ML19294B645
| ML19294B645 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 01/11/1980 |
| From: | Bowers C UNC RECOVERY SYSTEMS, UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Mccord T CHEM-NUCLEAR SYSTEMS, INC. |
| References | |
| NUDOCS 8003050202 | |
| Download: ML19294B645 (4) | |
Text
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4 Unc RECOVERY SVETEfT85 j
CEB 80-05 a.
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Ny A unc Resounces =.,i, i,
January 11, 1980 Chem-Nuclear Systems, Inc.
Tom J.
McCord, Vice President, Director of Nuclear Marketing g
One Greystone West Building 240 Stonehedge Drive f
Columbia, South Carolina 29210 Gentlemen:
We have reviewed your radioactive waste burial allocation plan which assigns a total of 592 cubic feet per month to United Nuclear Corporation for January through March, j
1980 (your letter, 12-28-79).
We recognize that Chem-I Nuclear is working under reduction schedules imposed
{
by an amendment to your South Carolina license.
- However, we object to the limits given to us in the referenced i
letter, for several reasons.
i First, the time-base used to determine the allocation ratio l
includes six months (November, 1978 through April, 1979) 6 when our burial needs were atypical and significantly below our normal and projected future requirements.
Second, the i
allocation given to UNC is disproportionately reduced from our base period average, when compared with Chem-Nuclear's required volume reduction.
Third, UNC Recovery Systems is currently working under a federal government (USNRC) mandate to retire a lagoon waste-holding system.
This mat-t erial, after a better-than-sixty percent volume reduction by special processing, will still require approximately 60,000 cubic feet for burial.
That volume is, of course, above and beyond our normal burial requirements.
If Chem-Nuclear were to allocate only 600 cubic feet per month to UNC, this material alone would take in excess of eight years to bury, far exceeding the deadline imposed by NRC.
(Accord-ingly, we are sending copies of this letter to W. T. Crow, NRC and H.
G.
Shealy, State of South Carolina for information.)
Based on the above and the information included in the attachment to this letter, we would appreciate your review of the burial volume currentl2 allocated to UNC and the basis for making future allocations, to determine if those allocations can be brought in line with our needs.
If you need any additional information, please contact our Manager, Guality Assurance (Mr. Robert Greggs.
Thank you for your assistancu.
Very truly yours,
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m Attachments
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800305 g
Attachment to Letter, CEB 80-05
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dated January 11, 1980 C.
E.
Bowers to Tom J.
McCord ANALYSIS OF UNC RECOVERY SYSTEMS RADIOACTIVE MATERIAL BURIAL INFORMATION I.
Base Period (November 1978 through October 1979) Burials Month Cubic Feet Nov. '78 173 Dec.
173 Jan. '79 188 Feb.
638 Mar.
173 April 518 May 1566 June 1947 July 1190 Aug.
3597 Sept.
1146 Oct.
2021 Total, Nov. 1978 through April 1979 1,863 ft3 (310 f t3/mo)
=
Total, May 1979 through Oct. 1979
= 11,467 f t3 (1,911 f t3/mo)
Total, twelve-month period 13,330 ft3 Average per month = 13,330/12 1,111 ft3/ month
=
II Burial Allocation Analysis Barnwell license reduction:
Base period 200,000 ft /mo 3
Jan.-Mar., 1980 178,000 ft3/mo 3
22,000 ft /mo 3r 11% reduction UNC Reduction Base period 1,111 ft /mo 3
Compared to Base Jan.-Mar., 1980 592 ft3/mo Period Burials:
519 ft3/mo or 47% reduction
" current allocation
1 Attachment CEB 80-05 Page 2 II.
Burial Allocation Analysis (cont.)
3 UNC Reduction (2)
May-Oct., 1979 1,911 ft /mo 3
Compared to Jan.-Mar., 1980 592 ft /mo 3
Typical Burials:
1,319 ft /mo or 69% reduction Even considering the maximum of 14% of burial space being held in an unallocated pool, UNC has been given an exces-sive reduction, as is shown below.
(1)
Base period less 14% =
955 ft /mo 3
592 ft /mo Jan.-Mar., 1980
=
363 ft /mo or 38% reduction (2)
May-Oct., 1979 less 14% = 1,643 ft3/mo 3
Jan.-Mar., 1980 592 ft /mo
=
3 1,051 ft /mo or 64% reduction When we consider the condition that the total volume reduction must come from outside the state of South Carolina, these reductions appear even more excessive.
i.e.
Since UNC was given a 47% reduction from the base period, all other non-South Carolina sources must have been given the same reduction.
Therefore, the total reduction of 22,000 cubic feet per month represents 47% of the non-South Carolina base period burials, which would be equal te (22,000)/(0.47)
=
46,808 ft / month.
Since the total nonthly burial 3
volume was 200,000 cubic feet, this means that only 23.4% of the total Barnwell burial volume came from out-of-state sources.
This figure does not seem con-sistent with the known ratio of producers of low-level radioactive waste within Souch Carolina to those outside which are in the area serviced by Chem-Nuclear.
'l NT C Attachment CEB 80-05 Pcge 3 Based on the above analysis, we believe that our allo-cation of burial space for the January through March 1980 period should be increased, at a minimum, to:
3 3
(1,111 f t ) (0.89) (0.86) = 850 ft / month for Recovery Systems alone base period average 3
where 1,111 ft
=
adjustment for 11% Barnwell site 0.89
=
i reduction adjustnent for unallocated pool.
0.86
=
To reflect our actual current usage rate, the adjustment should be to:
(1,911 f t3) (0.89) (0.86) = 1,463 ft3/ month for Recovery Systems alone III. Projection of UtJC Recovery Systems Burial Requirements Period Volume (f t3) 3 Jan. 1980 1,900 (861 ft already used)
Feb. 1980 1,300 Mar. 1980 1,500 3
April through Sept. 1980: a) 10,000 ft /mo (waste storage burial)*
3 b) 3,000 ft /mo (contaminated
~
mat'l burial) **
3 Oct. 1980 through Oct. 1981 1,000 ft /mo (contaminated mat'l burial)
- " Waste storage burial" is from the NRC mandated retirement of the lagoon waste holding system.
- "Centaminated material barial" is associated with facility decommissioning.
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