ML19154A589
| ML19154A589 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 06/03/2019 |
| From: | Consolidated Interim Storage Facility, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 72-1050-ISFSI, ASLBP 19-959-01-ISFSI-BD01, E-54257, RAS 55024 | |
| Download: ML19154A589 (3) | |
Text
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Page 2-7 In addition to industrial and transportation facilities, gas and oilfield operations are common in west Texas. Regionally, the WCS CISF is located in the Permian Basin of west Texas and southeast New Mexico, which is one of the most important petroleum-producing regions in the United States, containing several thousand oil and gas wells
[2-56]. Significant petroleum storage, however, is not located within 5 miles of the WCS CISF. Locally within the Waste Control Specialists property boundaries, oil and gas activity also is very limited. There is no active oilfield activity within the WCS CISF footprint area and only one documented dry hole in the immediate area of the WCS CISF (Figure 2-36). That dry hole has been cemented to the surface and proper plugging and abandonment protocol was observed. There is no evidence of any undocumented or orphan wells in the vicinity of the WCS CISF. If any open boreholes indicative of orphan wells are discovered during the construction process, these will be properly assessed and remediated using proper plugging and abandonment procedures in accordance with Texas Regulations. ISP joint venture member Waste Control Specialists also holds 100% of the Operating Rights for producing oil, gas, and other minerals for the area of land where the storage pads for Phase I and the future phases of the WCS CISF would be located. These rights allow ISP joint venture member Waste Control Specialists to prevent any drilling (horizontal or vertical) under storage pads for oil, gas, and other minerals. Based on Figure 2-36, 10 out of 12 locations (83%) are dry or no longer producing, which indicates there is little economically viable oil and gas resources within 1 mile of the WCS CISF and chances of petroleum recovery activities in this area are unlikely. As explained in SAR Section 2.6.2 and in the Probabilistic Seismic Hazard Analysis in Attachment D to SAR Chapter 2, it was determined there is a relatively low seismic hazard at the Waste Control Specialists site even with petroleum recovery activities.
SAR Chapter 12 Section 12.2 provides evaluations of the potential hazards these facilities present to the WCS CISF.
2.2.1 Aircraft Hazard Evaluation ISP performed an aircraft hazards evaluation for the WCS CISF to demonstrate adequate assurance that the risks from aircraft hazards are sufficiently low. NRC regulations pertaining to siting evaluation, 10 CFR 72.90, require that proposed spent fuel storage installations be examined with respect to the frequency and severity of external natural and man-induced events that could affect the safe operation of the facility. The NRC accepts that spent fuel storage installations do not need to be designed to withstand aircraft crashes if there is less than one-in-one-million (1x10-6) annual probability of occurrence [2-42].
For the WCS CISF aircraft hazard evaluation, relevant guidance from Standard Review Plan NUREG 0800 (Section 3.5.1.6-Aircraft Hazards) [2-43] was followed.
Although NUREG 0800 is intended for light-water reactor designs, the approach for estimating aircraft hazard is considered to be relevant guidance for the WCS CISF.
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Page 2-49 2-45 FAA IFR Enroute Aeronautical Charts and Planning. [Online]. Available:
https://www.faa.gov/air_traffic/flight_info/aeronav/digital_products/ifr/. [Accessed:
12-Feb-2019].
2-46 FAA AIS Open Data, MTR IR 128/180 Segment Location. [Online]. Available:
http://ais-faa.opendata.arcgis.com/datasets/0c6899de28af447c801231ed7ba7baa6_0/features/6
- 58. [Accessed: 12-Feb-2019].
2-47 Air Route Traffic Control Centers (ARTCC). [Online]. Available:
https://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/air_traffi c_services/artcc/. [Accessed: 14-Feb-2019].
2-48 GRC AirportIQ 5010 Airport Master Records and Reports. [Online]. Available:
https://www.gcr1.com/5010web/default.cfm. [Accessed: 11-Feb-2019].
2-49 Fact Sheet - Out Front on Airline Safety: Two Decades of Continuous Evolution.
[Online]. Available:
https://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=22975&omniRss=fact
_sheetsAoc&cid=103_F_S. [Accessed: 25-Feb-2019].
2-50 Air transport, passengers carried l Data. [Online]. Available:
https://data.worldbank.org/indicator/IS.AIR.PSGR?locations=US. [Accessed: 25-Feb-2019].
2-51 Hawley, J.A., 1993. The Ogallala and Gatuna Formations in the Southeastern New Mexico Region, A Progress Report: New Mexico Geological Society Guidebook, 44th Field Conference, p. 261-269.
2-52 Waste Control Specialists LLC, Andrews, Texas, 2007. Application for License to Authorize Near Surface Land Disposal of Radioactive Waste. License R04100, Rev 12c.
2-53 Fallin, J.A.T., 1988, Hydrogeology of Lower Cretaceous Strata under the Southern High Plains of New Mexico. New Mexico Geology, Volume 10, No. 1, February 1988, pp. 6-9.
2-54 Holt, R.M., and Powers,D.W., 2007a, Report on mapping of a trench through pedogenic calcrete (caliche) across a drainage and possible lineament, Waste Control Specialists Disposal Site, Andrews County, TX. Attachment 4-1a, Appendix 2B, to Byproduct Material Disposal Facility License Application to TCEQ by WCS, original date 21 June 2004, last revised June 2007.
2-55 Holliday, V.T., Hovorka, S.D., and Gustavson, T.C., 1996, Lithostratigraphy and geochronology of fills in small playa basins on the Southern High Plains, United States: Bulletin Geological Society of America, v. 108, p. 953-965.
2-56 Dutton et. al., 2005, Play analysis and leading-edge oil-reservoir development methods in the Permian basin: Increased recovery through advanced technologies.
AAPG Bulletin, V.89, No. 5 (May 2005), pp. 553-576.
Tentative Changes for Future RAI Responses RAI P-2.2-2 RAI P-2.2-1
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Page 2-109 Figure 2-36 CISF 1-Mile Radius Oil and Gas Activity All Indicated Changes are in response to RAI NP-2.2-2