due to the massive size of the generators. Short haul trucking from harbors in the Plant vicinity is impractical and it is unlikely that necessary permits could be obtained due to the excessive size and weight of the steam generators. Rail transport is impossible due to unavailability of rail equipment for such a massive load and to obstructions along the route. Onsite assembly of the steam generators is not a practical alternative due to the massive onsite

• facilities required and the manufacturing status of the replacement 1-1

PALISADES SGR-EA

• generators. Not having the steam generators on site and available for installation could add over $50 million in replacement power costs to the cost of the potential repair.

If the repair project is necessary, the Palisades Plant could be shut down for one to two years to replace the steam generators. Costs for replacement power from the Consumers Power system are estimated to be $8-$10 million more per month over generation costs from Palisades. In addition; the direct costs associated witb the repair are estimated* to be $80 million.

There are no known controversies which have not been addressed and the major uncertainty is receipt of the Permit under Act 24l on a timely basis to complete planning and engineering for the barge slip facility prior to receipt

• of the replacement steam generators. Timely receipt of the necessary governmental permits and approvals will contribute substantially to the success of the steam generator replacement contingency plan and will also minimize the costs of the repair .

• 1-2

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• Section TABLE OF CONTENTS Title Page No 1

SUMMARY

1-1 2 TABLE OF CONTENTS 2-1 3 DESCRIPTION OF EXISTING ENVIRONMENT 3-1 3.1 Littoral Drift Characteristics 3-1 3.2 Bottom Sediment Analysis . . . 3-2 4 ALTERNATIVES TO THE PROPOSED ACTION 4""'.1 4.1 No Action 4-1 4.2 Onsite Assembly 4-2 4.3 Truck Transport 4-2 4.4 Rail Transport 4-3 5 DESCRIPTION OF THE PROPOSED ACTION 5-1 5.1 Need for the Project . 5-1 5.2 Purpose of the Project 5-2 5.3 Schedule 5-4 6 IMPACTS 6-1 6.1 Primary Impacts 6-1 6.2 Secondary Impacts 6-3 6.2.1 Physical Impacts 6-3 6.2.2 Economic Impacts of Plant Shutdown 6-3 7 UNAVOIDABLE ADVERSE IMPACTS 7-1 8 PROPOSED MITIGATION 8-1 9 UNRESOLVED CONTROVERSIES 9-1 10 REFERENCES . . . . . . . *. 10-1 APP A EXCERPTS FROM PALISADES STEAM GENERATOR REPAIR REPORT 2-1

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• Table LIST OF TABLES Description 3-1 Sediment Sample Analysis - Proposed Barge Slip Area

• 2-2

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-* Figure

. LIST OF FIGURES Description 3-1 Sediment Sample Locations - Proposed Barge Slip Area

• 5-1 Site Plan 5-2 General Arrangement - Section A-A 5-3 General Arrangement - Section B-B

• 2-3

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3 DESCRIPTION OF EXISTING ENVIRONMENT 3.1 Littoral Drift Characteristics Littoral drift, or the movement of sand along the shore, is due to wave action and a longshore current. The sand movement is predominantly toward the south, with occasional flow ~eversals.

The sand movement occurs in the region near the shore where ~ave action is sufficient to carry the. sand. This region is expected to extend offshore about 2,000 feet, which is the Corps of Engineers estimate for another location on the southeast shore of Lake Michigan (3). The flow of sand varies greatly on a daily basis, is more substantial during storms and rough weather, and is not significant during ice-bound periods. The annual net volume southward of the drift has been stated to be not more than 100,000 ctibic yards along the southeast shore of Lake Michigan (3).

Shore erosion is related to changes in littoral drift and to wind waves and water erosion. Storms, particularly during periods of high water level, have severely eroded the shore at times. The shore areas with bluffs in reach of the waves are particularly susceptible to damage. The coarser eroded materials join the longshore drift while the finer are carried offshore.

Structures* built into the Lake from the shore may alter littqral drift. The significance of this alteration depends upon the length, design and duration of the protrusion from shore. The presence of such a structure will trap some sand along its sides, as limited by the physical size of the structure. The littoral drift must flow around the protrusion, and the sand flow will be 3-1

• PALISADES SGR-EA

• effectively blocked only if the flow is diverted into deeper water beyond the littoral drift zone, as a result of the length of the structure or by offshore currents.

3.2 Bottom Sediment Analysis In October 1979, Lake Michigan bottom sediment samples were collected by diver from the proposed barge slip area at the Palisades Plant. Collections were taken at the shoreline and at 100 ft, 200 ft and 300 ft fro~ shore (see Figure 3-1). All samples appeared to be entirely clean sand with no visible contaminants or obvious odors. Samples were preserved and analyzed according to the methods established by the American Public Health Association (1) and

-the US Environmental Protection Agency (EPA) (5). Results of these analyses

• are given in Table 3-1. According to the EPA guideline for the Pollutional Classification of Great Lakes Harbor Sediments (4), the sampled sediment material has been found to be nonpolluted .

• 3-2

• I.

TABLE 3-1 SEDIMENT SAMPLE ANALYSIS PROPOSED BARGE SLIP AREA (mg/Kg)

Sam!!le Locations Parameter A(a) B (b) C (c) D (d) NonEolluted (e)

Volatile Solids Chemical Oxygen Demand Oil and Grease (Hexane Sol) 0.30 2,065 192 0.25 1,886 113 0.24 2,442 173 0.26 1, 777 131

< 5 40,000

< 1,000 e,

Total Phosphorus - P 41.6 40.8 51.0 33.0 < 420 Total Kjeldahl Nitrogen 27 34 47 58 < 1,000 Ammonia 1.6 1.5 1.5 1.5 < 75 ttj Cadmium < 0.14 < 0.14 < 0.14 < 0.14 (f) ~

H Cyanide < 0.018 < 0. 016 < 0.017 < 0.016 < 0.10 en Chromium 2.47 2.20 2.40 1.89 < 25 ~

w M I Barium 3.23 < 2. 75 < 3.01 2.89 < 20 en w

Copper 1.28 1.02 0.95 0.76 < 25 en G"l Iron 1,861 1,351 1,440 1,450 < 17,000

~

Lead 1. 15 1.19 1. 75 1.42 < 40 Manganese 28.2 24.2 25.8 24.4 < 300

~

Mercury 0.013 0.013 0.008 0.014 < 1 Nickel 1.98 1.66 1. 37 1.33 < 20 Zinc 5.84 5.33 5.80 4.35 < 90 Arsenic 0.37 0.24 0.32 0.39 < 3 PCB (g) (g) (g) (g) < 10

'9 (a) Shoreline.

(b) 100 ft offshore.

(c) 200 ft offshore.

(d) 300 ft offshore.

(e) Great Lakes Harbor Sediment Classification (EPA 1977).

(f) Limits not established.

(g) No detectable amounts (< 0.06 mg/Kg).

• J,~n I

. GENERAL NOTES

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§ ~ ~ STEAM GENERATOR REPLACEMENT

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• 4

4. 1 ALTERNATIVES TO THE PROPOSED ACTION No Action The barge slip is the preferred means of delivering the replacement steam generators to the site. Presently, .the date for the outage to repair the steam generators cannot be predicted with a reasonable degree of.certainty.

However, the length of the outage and the associated cost of replacement power during the outage are of paramount importance. Those measures that serve to minimize the length of the outage also serve to minimize the total cost of steam generator repair proj~ct. Therefore, not having the replacement steam generators available at the site in advance of the outage would be the penalty to be paid for the additional replacement power required while the Plant is

• idle awaiting delivery of th~ replacement steam generators.

risk is unavoidable during the period that the replacement Although such gen~rators are being manufactured, such risk essentially can be eliminated if the replacement generators are delivered to the s.ite immediately following completion of fabrication. The shipping season on Lake Michigan generally precludes barge shipment between mid-October and mid-April. If it becomes necessary to commence steam generator repairs after the shipping season is closed and the replacement steam generators are not in storage at the site, there is the potential to add in excess ~f $50 million in replacement power to the cost of the outage. This estimate assumes that the barge slip would be constructed and the units delivered to the Plant at the earliest opportunity, once Lake shipping could be resumed .

• 4-1

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• 4.2 Onsite Assembly Onsite assembly of the steam generators is not a viable option due to the need for special facilities to assemble such equipment.

Even though planning would limit the scope of onsitl:! work, the assembly of the steam generators requires a massive facility with specialized equipment:

Large cranes, lifting devices, machining capability, extensive testing equipment and welding systems similar to those currently employed in the equipment's manufacture would be needed.

Additionally, the steam generators currently under fabrication would ~equire disassembly, as the shells (outer boundary) of the steam generators have been

• assembled .

4.3 Truck Transport Large transport vehicles have been used to haul complete steam generators, and this option was investigated assuming the availability of such vehicles for Palisades. This approach is completely impractical for the total trip from Chattanooga, Tennessee to the Plant site due to the size and weight of the loaded vehicle.

To address the practicality of short-range trucking, barge unloading in the existing harbors at South Haven and St Joseph was considered. At either harbor, an unloading facility would have to be constructed, as neither harbor is prepared to receive such heavy equipment. Specialized lifting*equipment would be needed to place each steam generator on the transport vehicle .

• • Presuming issuance of proper permits from the local agencies, the load would 4-2

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-\**.

proceed through city streets to the Blue Star Highway. Special supporting measures would be taken at bridges, underground pipes and ducts. Throughout the trip, residents would be inconvenienced because the movement requires an extremely slow speed, the removal of essentially all overhead wires, obstructions and branches, and the utilization of two lanes of roadway by the special 200-foot long "truck."

Based upon contacts with highway departments, Consumers Power believes that it is highly improbable that permits would be issued for highway use, because the expected loads present weight and dimensional requirements which are far in excess of those previously considered. During the construction of the Palisades Plant, highway departments urged Consumers Power to utilize the

• waterways for the delivery of heavy equipment.

Additionally, a cost estimate shows that transportation costs associated with this approach, about $500,000, would significantly add to the cost of delivering the steam generators.

4.4 Rail Transport The option of utilizing the railroads to deliver the assembled steam generators was investigated, considering shipment directly to the Palisades Plant from Chattanooga, Tennessee or from a barge offloading facility in either St Joseph/Benton Harbor or South Haven.

The Chessie system, the railroad company operating the rails in the area, informed Consumers Power that such a movement is a "physical impossibility,"

• 4-3

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• due to the unavailability of rail equipment that could accommodate a steam generator and to obstructions along the route .

• 4-4

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• 5 DESCRIPTION OF THE PROPOSED ACTION 5.1 Need for the Project During the 7-year operation of the Palisades Plant, the steam generators have been afflicted by a number of corrosion related phenomena. Consequently, a substantial portion of the extra heat transfer capacity of the steam generators has. been removed as. a result of plugging affected tubes. Major progress has been made toward arresting or retarding the various corrosion mechanisms through changes in Plant equipment, secondary chemistry and operating procedures. However, steam generator tube denting (local constrictions of tubes) remains an unresolved issue and threatens to result in additional steam generator probl~ms .

With the uncertainty that. exists with regard to future plugging requirements and the expected useful lives of the existing steam generators, Consumers Power Company has evaluated practical major repair alternatives that are available to restore the steam generators to their original condition and regain the initial heat transfer capability. Complete replacement of the steam generators is the preferred method of repair.

Recognizing the length of the procurement lead times associated with obtaining components for the steam generator repair project, Consumers. Power Company has embarked upon a contingency planning effort designed to mitigate possible adverse consequences of continued tube corrosion. To conduct this repair, the major elements of this contingency plan include: procurement of replacement steam generators and other long lead time' materials, preparation of engineering studies and detailed engineering necessary to support the 5-1

PALISADES SGR-EA

• construction aspects of repair; preparation of work plans associated with repair activities; and, preparation of applications for permits needed from various regulatory agencies.

Work proceeds on all elements of this plan and although Nuclear Regulatory Commission (NRC) approval of the repair program will be required prior to the commencement of the actual repair work, it is reasonable to expect that the replacement generators will be finished and ready for shipment to the site before replacement is necessary. NRC approval by June 1979 was requested.

A Consumers Power Company Application for a Permit under the Great Lakes Submerged Lands Act, Act 247, PA 1955, as amended, and Section 10, Navigable Waters, US Rivers and Harbors Act of 1899, was transmitted to the Michigan Department of Natural Resources (MDNR) and the US Army Corps of Engineers (COE) on,January 10, 1979 (joint application) for installation of the barge slip. This Permit is a long lead time item which is needed to finalize planning, to have the barge slip approved before work starts, and to minimize the outage time and costs if it is necessary to replace.the steam generators.

5.2 Purpose of the Project The project for which Application for an Act 247 Permit was submitted is the construction of a temporary barge slip in Lake Michigan to deliver two replacement steam generators to Consumers Power's Palisades Plant.

Application has also been made to the NRC for.approval of a program to replace the steam generators when and if such a repair is necessary. The details of

• 5-2

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• the proposed repair program were presented to the NRC in January 1979 in a document entitled "Palisades Plant Steam Generator Repair Report."(2)

It is planned that replacement generators will be shipped by barge and unloaded at a temporary barge slip at the Plant site (see Figure 5-1). It should be noted that the proposed barge facility has been designed to accommodate the largest barge considered and the facility may be smaller if a smaller barge is utilized. However, Interstate Commerce Commission regulations prohibit the contracting of a barge more than 40 days in advance of its use, so the barge facility must be designed at this time to accommodate the larger barge.

A portion of the reactor containment building will be detensioned and a construction opening cut in the containment to allow access of ~en, components and materials. The old steam generators will be cut free from connecting

.piping, rigged vertically from their cavities, lowered to a horizontal position, and removed through the construction opening in the containment*.

The installation will then follow in reverse order using the replacement generators (see Figures 5-2 and 5-3).

The "Repair Report" included an assessment of alternatives for disposal of the old steam generators. (Sections 4.4 and 9.3 from that report are included as Appendix A to this Environmental Assessment.) In addition to possible site storage in a suitably shielded facility, consideration was given to offsite disposal methods; with shipment from the site by means of either rail, truck, or barge. Offsite disposal with shipment from the Palisades Plant via barge

• 5-3

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• is the most desirable method of disposal from both an economic and an occupational dose standpoint.

No date has been established for commencing the repair proje~t, and availability of offsite disposal facilities at the time of the repair is uncertain. Therefore, it is prematur~ at this time to include shipment of the old steam generators from the site as a definite use for which the Application for an Act 247 permit is submitted. If the repair project schedule and availability of offsite disposal facilities are compatible with receipt of the replacement generators, tnen Consumers Power Company may ask for an extension of the Act 247 Permit for shipment of the old steam generators.

However, a real and urgent need exists to have suitable facilities available

• at the site for the receipt of the replacement generators, and the approval of the proposed barge slip is sought now. The replacemen~ generators are being assembled on schedule at a vendor shop and are expected to be ready for shipment to the Plant site by August 1981.

5.3 Schedule The following .schedule milestones must be met in order to permit barge delivery of the replacement steam generators to the Palisades Plant site in August 1981:

a. Complete Soil Investigation and Test Piles, December 1979

b. Complete Design of Barge Slip, June 1980

• c. Award Sheet Piling Contract, December 1980 5-4

PALISADES SGR-EA i .

d. Deliver Sheet Piling, March 1981

e. Drive Sheet Piling, Start April 1981, Finish July 1981

f. Dredge Channel, July 1981 Federal *(COE) and State (MDNR) approval of the Application for an Act 247 Permit for the repair project is sought by January 1980 (one year after Application date) to avoid an adverse impact on this schedule.

The offshore sheet piling 'or sunken ship hulls that may be required temporarily (approximately eight months) in the Lake will be removed as soon as practicable after operations are completed. The decision on the ultimate disposition of the onshore facilities above the Ordinary High-Water Level of the Lake has not been finalized; however, their removal will be at Consumers Power's option.

5-5

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FIGURE 5-3 ENVIRONMENTAL ASSESSMENT

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PALISADES SGR-EA 6 IMPACTS 6.1 Primary Impacts The primary impacts are those impacts associated with the temporary barge facility. This facility is discussed in Section 5 and shown in Figure 5-1.

The impacts are categorized as construction impacts, dredge disposal impacts, shoreline impacts, and visual impacts.

The construction impacts would be those temporary impacts of construction, and are addressed in Appendix A, Sections 7.0 through 7.6.3. Within that Appendix, Section 7.2.3 discusses the effects on water resources. Other construction impacts, including noise and dust, are* discussed in Section 7. 4

• • of that Appendix.

Because the dredged material was shown to be nonpollut~d (see Section 3.2),

the relocation of this material will not have a significant impact. The offshore dredge material would be distributed on the sides of the dredge channel. The onshore excavated material would also be placed on the sides of the work area and remain onshore. Material from either source may be transported to a disposal area on site if they interfere with construction activities, or if it is found to be polluted at the time of dredging. Natural wave action will return the Lake bottom to its original contour; the disposition of the onshore sand piles will be* determined at a later date.

The shoreline concerns are: (a) restricted access, and (b) erosion. The temporary offshore i~stallation, due to its physical limits, will preempt

• approximately 0.6 acre of the Lake surface and bottom.

6-1 This portion of Lake

PALISADES SGR-EA .

• Michigan would be preempted from public recreational and fishing use, but the impact is minimal because of its small size relative to similar water of the Lake. The offshore portions would pose a temporary obstacle to boats, and appropriate markers and/or lights will be installed. The onshore sheet piling will extend about 100 feet along the shore, making that section unsuitable for beaching small water craft. This area, however, is not generally used for such activities. Access to the beach by walkers is already hampered by natural and other Plant interferences.

As described in Section 3.1, protrusions into the Lake may alter the littoral drift and, thereby, aggravate beach erosion. However, because this facility extends only about 240 feet into the Lake, the flow of the sand near the shore will be deflected into the Lake, but will remain close enough to shore to be carried to nearby beaches by wave action. This flow pattern would also occur during storms, when major shore erosion would be most likely; Most important, the offshore facilities will be present for only a brief period and removed promptly upon completion of equipment delivery. Therefore, the contribution of the barge facility to shore erosion from natural effects is expected to be minimal.

The barge facility will be visible to the public from the Lake, beach, and air. It will appear like portions of other marine facilities in harbors or pleasure boat maiinas. The offshore installations will be removed after use, leaving only the onshore barge slip which will be inobtrusive because of its size relative to the Palisades Plant .

• 6-2

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'\ '

6.2 Secondary Impacts 6.2.1 Physical Impacts The construction activities associated with the steam generator replacement are similar to those of any heavy construction work, but with the addition of radiological considerations. Radiological impacts are within the scope of the jurisdiction of the U.S. Nuclear Regulatory Commission.

This topic was addressed in the Steam.Generator Repair Report (2) and portions of that report are included here as Appendix A. Sections 4.4 and 9.3 of Appendix A discuss the disposition and the impacts of steam generator storage.

Sections 4.37 and 6.2.2 of the Appendix address radiological aspects while Section 7.0 considers other environmental aspects of the repair program. Only references within those sections that are relevant to the topic are included in the Appendix.

6.2.2 Economic Impacts of Plant Shutdown The replacement of the Palisades steam generators requires that the Plant be shut down for some period of time (expected to range from one to two years).

During that time, the generation deficit caused by the loss of the Palisades Plant from the electrical system will be made up at other Consilmers Power Company generating facilities or from external sources. If system reserves are adequate and replacement power is available within the Consumers Power Company system, such power is estimated to cost from 8 to 10 million dollars more per month to produce than if it were generated at Palisades. (Estimated

• costs are based on an outage which might occur in the early 1980s.)

6-3 The

PALISADES SGR-EA

• estimated cost of the steam generator replacement project, exclusive of replacement power, is 80 million dollars. This estimate is also based on the repair outage occurring in the early 1980s.

The impact upon rate payers will depend upon treatment by the Michigan Public Service Commission. It should be noted, however, that to minimize the economic impact of the steam generator repair program, Consumers Power Company has proceeded on the contingency plan described in Section 5.1. The success of that plan and the ability to minimize the cost of the repair will, to a large extent, depend upon the ability to obtain the necessary governmental permits and approvals on a timely basis .

• 6-4

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• 7 UNAVOIDABLE ADVERSE IMPACTS The impacts discussed in Section 6 must be incurred to accomplish the repair of the Palisades steam generators in a practical manner. Unnecessary impacts have been eliminated by controlling the scope of activities.

The impacts discussed in Section 6 are tabulated below:

- Construction Impacts of Barge Slip and Replacement Effort

- Dredge Disposal Impacts

- Shoreline Access Limitations

- Shoreline Erosion

- Visual Impacts

- Radioactive Releases

• - Radiation Exposure of Workers

- Resource Commitments These impacts, however, are minor in that they do not significantly alter any ecological system or massively disrupt natural settings. With the exception of some onshore structures which will not be removed, the impacts of the steam generator repair effort will be temporary .

• 7-1

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• 8 PROPOSED MITIGATION With specific regard to the proposed barge slip, several items h~ve been identified tha.t warrant continued appraisal and may result in the need for mitigative action to reduce adverse environmental impacts. These are identified separately below. In addition, construction activity will be controlled to mitigate, to the extent feasible, impacts associa.ted with noise, dust, aesthetic intrusions and related activities that may be cause for local complaint.

A program of shoreline monitoring will be in effect during the period when offsh.o+e facilities may affect littoral drift, although the Company believes the project will have no significant impact on littoral drift. Visual inspection procedures, as well as land-based photography, will form the basis for identifying erosion patterns. Upon identification of adverse effects, if any, quantitative estimates of material displacement would be developed and a program of corrective beach nourishment would be implemented after concurrence by the appropriate agencies and property owners.

Representative samples of dredged material will be obtained to ensure that the material is disposed of in accordance with regulations which limit chemical constituents and particle size characteristics. Mitigative action may be necessary should the tests indicate an unexpected variance from anticipated characteristics. The Michigan Department of Natural Resources will be notified immediately if any significant variance is found .

• 8-1

PALISADES SGR-EA 9 UNRESOLVED CONTROVERSIES It is hoped that the information contained herein will resolve any controversies with individuals and groups who have filed objections to the proposed actions. The primary interest of most objectors is in connection with shoreline erosion, which has been recognized, but should not be significantly affected by this activity.

Some uncertainty remains with respect to the need for and extent of mitigative activity, as identified in Section 8, and with regard to the schedule of various activities. Necessary adjustments in either of these categories are not expected to significantly affect the nature and extent of environmental impacts .

• 9-1

PALISADES SGR-EA

• 10 1.

REFERENCES American Public Health Association, Standards Methods for the Examination of Water and Waste Water, 14th Edition, APHA. Washington, DC, 1975.

2. Consumers Power Company (Compiler), Palisades Plant Steam Generator Repair Report (as revised) (January 3, 1979), Consumers Power Company.

3. Tillinghast, John, (Senior Executive Vice President, American Electric Power Service Corp.), statement before the US Corps of Engineers at a Hearing in Bridgman, Michigan, April 19, 1973.

4. US Environmental Protection Agency, Guidelines for the Pollutional Classification of Great Lakes Harbor Sediments (1977), USEPA Region V.

Chicago, Illinois.

S. US Environmental Protection Agency, Methods for Chemical Analysis of Water and Waste (1979), Environmental Monitoring and Support Labqratory, Office of Research and Development, USEPA. Cincinnati, Ohio .

\

• 10-1

PALISADES SGR-EA APPENDIX A Excerpts From Palisades Steam Generator Repair Report

• Se.ct ion 4.3.7 Man-Rem Assessment 4.4 Disposition of Old Steam Generators 6.2.2 Offsite Radioactive Releases and Dose,Assessment 7.0 Environmental Aspects of the Repair Program 9.3 Steam Generator Storage and Disposal

\...

4.3.7 4.3.7.1 MAN-REM ASSESSMENT PALISADES PLANT SGRR Man-Rem Assessment for Continuing Operation Assuming that the replacement steam generator tubes maintain their integrity during the remaining operating lifetime of the plant, radiation exposure attributed to steam generator work will be reduced. It is not expected to exceed 25 to 50 man-rem per year for a tube inspection operation in accordance with Regulatory Guide 1.83. It has been estimated that approximately 250 man-rem could be saved each year following the steam generator repair.

4.3.7.2 Man-Rem Assessment* for the Repair Effort Health physics survey data have been reviewed for the period from November 1976 through March 1978 at various times after shutdown to determine trends in dose rates and radionuclide contributors that affect operations in the vicinity of the steam generators. (Typical survey results and data are shown in Figures 4.3-3 through 4.3-5.) It is believed that this plant survey data is representative of conditions expected at the. start of the repair activity, provided that appropriate dose rate increases due to activity buildup within the steam generators are considered (Reference 3).

Survey data in the vicinity of the steam generators and primary coolant piping were averaged and used to project general field and dose rate estimates at various times after shutdown (see Figures 4.3-6 and 4.3-7). The man-rem assessment for the repair effort is shown in Table 4.3-2.x 4.3.7.2.1 Radiation Field Uncertainties

a. Radiation fields were taken from actual Palisades Plant surveys and adjusted for activity increase as a function of time before steam generator removal.

In developing the man-rem predictions, it was assumed that the radiation fields would not decay throughout the repair effort. Actual radiation fields will decrease with time. Therefore, the actual total job man-rem are expected to be lower than the calculated values.

b. The effectiveness of temporary shielding or local decontamination will be further defined as dose rate survey data and primary system samples are gathered during future outages. Reduction factors as now estimated are indicated in Table 4.3-2.*

• This table has be.en revised and is now labeled Table C-1-5

• 4-31

PALISADES PLANT SGRR 4.3.7.2.2 Assumptions Used to Estimate Manhours by Area for Dose Calculations

a. Nonwelding Operations in Radiation Area

l. 50% of manhours in radiation area

2. 30% of manhours checking in and out through Health Physics and Security

3. 20% of manhours in lower radiation area of containment

b. Welding Operations in Radiation Area Welding operations in the radiation area are based on rotating welder and helper between work area and lower radiation area, .as work operations dictate, to minimize welders' exposure.

l. 35% of manhours in radiation area

2. 30% of manhours checking in and out through Health Physics and Security c.

3. 35% of manhours in lower radiation area of containment Outside Work All manhours are outside of the containment.

d. Welding of Primary Coolant Pipe The following is based on ro~ating welder and welder's helper between work area and lower radiation area as work operations dictate to minimize welders' exposure.

4-32

• l.

PALISADES PLANT SGRR 35% of manhours at primary coolant pipe broken down as follows:

outside pipe 35% X 68% = 24%

Inside pipe* 35% X 32% = 11%

Total in place = 35%

i1rrnside pipe manhours required to grind and clad inside of primary coolant pipe by conventional manual methods

2. 35% of manhours in low radiati~p area of containment

3. 30% of manhours checking in and out through Health Physics and Security

e. Stress Relieving of Primary Coolant Pipe

1. 10% of manhours inside pipe

2. 30% of manhours within 6 feet of pipe 3* 30% of manhours in lower radiation area of containment

4. 30% of manhours checking in and out through Health Physics and Security

f. X-Ray and NDT of Primary Coolant Pipe A total of 2,600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> is allowed to x-ray the primary coolant pipe. This is based on 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> availability per day for x-raying inside containment.

1. 37% of manhours checking in and out through Health Physics and security,

2. 20% of manhours inside of pipe

3. 30% of manhours within 6 feet of outside pipe

4. 13% of manhours in lower radiation.area of containment

• 4-33

PALISADES PLANT SGRR

g. Approximately 780 additional hours of time for x-ray technicians are included to x-ray*the main steam and feedwater lines.

h. Rigging

1. The following work operations were considered to be outside of the power plant building but inside of the security fence:

(a) Set up equipment to handle the new steam generators from the barge slip to the containment *

(b) Set up equipment external to the containment to handle the new and existing steam generators (c) Offload, move to storage, and later transport steam generators to containment (d) Remove all external rigging equipment from the site (e)

• Decontaminate and remove all internal rigging from the site (f) 21% of manhours allowed to install new steam generators

2. The following work operations *were considered to be at the containment operating floor level or higher:

(a) . Install rigging equipment inside containment (b) Decontaminate and remove rigging equipment from inside of containment (c) 60% of the manhours allowed to install new steam generators

3. Seventy percent of the manhours associated

• with 2. above were considered to be at the operating floor while 30% were required for checking in and out through Health Physics and Security.

4-34

• 4.

PALISADES PLANT SGRR Forty-nine percent of the manhours associated with removing the existing steam generators from the containment were considered to be within 6 feet of the primary coolant pipe or bottom of the steam generator, 21% were required to check in and out through Health Physics and Security, and 30% were next to the existing steam generators outside of the containment. *

5. Th~ manhours associated with moving the existing steam generators to storage were considered to be adjacent to the existing steam generators but outside of the containment.

i. An assumption was made that 50% of the manhours required to cut the primary coolant pipe would be spent within 6 feet of the outside of the primary coolant pipe or bottom of the steam generators, with partial exposure to the inside of the primary coolant pipe before the steam generator removal.

Thirty percent of the remainder would be spent

• j.

checking in and out through Health Physics and Security, and 20% would be spent in an area of low radiation.

It was also assumed that 50% of the manhours required to level, line up, and tack the primary coolant pipe would be spent within 6 feet of the outside of the primary coolant pipe, with partial exposure to the inside of the primary coolant pipe after steam generator removal. Thirty percent of

.the remainder would be spent checking in and out through Health Physics and Security, and 20% would be spent in an area of low radiation.

k. The manhours associated with miscellaneous piping operations were spread in accordance with the piping hours spent in each area.

1. Distributables 1 .. Welder tests and miscellaneous services were considered to be outside the plant buildings but inside the security fence.

4-35

PALISADES PLANT SGRR

2. Startup, cleanup, and scaffolding distributables were prorated on the basis of total manual manhours at each location, excluding the outside work.

m. Nonr.:anual Labor The following assumptions were made on the nonmanual labor manhours:

1. All inanhours, except for superintendents

• and engineers, would be expended outside plant buildings but inside the plant* security fence (office work).

2. Fifty percent of the superintendents' and engineers' manhours for piping, el,ectrical, civil, rigging, and safety would be outside the plant building but inside the security fence (office work).

3. The remaining 50% of the superintendents' and engineers' manhours were prorated to each of the work areas based on the total manual hours spent in each area by discipline. For instance,

. the piping superintendents' and ~ .

engineers' manhours were prorated on the basis of the total of manual hours spent in performing the piping operations in each area.

4.3.7.2.3 Technique for Estimating Radiation Dose The total dose is dependent on the following factors:

a. Dose rates (rem/hr) before shielding or decontamination

b. Shielding or decontamination effectiveness

c. Duration of tasks (hours)

d. Manhours required to complete tasks

e. Fraction of time the task is in radiation field of interest The entire repair program.has been divided into discrete areas. The total personnel exposure in an area is the 4-36

• PALISADES PLANT SGRR product of the dose rate and the manhours required to complete all tasks involved. The total exposure for the.

entire*job is a summation of the exposure for all areas.

Therefore:

Ei = Di (rem/hr) x Mi (manhours)

E = L Ei (man-rem) where:

Ei = Total personnel exposure for area i (man-rem)

Di = Average dose rate in area i (rem/hr)

Mi = Manhours to complete all tasks in area i (manhour)

E = Total personnel exposure for all areas (man-rem) 4.3.7.2.4 Confirmation of Man-Rem Estimate Daily radiation dose logs will be maintained for each worker stationed within the higher dose rate (~10 mrem/hr) areas of the containment. Weekly, monthly, or quarterly records will be maintained for those working outside the containment and in other specially designated low dose rate areas. These actual doses will be tabulated by task category for

• confirmation of estimated doses provided in this report .

• 4-37

l'Al.l:iAlll:::; l'l.Alff Sl:RR

• rAUl.t: t:-1-5.

(:;11u:1* I)

HAN -Hf.ti t:STltlATE (l)

(I) t:nt: ln111teJ HnnhourR In ll*1ollntlnn flelJ Arcn flim-llPm lloee AveruK" RaJlalton FlelJ (tla111111l Welding) (Hadilne Wt*l*ll111t) (Han *R*'tfl)

Wnrk Arcu (l.m*m 11111) (re~/hr)

• • • • -*--~*--*- *----*-**-.-~I _____

(Hnnual Weldl1111) (tiadllue Wel1lln11)

I. OuL1:1lcle of 11uwcr 1dant l*nll1llni; hut within occur I l y ( *~ucc.

2. Cl1twk Int; tn n11cl out Lhruugh tu~cur I ty anti

.':i II 10

-':i 217659 217619 1.1 I. I e

health 1*hylikli 1111 wdl uo Lime spent HniLln~

111>, c I t!**n I nu 111* and 1uovl11" to and rnuu w1u-k nreat1 tor 11crau11nt_*l Mork Ing In rihl lu;u:t lvt~

urcu:i. .0025 ':i114l 52018 110.J 1111

). lnsltlt! c*nnlalnlAl!nl nt*ar new conttlnu.:t lou npcnlnn. .OOI "1'14 l~ll. ).5 1.5

4. lllthlll b 1 O{ OtlllilJl! or Ct!nt:tor cool.1nl pl11c or l1ottntA of Hlcam gt.*nt~n*tur 1*r lor l u f(:Uluva I o( stcma KCncrntors. .010 - .050 6276 64115 188.J - lll.R 19").} - 122.l

5. Within 6' uni ul1lc of rt*a1:lor t*nnlnnl 1d1u.* uftt~r Ult*;un gc11cra1 n1* *ti r**ruuva I.

f1. Within f,' uf uulul1l1! of' reactor

..:oolnnl 1d1w ur huttmu of Htc11m ~~ncr~ttorH wllla 1*11rtl;1I

.OIO - .030 19618 121 Jl 196.8 - ':i'JO. l 121

• l - 1r,4 . o e

cx110Hure to I 118 I clc* ot' 1*c1u*1.ur conlnnt pipe l'r lur to 1:1temo .,;c1!c~ratnr'H l"t*moval. .oso - o. 100 507 Sil/ 2'>.4 - so .., 15.4 - 50. 7

1. Within 6' of uni slJl! of 1*.,actnr 1:uolant plfll~ with 11a1*1.1al CX(HJllllCC tu luRl4IC! u( r'-:u:lor cuolmtl ttlpc aftt~f" HC:l*aw 1

W!ll(~fitlUl" A a*cUHtVOl I. .oso - . 100 '>658 C11'>':i 281 - 4':il1.R "111.H - 615.5

• l'Al.ISAllF.S Pl.Alff SGRll TAlll.t: C-1-~

(SllEt:*r l)

HAH*-llt:tl t~'il'IHA1'E (l)

(1) t:nt lmateJ tlanhoura In ll1111l11t Ion Field Area Hnn-R"ia llo"e Avernge Rn11lot Ion Fie Id (tlanunl lleldlng) (tlad1lue Wlll11lng) (Han-11.,m)

\lurk Arca (l**.:nL lnu) (rc111/hr) Al (Hanuel Welding) (H111:hlne lll!ldlng)

---

*----- --- .. -".L __ _

8. a) lnei.te of reuclor cuolnnt pipe hefo~e dt!<:onl111alnat Ion. 4.) 4.2 ~1.6 17.8 - S0.4 9.0 - 12.0 18. 7 -

11) Outel1le of pipe w/p11rl lnl exposure lnslilo hcrure 1tccontm11lnnl Ion. 1.0 - 2.0 1)6 1'14 1)6 - 212 .o ll4 - 2"8.0

,:) lneldc uf r~a**tnr cnnlnnt pip~ ttflcr ***~t.:untmnluatlun. .0)5 148 ISO 5.2 ~-l 4*. l*>W ra1ll11Ll1111 orcn within conlatnllN!nt .005 :1*1198 116010 ~

l96 2"\0.2

• I

10. llllhlu 6 1 u( tn1* half of oftclnal sl~am g*~nt.-ralurs (lnelallcd ln pl111*c). .oos 2J65 2150 ll .8 11.R 1

II. lllrhlu 6 o( 1up hnU of ncv Rt<!aia generator" ( lnRI 11 I lt!d In place). .OOI 11211 1120 II. 2 11. 1

12. 01,ernl Ing f 1001* ur cuula lnmt:nt. .OOS - .OIO ')1161 'J'}Ofo 0.1 - 't8.1 4'1.5 - 99.0 I). lnsldt! cnntalnmL!nt, 11t polar t:rune t'!.lt!VAl luu. .001 '11161 "111(,1, ).9 1.'J

14. Auitlllory hull*llnK """r clenn rt!Hln tnnk nml cool.Int; wutcr lunk. .001 729 729 0.7 0.1 e

15. Auxll lary hull1llug near l>luwduwn ti111k. .001 fi/1011 M42 6.4 6.4

16. S11ent fud l""'I floor. .oos llll2 lllll l4.2 14.2 1

11. llllhln 6 of the hot111an half of new a1 ... ~mD u*:n.-~ruto.-s (In ll l."lce). .Oto - .010 lolllf1 lolOf* 4l. I - 11'1.l 41.1 - 121.2

l'Al.ISAllES l'l.Atl'r SGRR

'l'Alll.K c:-1-';.*

. (lillf.lo:'I' 1) tlAN**llfll l*:S-l'IHA'l'E (1)

(I) t:Ht* lau1tcJ Hllnhours In R:11ll11rlo11 Field An"' H1111**ll**m lk*Rt*

Averngc ll;ull11t Ion t"lc Id Ot;inual Welding) (H11dil1lt! WelJlng) (11:111-11 .... )

(nm/hr) <Hnnuol Weldlnit) Olad1lne Welding)

"1 ______ "1 *---*--

18. Within ,, ' .. r lhe 011tsl.1lt* of the rt!aC.tnr VCllS<'I. .100 40 1,11 4.0 4.0

19. tfoxr to 1.l1c t*i<l>1t Ing gt.*ne:ruloru Olll!ildc uf talnnu~nt tltl~iJID r.un-

.020 - .0'10 1117 1111 14.7 - ';2.1 'llo.1 - 52. I

20. lnslz1l Int Ion o;hlo*l*llng :uul leu.:a*t "'

1h~1:unl:mul11nl Inn. (l) (l) (1) 1547 - 2Rll7.6 15H - 2'162. 'I Non::

(I) llt,.1111'.1 lun* fal'tOl'IJ altrllmtcd to shielding aml/or tlec:n11tm*l11111 lo1i hnve bl*en llu*urpural*"I lnlu 11,.,,.,. fkl1I estlmntes a111I will not he 1*rcH<'lllcd here ns a t1c1u1rulc t*ulman.

(2) t"nrthm* n**ln<:l lun In llrt*n mnn-rem 1luse co11l1I occur "" work l'""k"ll"B ond Al.AllA uL111l lc~ l.'nnt hnw. Tiil! cttl I mutes n.-~ hosed 011 cuns,~rvnl lvt? nRtuuupt lune.

(')) 'l'lw n1anhnur *!t1th1alctj fur ploccsuent of ehl1?ltllnM 111111 ltwn1 dH*'ontomluntlon arc l*!Ulatlve thw tu 1111* continuation or Al.AllA analyttlR an'I wo1*k pn1;kut;t!

1ll?Vt!lu1*ntt?nt. "l'lt*.* 1111htln*rH 1*r1*tu!nt1"1I here nru an eu1* lm.1lt.* au1I l'Hprcseut a pt!C't:a.!nt ;11:1: or t lu! tut;d m:an-rcm *

• PALISADES PLANT SGRR

\.

. 4.4 DISPOSITION OF OLD STEAM GENERATORS The disposal effort is ~ndependent of the repair and is evaluated on that basis. Because of the uncertainty of the timing of the repair and the availability of the offsite disposal facilities, the ultimate disposition of the old units cannot be finalized at this time; however, a variety of disposition alternatives has been investigated.

The steam generators to be removed represent the single largest source of solid radioactive waste to be disposed of during the repair effort. The primary side internal surfaces of the steam generators are contaminated by a tenacious film of deposited radioactive corrosion products made up primarily of cobalt; manganese, and iron isotopes.

Isotopic analyses obtained from uncleaned 2-inch long sections of steam generator tubing indicate that at the time the steam generators are removed, each will contain approximately 30 curies of deposited gamma activity (see Table 4.4.l and References 2 and 3). The activity will decrease to approximately 2.8 curies per steam generator 2 years after shutdown, then continue to decay with the 5.6 year half-life of Cobalt-60.

4-37

PALISADES PLANT SGRR 4.4.1 OBJECTIVES OF HANDLING/DISPOSAL OPERATIONS /.J The objectives of handling/disposal operations are as follows:

• a. To dispose of the steam generators safely and economically *

b. To provide the means to handle/dispose of the steam generators so that radiation exposures to plant and contract personnel are as low as is reasonably achievable

c. To minimize the release*of radioactivity to the environment so as to keep radiation exposure to the public as low as is reasonably.achievable and within the limitations of 10 CFR 20

/

4.4.2 ONSITE STORAGE If it is decided thatthe old steam generators will be stored onsite, a storage facility will be necessary (see Section 4.1.1.2.2).

Before removal from the containment, the openings in the steam generato:rs will be sealed to prevent the release of radioactivity during transfer and subsequent onsite storage (see Section 4.3.5.2). Sealing will be performed by welding plates of steel over each pipe opening. The steel plates will be thick enough or supplemented by lead shielding, if required, so that external dose rates at th,e sealed op_ening are not higher than adjacent surface areas.

The only significant radiological consideration associated with* storage is the direct radiation from the steam generators (see Section *4.4.6). Shielding will be provided to ensure acceptable radiation levels external to the storage facility. Section 4.4.7 demonstrates that there are no credible accident considerations associated with onsite storage of the sealed steam generators that result in the release of radioactivity from the steam generators.

4-38

• PALISADES PLANT SGRR Based on the above considerations, the required storage facility design criteria are:

a. Appropriate shielding for direct dose

b. Access for periodic surveillance of steam generator seal integrity using portable monitors

c. Environmental protection in a weathertight and restricted-entry shelter 4.4.3 OFFSITE DISPOSAL The following three method.s were investigated as alternative means of shipping the removed steam generators to a*licepsed land burial site:

a. Shipment by barge in one piece

b. Shipment by truck cut up

c. Shipment by rail cut up 4.4.3.l Preparation for Shipment by Barge .

Barge shipment of the old steam generators is determined to be the most acceptable method from both environmental and occupational dose standpoints provided that routing and handling capabilities remain available at the time of shipment. The steam generators will be sealed before removal from the containment so that the radioactivity will be contained within a strong, tight package as required by 49 CFR 173. When the steam generators are to be shipped"to a licensed land burial site, each one will be transported to.

the barge facility intact and shipped as low specific activity (LSA) material in ~ccordance with applicable state and federal regulations.

4.4.3.2 Preparation for Shipment by Rail and/or Truck In preparation for shipment of the steam generators by rail or truck to a licensed land burial site, the generators would be cut into sections suitably sized for shipment. The cutup sections would then be packaged in strong, tight packages and shipped with appropriate shielding in accordance with applicable state and federal regulations.

• 4-39

PALISADES PLANT SGRR Cutting operations on the steam generators would be performed in enclosure envelopes, as required, to minimize the spread of airborne radioactivity. The enclosure envelopes will be provided with a HEPA filtration system to reduce the potential release of radioactivity to the environment and will be designed to allow the ~se of remote

• cutting techniques to reduce personnel exposure to radiation during cutting. Temporary shielding will also be provided, as required, to further reduce personne.l radiation exposure.

Radiation detection and measurement during cutting operations will be in accordance with the Palisades Plant Health Physics Procedures.

4.4.3.3 . Shipment If shipped by truck, potential disposal sites would be Sheffield, Illinois; Morehead, Kentucky; Barnwell, South Carolina; Beatty, Nevada; and Richland, Washington if in service at the time. Further, if shipped by truck, 14-foot maximum width dimension limits.exist, and then only for escorted shipments. This width inGludes shielding and overpack material. Hence, the net width would be around 12 feet, with maximum length limited to about trailer length, or 38 feet, without special hauling permits.

Shipment by rail or barge limits disposal to Richland, Washington, as thfs is the only site with rail and ship offloading facilities.

For rail, the maximum width, including shielding and overpack, is 10 feet, producing an effective maximum net width of the cutup material of about 8 feet. These maximum dimensions apply for rail and truck shipments only if additional large shields are constructed and receive U.S.

Department of Transportat~on approval permits. Utilizing existing shielded casks, 'dimensions of the cutup material would be considerably smaller--on the order of 10 feet by 6 feet by 3 feet. If the steam generators were shipped by truck, with a net payload of 10,000 pounds per shipment, approximately 90 shipments would be required for each of the 450-ton steam generators.

Conceivably, a single shipment of both steam generators by barge can be made to Richland, Washington, through either the Illinois - Mississippi River - Panama Canal route or the St. Lawrence Seaway - Panama Canal route. The offloading facilities at Richland, Washington, can easily accommodate a single steam generator at 450 tons.

4-40

• PALISADES PLANT SGRR I

4.4.4 MAN-REM ASSESSMENTS If the steam generators are shipped by rail and/or truck, they must be cut into suitably-sized sections before shipment. The man-rem associated with this operation will vary depending on the length of time the steam generators are in storage before the actual cutting operation.

If barge transport is employed, cutting is not required and handling of the steam generators would be minimized. Based on radiation survey data and analogous manhour estimates established in Section 4.3.7, the man-rem associated with barge transport ( 1 to 5) is a small *fraction of' the man-rem associated with rail and/or truck shipments ( 575 to 750) *

(see Table 4.4.-2).

4.4.5 RADIOACTIVE RELEASES AND DOSE ASSESSMENT ASSOCIATED WITH OFFSITE DISPOSAL The openings in the steam generators will be sealed pefore the steam generator is removed from the containment building (see Section 4.3.5.2). Since the steam generators will be sealed during storage and eventual shipment by barge, no

• airborne or liquid radioactive releases are associated with offsite disposal.

4.4.6 RADIOACTIVE RELEASES AND DOSE ASSESSMENT ASSOCIATED WITH ONSITE STORAGE If onsite storage is necessary, a suitable storage facility would be constructed before the removal of the old steam generators (see Section 4~1.1.2). Since all openings in the steam generators will be sealed before removal from the containment, no airborne or liquid radioactive releases are expected as a result of onsite storage.

As discussed in Section 4.4.7, the radioactivity within* the steam generators is inunobile. Thus, if seal integrity was lost, releases to the environment would not be likely.

Nonetheless, a surveillance program will be implemented comprised of periodic visual inspection of the external surfaces of the lower assemblies, area radiation surveys, and random swipes of the welds sealing the covered openings in the lower assemblies. This surveillance program will provide further assurance that there are no unanticipated releases of radioactivity to the environment .

• 4-41

PALISADES PLANT SGRR The only contribution, therefore, to the annual dose equivalent to any member of the public is from direct radiation emanating from the storage facility. *The storage facility would be shielded, as required, in o~der to limit the dose rate at the outside of the storage facility to 1.0 mR/hr. The resulting dose equivalent to an individual at the NNE site boundary (@ 2,200 feet) for a full year would be approximately 1. 9 x io*3 mrem, which is considered an insignificant contribution to the offsite dose.

Furthermore, it is highly unlikely that an individual would be continuously exposed for a period of 1 year at the site boundary; therefore, the actual annual dose equivalent to any individual at this location will be lower than that given *above.

4.4.7 ACCIDENT CONSIDERATIONS ASSOCIATED WITH ONSITE STORAGE The primary concern associated with accidents involving the onsite storage of the old steam generator is the remote possibility for the release of radioactivity to the environment. The majority of this radioactivity is on the primary side surfaces of the lower assembly in the form of a protective corrosive film of metal oxides which is very adherent and refractory.

As ':discussed in Section 4. 4. 6, an additional measure of *.

radio~ctivity confinement will be attained by welding cover plates over all pipe connection openings in the old steam generators.

Radioactivity could conceivably be released to the environment only if both of the conditions below occurred:

a. Radioactivity is dislodged from the primary side

• surfaces.

b. The lower assembly primary side boundary is

. breeched.

There are three mechanisms which could potentially dislodge the corrosion film:

a. Thermal shock

b. Chemical/corrosive attack

c. Mechanical shock 4-42

• PALISADES PLANT SGRR The old steam generator storage facility would provide a weathertight environment and minimize temperature extremes so that dislodging of corrosion by thermal shock is considered unlikely. Because the steam generators will be drained and sealed against moisture, chemical and corrosive attack is not likely to occur. The possibility of mechanical. shock during storage is *not great since the storage building would be an engineered structure and not subjected to general use. Even if thermal or mechanical shock* is assumed, the tenacious nature of the corrosive film is such that it would not dislodge a significant amount of radioactivity.

In addition to the fact that it is.highly unlikely for a .

significant amount of radioactivity to be.come dislodged from a primary side internal surface, breeching the lower assembly primary side boundary is considered an extremely re~ote possibility because of the minimum steel thickness of approximately 4 inches. Based on the above, it is concluded that there are no realistic accident scenarios which would result in the release of radioactivity from the generators during the onsite storage interval.

4.

4.8 CONCLUSION

S

/

The steam generators will ultimately be disposed of in a licensed land burial site or decommissioned with the plant.

ALARA considerations,.economics, and burial site availability will be the factors determining the storage, handling, and shipping techniques employed.

• 4-43

PALISADES -PLANT SGRR TABLE 4.4-1 ACTIVATED CORROSION PRODUCTS AFTER SHUTDOWN ACTIVITY IN (CURIES x 10-6 )/(2 11 SAMPLE )111 121 Isoto:ee O da~s. 42 da~s 140 da:z::s 200 da~s 470 da:z::s Cr-51 5.85 2.06 0.807 0.04 0.0 Mn-54 1.33 1.23 1.00 0.86 0.47 Co-57 0.60 0.54 0.428 0.36 0.18 Co-58 341.10. 228.50 117.18 48.95 3.56 Fe-59 3.08 1. 70 0.733 0.14 o.o

.Co-60 6.16 6.06 5.85 5.73 5.18 Nb-95 0.31 0.14 0.0594" 0.01 o.o Zr-95 0.37 0.24 0.116 0.04 0.0 Total 358.8 240.47 126.24 56.13 9.39

\

Notes 111 The activities established are an approximation which assumes that the majority of the activity is concentrated in the tubesheet.

121 The following technique was used to find approximate activity per steam generator at the time of removal c-200 days):

3.5 x 10 5 inches of tube/tube sheet (3.5 x 10 5 inches of tube)(56.13 x 10~ Ci/2 inches of tube) = 9.82 curries/steam genrator at 200 days This should increase by a factor of 2-3 for additional operation of from 3 to 5 effective full power year (Reference 3).

Therefore: ( 9. 82 curies) x 3 :::::. 29. 5 Ci/steam generator at

-200 days

PALISADES PLANT SGRR 6.2.2 OFFSITE RADIOACTIVE RELEASES AND DOSE ASSESSMENT Radioactive airborne and liquid offsite releases have been evaluated for the repair effort using conservative bounding parameters and assumptions.

6.2.2.l Airborne Releases Radioactive airborne effluent releases to the environment resulting from the repair effort have been estimated using the following assumptions and parameters:

a.

• Airborne releases are assumed to occur during the cutting operations.

b. The reactor coolant pipes and the steam generators are expected to be contaminated primarily by deposited corrosion products. Typical corrosion product activities expected on the primary side surfaces of the steam generators are given in Table 6.2-i. These activities have been increased by a factor of 3 for approximately 5 effective full power years (Reference 3) of additional reactor operation.

c. It is conservatively assumed that all the activity present in the vicinity of each cut will become

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PALISADES PLANT SGRR airborne and be available for release to the environment.

d. One hundred forty days of radioisotope decay were assumed before cutting operations, on the basis of the earliest reasonable.time as dictated by the repair effort. No credit was taken for radioisotope decay during cutting operations~

e. All primary coolant piping cuts are assumed to be made in specially-designed contamination control enclosures which will provide high efficiency filtration. The enclosures are assumed to be 90% efficient for.capturing particulates. An additional 99% efficiency is assumed for the stack filter (HEPA) through which all plant ventilation flows. Further reductions in airborne radioactivity will occur through use of the two internal recirculation filters which are discussed in Section 4.3.3; however, no additional environmental release credit is assumed for these filters since their primary purpose is to reduce occupational doses and minimize personal respiratory protection devices. Radioactiye airborne effluent releases to the environment based on the above assumptions are approximately

5. 9 x 10 -s Ci. Details of the airborne effluent release by isotopes*are given in Table 6.2-1.

6.2.2.2 Comparison with Observed Gaseous Releases and Estimated Doses During Normal Operation The estimated releases of radioactive airborne effluents during the repair effort are found to be much smaller than the observed effluent releases at the Palisades Plant during 1977. Observed airborne effluent releases during 1977 are compared with estimated releases during.the repair effort in Table 6.2-2. The estimated critical organ dose for the repair program was found to be less than 1.0% of the calculated critical organ dose for 1977.

6.2.2.3 Liquid Effluent Releases Liquid effluent releases resulting from the repair effort

. were estimated using analogous data from previous refueling and steam generator inspection outages. The total radioactive effluent release estimated for the repair activity is shown in Table 6.2-4. The total incluqes 6-3

• PALISADES PLANT SGRR laundry waste effluents expected during repair activities and the small amount of liquid waste generated as a result of local decontamination. The estimated specific activities of laundry wastewater are shown in Table 6.2-3. A description of the laundry waste treatment system is included in Section.4.3.6.3. A comparison of the average release for the repair effort is shown on Table 6.2-5.

6.2.2.4 Comparison with Observed Liquid Releases during Normal Operation.

Observed liquid effluent releases during 1977 are compared with the estimated releases for the repair effort in Table 6.2~5. The total body and significant organ doses for the repair effort were roughly equivalent to the dose from liquid effluents during .the year 1977.

6.2.2.5 Conclusion The combined effect to the offsite dose from gaseous and liquid releases is less than that expected for a year of normal operation. The estimated dose to an individual in an unrestricted area from all pathways of exposure is much less than the limits specified in 10 CFR Part 50 (Appendix I)~

• 6-4

PALISADES PLANT SGRR TABLE 6.2-1 ESTIMATES OF AIRBORNE RELEASES TO ENVIRONMENT DURING STEAM GENERATOR REPAIR EFFORT Activity o f Corrosion

. Pro d ucts 111 Total Release 121 Isotope at 140 days (µci/in2) (µCi)

Cr-51 0.589 0.378 Mn-54 0.730 0.468 Co-57 0.312 0.200 Co-58 85.5 54.8 Fe-59 0.535 0.343 Co-60 4.27 2.74 Nb-95 0.040 0.026 Zr-95 0.085 0.054 TOTAL NOTES:

( 1) 92.2 These are the activities presented in Table 4.4-1 59.1 converted to- µ Ci/in2. The a:ctivi ties were increased by a factor of 3 to account for the expected activity build-up.

(2) The following technique was used to estimate the activity from each isotope released during cutting operations:

Airborne Enclosure and

• Activity = Area x Activity of x Nwnber x Stack Filter Near cut of Cut Corrosion of Cuts Penetration

(µCi) ( . 5 in 2 ) (µCi/in2) (No.) ( .1) ( .01)

The total nwnber of cuts on primary coolant piping which were assumed. to total 12 where:

4 cuts (42-inch ID pipe) 8 cuts (30-inch ID pipe)

PALISADES PLANT SGRR TABLE 6.2-2 COMPARISON OF GASEOUS EFFLUENT RELEASES Estimated Release Average During SG Isotope 1977 Release . (Ci) Repair Effort (Ci)

Noble Gases 59.89 Negligible Iodines 1.51 x io*2 Negligible (11 Particulates 1.1 x io*3 * . 059 x io*3 Tritium 2.21 Negligible NOTES:

111 Approximately 29.0 and 26% of the total particulate release

• • during the year 1977 are Co-58 and Co-60, respectively .

PALISADES PLANT SGRR TABLE 6.2-3 ESTil~A1'ED SPECIFIC ACTIVITY OF LAUNDRY WASTEWA'IER ISO'IDPE §FECIFIC ACTIVITY Ci/cc< i>

Co~57 8.96 x 10-7 Cs-134 4.64 x 10-s Cs-13 7 1.03 x 10-*

Co-58

• 3.85 x 10-*

Mn-54 2.63 x 10-s Co-60 1.22 x 10-s Fe-59 3.27 x 10-*

Zn-65 4.09 x 10-7 Zr-95 Nb-95 sr-90

4. 15 x 10-6

7. 2 x 10-*

3.66 x 10-s Ni-63 2.65 x 10-s NOTE:

<1> Time averaged specific activity during a period of 365 days.

• PALISADES PLANT SGRR TABLE 6.2-4 ESTIMATED RADIOACTIVE LIQUID EFFLuENT RELEASED DURING THE STEAM GENERATOR REPAIR ISOTOPE RELEASE Ci co-57 6.85 x 10 4 Cs-134 3.54 x 10*2 cs~l37 7.85 x 10'.2 co-58 2.95 x 10 *1 Mn-54 2.01 x 10 *2 co-60 5.5 x 10 *2 Fe-59 2.5 x 10 *3 4

.Zn-65 3.12 x 10

• Zr-95 Nb-95 sr-90 3.17 x 10 *3 5.5 x 10 *3 2.79 x 10 *2 Ni-63 2.02 x 10 *2 TOTAL .544 H-3 1.91

PALISADES PLANT SGRR TABLE 6.2-5 COMPARISON OF RADIOACTIVE LIQUID EFFLUENT RELEASES

'J ESTIMATED RELEASE DURING ISOTOPE AVERAGE 1977 RELEASE (Ci) SG REPAIR EFFORT (Ci}

Fission .093 .544 and acti-vation products Tritium 55.8 1.91 Total . 55.9 2.45

PALISADES PLANT SGRR 7.0 ENVIRONMENTAL ASPECTS OF THE REPAIR PROGRAM 7.1 GENERAL The following sections present information and the assessment of environmental impact of the proposed steam generator repair program. The estimated environmental impact of the repair activity and disposal of the removed steam generators is expected to be negligible and temporary.

The proposed activity will cause little additional environmental impact over that of normal plant operation.

Construction activities, particularly the barge slip preparation, will be carried out in conformance.with local, state, and federal regulations. When the facility is returned to service after the repair, water use, occupational exposures, and radiological releases are expected to be less than those associated with current facility operation.

It may be necessary to store the old steam generators onsite in an engineered storage facility that will provide shielding for the direct radiation. The steam generators will be sealed to contain any airborne radionuclides. The steam generators may be shipped offsite to a federally licensed st9rage facility, if available. If shipped offsite, all local, state, and federal regulations pertaining to the shipment of radiological materials will be followed.

7.2 RESOURCES COMMITTED 7.2.l NONRECYCLABLE BUILDING MATERIALS The steam generator repair program at the Palisades Plant will require the commitment of various irretrievable building materials. The quantitative estimates for the nonrecyclable building materials are as follows:

• Concrete l,000,000 pounds Structural steel 50,000 pounds Alloy or stainless steel 1,594,000 pounds Tendons (53) 150,000 pounds Cable (copper) 400 pounds Inconel 280,000 pounds Pipe 5,000 pounds Wood 15,000 board feet

• • 7-l

7.2.2 LAND RESOURCES PALISADES PLANT SGRR The steam generator repair program will have minimal impact

. on the existing site in terms of land use. The construction

• '.J of facilities (see Section 4.1.1.2) to store the steam generators will require some excavation, leveling, and foundation work. If necessary, a building will be located near the temporary barge slip (see Figure 4.1-1). The extent of the disturbance will be temporary, negligible, and of minor impact. This area had been previously excavated during plant construction.

7.2.3 WATER RESOURCES During the repair effort, construction water will be supplied from existing Palisades Plant water sources. No requirements for commitments of new water sources have been identified for the repair effort. Since water consumption during the extended shutdown is expected to be less than during plant operation, water consumption during the repair effort will ~esult in a reduction in plant water usage.

A temporary barge slip will be constructed just north of the existing Palisades Plant (see Figure 4.1..;.2) to receive and offload two replacement steam generators.

• The temporary

• barge slip will be approximately 110 feet long, 50 feet wide, and 18 feet deep. The total dredged quantities are anticipated to be approximately 12,000 cubic yards based

• upon a lake elevation of 579' -0 11 (USGS). The dredged material will be disposed of according to Guidelines for the Pollution Classification of Great Lakes Harbor Sediments, U.S. EPA Region v. The dredging will be conducted according to specifications of the U.S. Corps of Engineers permit.

Steel sheet piles or sunken ship hulls may be used to provide wave and scour protection for the barge. Depending on lake conditions, the barge slip may have to be periodically redredged to specifications if suspended materials (sand) are deposited there before delivery of the generators.

The dredging activity will temporarily increase turbidity in the site vicinity and remove a small number of benthic organisms with the spoils. The piling or sunken hulls, if used, will provide substrate suitable for attachment of periphyton and filamentous algae, but large growths are not expected. The impacts of the dredging will only have a temporary impact upon the aquatic biota in the immediate plant vicinity. Removal of the temporary barge slip 7-2

• PALISADES*PLANT SGRR facility will result only in some temporary increase in turbidity* along the shore line.

7.3 WASTEWATER 7.3.1 SANITARY FACILITIES Since the repair activities will take place in locations near which permanent sanitary facilities are not readily accessible (e.g., the containment and laydown area),

portable units w:i.11 be used. There will be no modification to existing sanitary facilities as a result of the repair activity. *

• 7.3.2 LAUNDERING OPERATIONS Laundry wastewater generated during the repair activities will be produced in the existing facility. A description of the laundry waste processing scheme is included in Section 4.3.6.3.

7.4 CONSTRUCTION Construction activities at the time of the repair effort will satisfy applicable laws that are in force at that time.

These activities will have a negligible effect on noise levels, dust, or smoke.

7.4.1 NOISE Values and calculation methods described in Reference 6 have been used to exarr.ine the maximum sound pressure level (SPL) expected at the site boundary (0.4 miles) because of construction.noise. The maximum source SPL is expected to be less than 94 dBA at 50 feet, which will attenuate to less than 62 dBA at the site boundary. The site boundary maximum expected SPL is within the acceptable limits for permissible outdoor noise levels for sleeping with open windows.

Moreover, the site is located in a low population area. On the basis of these facts, it is concluded that the additional noise resulting from the repair program for the steam generators is expected to have negligible impact on the local area.

To protect personnel located on the site, Occupational Safety and Health Administration standards (state and federal) will be followed.

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7.4.2 DUST PALISADES PLANT SGRR Dust, if any, will be abated by periodically spraying with

• /'

water or other dust control measures. The frequency of spraying and the quantity of water sprayed will be determined by vi~ual inspection of the areas and will vary with the weather conditions.

7.4.3 OPEN BURNING Open burning is not anticipated during the steam generator repair effort. However, should the necessity arise, applicable county and state regulations for open burning will be followed.

7.5 RADIOLOGICAL MONITORING Radioactive effluent release points during steam generator repair activities will be the same as during normal plant

• operations; therefore, the plant radioactive process

• monitors will not be affected. Since releases of radioactive effluents during the repair-program will be similar to those from the operating plant, and their potential exposure pathway will be the same as for existing pl*ant operations, these effluents will be monitored in accordance with the existing environmental monitoring

• program at Palisades Plant.

7.6 RETURN TO OPERATION 7.6.1 WATER.USE Water consumption during post repair plant outages is expected to be appreciably less than is currently required as a result of repairs to degraded tubing.

Periodic plant shutdown for steam* generator inspection consumes large quantities of pure water. During shutdown, the steam generator water level is controlled on the low side (between 20 to 40% of operating band) to aid in chemical layup. Approximately.10,000 gallons of water are required to place the two steam generators into wet chemical layup.

If a steam generator requires draining (for tube plugging, tube sleeving, or tube removal) during the inspection, it would require an additional 24,000 gallons to refill. Other plant requirements for pure water include 70,000 to*ss,ooo 7-4

• PALISADES PLANT SGRR gallons for heater train, condensate polishers, and hotwell.

This is the amount necessary to refill the systems if maintenance had been performed that required draining the systems. Approximately 75,000 gallons would be required for primary system dilutions to return to power. Depending on various chemical parameters, as much as 50% of this water could be recovered through the plant recovery systems, such as clean radwaste system, boric acid recycle system, and steam generator blowdown recovery system.

Following replacement of the steam generators, it is expected that forced outages associated with steam generator tube plugging and/or tube sleeving will be essentially eliminated; however, it is not anticipated that the water consumption associated with the current inspection program will be significantly reduced because of the continuing requirement to inspect (eddy current test) the steam generator tubing at regular intervals.

7.6.2 OPERATIONAL EXPOSURES Section 4.3.7 discusses the future reduction in man-rem exposure as a consequence of the repair program. A

• • potential savings.of 250 man-rem/yr may be realized because of the expected elimination of the necessity to plug tubes in the repaired steam generators and the decrease in the number of inspections required (Regulatory Guide 1.83).

7.6.3 RADIOLOGICAL RELEASES Although the Palisades Plant has experienced only one primary to secondary leak from tube failure (1974), the repair of the steam generators should reduce the probability of future.

secondary releases as a consequence of the same tube failure mechanism.

• • 7-5

PALISADES PLANT SGRR 9.3 STEAM GENERATOR STORAGE AND DISPOSAL The old steam generators may be stored onsite, at least temporarily, before eventual disposal. The alternatives associated with the storage and disposal are addressed below .

9.3.1 LONG-TERM STEAM GENERATOR STORAGE ONSITE As discussed in Section 4.4.6, the steam generators would be sealed before storage to ensure complete encapsulation of residual contamination and placed in a storage facility.

The storage facility would provide adequate shielding around the steam generators. Access control and monitoring measures would be implemented during the storage period. At .

the end of the plant lifetime, disposition of the steam generators will be accomplished in conjunction with plant decommissioning.

9.3.2 IMMEDIATE SHIPMENT BY BARGE The immediate shipment of the steam generators in one piece by barge as discussed in Section 4.4.3.3 is currently considered to be a viable method of disposal. Immediately upon removal from the containment, the steam generators would be loaded on barges and shipped to a licensed depository.

• 9-2

PALISADES PLANT SGRR 9.3.3 SHORT-TERM STORAGE ONSITE WHILE UNITS ARE CUT UP FOR SHIPMENT (WITHOUT DECONTAMINATION)

• • r

\-

If the steam generators are to be cut up for shipment, additional contamination control measures, as well as shielding, would have to be employed as discussed in Subsection 4.4.3.2. For this option, an enclosure with appropriate controls for airborne and liql.iid effluents will be required in addition to the requirements set forth in Section 4.4.2. Techniques for cutting and packaging are not well established, making cost and dose calculations uncertain.

9.

3.4 CONCLUSION

S The present-day conceptual c;:ost and man-rem estimate for each method of steam generator s*torage and .disposal are summarized below.

Approximate Cost Man-Rem

a. Immediate shipment by barge $353,000 1-5 b.. Long-term storage with disposition during .

• decommissioning $2,560,000 5-10

c. Cut up and disposal near term with no decontamination $1,756,000 575-750 It is apparent that immediate shipment by barge would be beneficial from the standpoint of both man-rem exposure and cost.

9-3