ML18054A344
| ML18054A344 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/27/1988 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807050306 | |
| Download: ML18054A344 (7) | |
Text
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consumers Power POW ERi Nii MICHlliAN'S PROliRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 June 27, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
SUPPLEMENT - REQUEST TO RETAIN SOIL IN ACCORDANCE WITH 10CFR20.302 Consumers Power Company correspondence dated November 12, 1987 and January 25, 1988 requested authorization to dispose contaminated soil inplace as specified by 10 CFR 20.302.
The area, known as the South Radwaste Area, has been contaminated by numerous cooling tower overflows and redistributed by heavy rain showers.
Although the majority of the radioactive material has been packaged for waste shipment, a large volume of very low activity radioactive material remains.
This volume of material would be very expensive to ship as waste.
The NRC, by letter of March 15, 1988 to Consumers Power Company, requested additional inhalation dose information and clarification of the contaminated area.
A generic inhalation dose evaluation is described in Attachment A.
Conserva-tive assumptions have been made to get the maximum organ dose possible from inhalation of contaminated soil.
The inhalation doses are not significant.
Consumers Power Company requests to expand this 10 CFR 20.302 request to include the entire South Radwaste Area.
Periodic cooling tower overflows and occasional heavy rains have caused redistribution of radioactive material to areas which were below Lower Limits of Detection (LLD) during previous evalua-tions.
Expanding the area would eliminate the need for a new 10 CFR 20.302 submittal if radioactive material is redistributed within the South Radwaste Area.
The South Radwaste Area is completely fenced and located directly South of the Plant South Security fence.
Area fence is shown in dark outline on Figure 1.
As described in our January 25, 1988, letter we intend to transfer the radwaste activities which caused the contamination of soil from the South Radwaste Area, except for the high level vault use which is not a potential flooding release problem.
OC0688-0049-NL02 8807050306 880627 PDR ADOCK 05000255 p
PDC I
Nuclear Regulatory Commission Palisades Nuclear Plant Retain Soil in Accordance w/10CFR20.302 June 27, 1988 Consumers Power Company requests approval to dispose of inplace low level radioactive materials which meet the following conditions without further 10 CFR 20.302 submittals.
- 1.
Material contained in the fenced area described as South Radwaste Area.
- 2.
Direct dose to a radiation worker would not exceed SE-02 mRem/hour from contaminated soil.
- 3.
Average gross beta/gamma concentration not to exceed SE-05 µCi/gm so inhalation doses to a radiation worker or at the site boundary would not exceed the values contained in Attachment 1.
2
- 4.
Additional radioactive material releases shall be identified in liquid Semi-Annual Effluents Reports as an 'Abnormal Release'.
Sampling, analyses and Semiannual Effluent Report inclusions of 'Abnormal Release' will be performed only when further flooding of the area occurs.
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?-;;;:uemin Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment OC0688-0049-NL02
,..1 The inhalation doses have been ca°Iculated on a generic worst case basis.
A generic basis has been selected to compensate for the elevated Lower Limit of Detection (LLD) in analysis and also to address movement of radioactivity within the South Radwaste Area.
The assumptions made are the worst case Dose Conversion Factor (DCF) used (see Table 3), a total average activity concentra-tion of 5E-05 µCi/gram and the entire area (500 m2 ) used instead of the indi-cated contaminated area (117 m2 ).
Increasing the area is self-explanatory.
The total average activity concentra-tion is being used irlstead of actual to account for dose important isotopes which may be present near the analysis LLD of lE-06 µCi/gm, but not detected.
The worst.case DCF is used to demonstrate a maximum organ dose.
A variation in isotope mixes could shift the maximum dose to a different organ but could not exceed the dose indicated.
Radworker and site boundary inhalation dose calculations are attached.
OC0688-0049-NL02
\\
.J DW = C s Where:
. fl8 cs Ef =
fl8 Table 1 Inhalation Dose From Contaminated Soil -
Adult Radiation Worker concentration of waste:
5.0E04 pCi/Kg.
occupancy factor: 2080 worker hours.;. 8760 hrs/yr = 0.237 areal mass available for resuspension (top 1 cm of soil):
16 Kg/m2 f 14 resuspension factor:
8.5E-9/m f 15 adult annual inhalation rate:
7300 m3 (RG 1.109).
DCFi = 7.46E-04 mRem/(50 yr. pCi):
adult lung (RG 1.109)
Substituting:
- 8. 78E-03 mRem/50 yr:
maximum organ dose.
Reference:
AIF/NESP-035 Evaluation of the Potential for De-Regulated*Disposal of Very Low Level Wastes From Nuclear Power Plants OC0688-0049-NL02
I, Table 2 Inhalation Dose At Site Boundary -
Infant Most Limiting X/Q
µ A
Where:
Terms are identified in Table 1 and F16 = 2045 m3 :
infant annual breathing rate (RG 1.109)
X/Q 1.4 E-6 sec/m3 :
actual 5 year site average
µ 3.8 m/sec average wind speed:
actual 1986 A
500 m2 :
contaminated area DCFi = 3.22E-03 mR/(50 yr. pCi):
infant lung (RG 1.109)
Substituting DSB 1.19E-04 mRem/50 yr:
maximum organ dose OC0688-0049-NL02
Table 3 Dose Conversion Factors for Inhalation:
Committed dose (mRem) over SO years per pCi inhaled, per Regulatory Guide 1.109.
Onsite - Radiation Worker Bone Liver Kidney Lung GI Cs-134 4.66E-05 l.06E-04 3.59E-05 l.22E-05 l.30E-06 Cs-137 5.98E-05 7.76E-05 2.78E-05 9.40E-06 l.OSE-06 Ba-140+D 4.88E-06 6.13E-09 2.09E-09 l.59E-04 2.73E-05 Sr-90*
l.24E-02 o.o 0.0 l.20E-03 9.02E-05 Co-60**
0.0 l.44E...:.06 o.o 7.46E-04 3.56E-05
- Sr-90 is a factor of SE-03 lower than Cs-137 based upon 10 CFR 61 sampling analysis and cannot be limiting.
Cs-137 was present in all samples where activity was identified.
Offsite - Infant Most Limiting for Inhalation Cs-134 2.83E-04 5.02E-04 l.36E-04 5.69E-05 9.53E-07 Cs-137 3.92E-04 4.37E-04 l.23E-04 5.09E-05 9.53E-07 Ba-140 4.00E-05 4.00E-08 9.59E-09 l.14E-03 2.74E-05 Sr-90*
2.92E-02 0.0 0.0 8.03E-03 9.36E-05 Co-60**
0.0 5.73E-06 0.0 3.22E-03 2.28E-5
- Sr-90 is a factor of SE-03 lower than Cs-137 based upon 10 CFR 61 sampling analysis and cannot be limiting.
Cs-137 was present in all samples where activity was identified.
OC0688-0049-NL02
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