ML19318C082
| ML19318C082 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/12/1980 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8006300526 | |
| Download: ML19318C082 (11) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 5
E WASHINGTON, D. C. 20555 E
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June 12,1980 Dockets Nos 277 and 50-278 Mr. Edward G. Bauer, Jr.
Vice President and General Counsel Philadelphia Electric Comany 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
Recent restrictions and reduced allocations at comercial burial sites have caused numerous licensees to actively consider increased on-site storage.
Several licensees are currently storing waste on a temporary basis and pro-posing to establish new facilities for longer term storage.
If on-site storage is necessary, the licensee must assure that the design and operation of the proposed facilities are adequate to maintain public health and safety, minimal risk to operating personnel, and present a minimal environmental impact.
Any decision to incorporate on-site storage requires a 10 CFR 50.59 safety review of the areas of:
(1) Radioactive Material and Effluent Control, (2)
Radiation Dose Control for Both On-site and Off-site Individuals, and (3) Acci-dent Prevention and Control. Enc ~
'd is a c.1ft NRC Licensing Position for
" Safety Considerations for Teg ort
'1-Sita 'corage".
This draft is forwarded for your information and use in evaiuating low-level waste storage criteria.
The NRC is presently evaluating both temporary and long 'erm on-site storage and its iglications. Currently,10 CFR 50.59 requires that you furnish a report containing a brief description and summary of the safety evaluation for each 10 CFR 50.59 change to your facility. The proposed model Appendix I generic Techni-cal Specifications (NUREG-0472 and 0473) contained guidance on the desired detail necessary in that report for radwaste systems.
In the interim, until Appendix I Technical Specifications are incorporated in your operating license, you are requested to include reviews for on-site storage additions in the monthly oper-ating report following the period in which the evaluation was completed. This report should detail the major additions / changes and contain a summary of the safety evaluation. This summary should include as a minimum your evaluation of each of the safety review areas described herein, including consideration of the guidance provided in the enclosed draft Licensing Position, man-rem igacts, anticipated radiological release assessments, final disposition of waste, and final conclusion of the 50.59 evaluation.
8008300
O Mr. Edward G. Bauer, Jr. :
No formal response is required concerning this letter unless waste storage facili-ties are modified. Comnents, however, are invited concerning the enclosed draft l
Licensing Position.
Sincerely, Ly Robert W. Reid, Chief Operating Reactors Branch #4 Division of Licensing
Enclosure:
Draft Licensing Position cc w/ enclosure:
See next page h
Mr. Edward G. Bauer, Jr.
Philadelphia Electric Company cc:
Eugene J. Bradley Director, Technical Assessment Philadelphia Electric Company Division Assistant General Counsel Office of Radiation Programs 2301 Market Street (AW-459)
Philadelphia, Pennsylvania 19101 US EPA Crystal Mall #2 Troy B. Conner, Jr.
Arlington, Virginia 20460 1747 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 Region III Office ATTN:
EIS COORDINATOR Raymond L. Hovis, Esquire Curtis Building (Sixth Floor) 35 South Duke Street 6th and Walnut Streets York, Pennsylvania 17401 Philadelphia, Pennsylvania 19106 Warren K. Rich, Esquire M. J. Cooney, Superintendent Assistant Attorney General Generation Division - Nuclear Department of Natural Resources Philadelphia Electric Company Annapilis, Maryland 21401 2301 Market Street Philadelphia, Pennsylvania 19101 Philadelphia Electric Company ATTN:
Mr. W. T. Ullrich Peach Bottom Atomic Power Station Delta, Pennsylvania 17314 Mr. R. A. Heiss, Coordinator Pennsylvania State Clearinghouse Governor's Office of State Planning Government Publications Section and Development State Library of Pennsylvania P. O. Box 1323 Education Building Harrisburg, Pennsylvania 17120 Commonwealth and Walnut Streets Harrisburg, Pennsylvania 17126 Albert R. Steel, Chairnen Board of Supervisors Peach Lottom Township R. D. fi Delta, Pecmsylvania 17314 Curt Cowgill U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Peach Bottom Atomic Power Station P. O. Box 399 Delta, Pennsylvania 17314
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NUCLEAR REGULATORY COMMISSION y
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SAFETY CON 5Ir{ RATIONS FOR TEMPORARY ON-SITE STORAGE OF LOW LEVEL RADIOACTIVE WASTE I.
Introduction The objective of this technical position is to provide guidance to the Licensees considering additional on-site low level radioactive waste stor-age capabilities. The duration of the intended storage, the type and fom of waste, and the magnitude of radionuclides present will dictate the safe-guards and the level of complexity required to assure public health and safety, and minimal risk to operating personnel. The longer the intended storage period, the greater the degree of controls that will be required for radiation protection and accident prevention.
For purposes of this document, the duration of temporary material storage is to be up to four (4) years. The magnitude of the on-site storage safety hazard is prect-cated on the type of waste being stored, the amount of radionuclides pres-ent, and how readily they might be transported into the environment.
In general, it is preferable to store radioactive material in solid form.
Under some circumstances, however, temporary storage in a liquid form may be desirable or required. The specific design and operation of any storage facility will be significantly influenced by the various waste forms, consequently, this document addresses wet waste, solidified wet waste and dry low level radioactive waste.
II. General Information Prior to any implerrantation of additional on-site storage, substantial safety reviews and environmental-analysis need to be conducted to assure adequate public health and safety, and minimal environmental impact. The acceptance criteria and perfomance objectives of ny proposed storage facility, or area, will need to meet minimal requirements in areas of design considerations, operational considerations, sifety censiderations and policy considerations.
For purposes of this brar:h po?Ition the major emphasis will be on safety considerations in the storing, handling and eventual disposition of the radioactive waste. Design and operational acceptability will be based on minimal requirements which are defined in existing SRP's, Regulatory Guides, and industry standards for proper management of radioactive waste. Policy considerations for waste min--
imization and volume reduction will also have to be integrated into the waste manegrment plan and the on-site storage alternative. Additional considerations for ALARA, decontamination, and decommissioning of the temporary storage facility also need to be integrated into the design and l
operation of the proposed waste storage facility.
Integratioa of waste l
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2-volume reduction and eventual disposal should be performed as early as possible because future requirements for waste forms may make stored wastes unreceptable for final disposition.
III. Wet Radioactive Waste Storage
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(a) Vet radioactive waste will be defined as any liquid or ifquid/ solid slurry.
For storage considerations, wet waste is further defined as any waste which does not meet January 1,1981 burial requirements for solidified waste (i.e., < 0.5". free water by volume of container or
< l.0 gallon per container whichever is less).
(b) The facility, supporting structure and tanks should be designed to prevent uncontrolled releases of radioactive materials due to spil-lage or accident conditions.
(c) The "following design objectives and criteria are applicable for wet radioactive waste facilities.
(1) Structures that house liquid radwaste storage tanks should be designed to seismic criteria as defined in Standard Review Plan (NUREG 75/087 - Section 11.2).
Foundations and walls shall also be designed and fabricated to contain the liquid inventory which might be released during a container / tank failure.
(2) All tanks or containers should be designed to withstand the corrosive nature of the wet waste stored.
The duration of storage under which the corrosive condi-tions exist shall also be considered in the design.
(3) All storage structures.should have curbs or elevated thresholds with floor drains and sumps to safely col-1ect wet waste assuming the failure of all tanks or con-tainers. Provisions should be incorporated to route spilled wet waste to the radwaste treatment systems.
(4) All tanks and containers shall have provisions to monitor liquid levels and to alarm potential overflow conditions.
(5) The' quantity of radioactive material allowed and the
,5hielding configurations will be dictated by the dose
/ rate criteria for both the site boundary and unrestrict-ed areas on-site.
The 40 CFR 190 limits will restrict the annual dose from direct radiation and effluent re-lease to the Public (individual) to less than 25 mrem per year to the whole body from all scurces of the Ura-nium fuel cycle; therefore, off-site doses from on-site
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~ storage must be sufficiently low to account for other sources (e.g., < l mrem / year). On-site dose limits as-sociated with temporary storaae will be controlled per 10 CFR Part 20 including the ALARA principle of 10 CFR 20.1.
(6) All potential release pathways of radionuclides (e.g.,
ovolved gases, breach of container, etc.) shall be con-trolled and monitored as per 10 CFR 50 Appendix A (General Design Criteria 60 and 64). Surveillance pro-grams should incorporate adequate methods for monitor-ing breach of container integrity or accidental releases.
(7)
All temporarily stored wet waste will require additional reprocessing prior to shipment off-site; therefore, pro-vision should be established to integrate the required treatment with the waste processing and Solidification systems. The interface and associated systems should be designed and tested in accordance with the codes and standards described in NUREG-75/087 Section 11.
IV. Solidified Radioactive Waste Storage (a) Solidified radwaste for storage purposes shall be defined as that waste which meets January 1,1981 burial site solidified waste criteria. Therefore, solidified radwaste will be identified as wet waste (e.g., evapora. tion bottoms, resins, and sludge) which is solidified and contains < 0.5% free water (by container volume) or 1.0 gallon of liquid (in the container), whichever is less.
For purposes of this document resins or filter sludges dewatered to the above criteria will be defined under this waste classification /
criteria.
(b)
Dewatered resins and filter media with radioactivity levels above 1 uCf/cc (>5 yr. half-life) which are disposed of after July 1,1981, will be required to be solidified or stored in high integrity containers (e.g., reinforced concrete).
Any storage plans should address container protection as well as any reprocessing requirements for eventual ship-ment and burial.
(c) Casks, tanks, and liners containing solidified radioactive waste should be designed with good engineering judgment to preclude or reduce the occurrence of uncontrolled releases of radioactive materials due to handling, transporting or storage. Accident miti-gation and control for design basis events (e.g., fire, flooding, tornadoes, etc.) must be evaluated and protected against unless otherwise justified.
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DRAFT
- (d) The following design objectives and criteria are applicable for solidified waste storage containers and facilities:
(1) All solidified radwaste should be located in restrict-ed areas where effective material control account-ability can be maintained. While structures are not required to maet seismic criteria, protection should be
, afforded to insere the radioactivity is contained safely by use of good engineering judgment, such as the use of curbs and drains to contain spills of dewatered resins or sludges.
(2)
Container material selection should conform to require-ments established in NUKEG-75/087 (Section ll).
If liquids exist which are corrosive, proven provisions should be made to protect the container (i.e., special liners or coatings) and, or neutralize the excess lig-uids.
If deemed appropriate and necessary, highly non-corrosive materials (e.g., stainless steel) should be used.
Potential corrosion between the solid waste forms and the container should also be considered.
In the case of dewatered resins, highly corrosive acids and bases can be generated which will significantly reduce the longevity of the container. The Process Control Program (PCP), should implement steps to assure the above does not occur, and provisions on container materi-al selection and precoating should be made to insure that container breach does not occur during temporary storage periods.
(3) Potential release pathways of all radionuclides present in the solidified waste form shall be monitored as per 10 CFR 50 Appendix A.
Surveillance programs shall in-corporate adequate methods for detecting failure or con-tainer integrity and measuring releases to the environ-ment.
For outside storage, periodic direct radiation and surface contanination monitoring shall be conducted to in-sure that levels are below limits specified in 10 CFR 20.202, 20.205, and 49 CFR 173.397. All containers should be decontaminated to these levels or below before storage.
(4)
Provision should be made for additional reprocessing or repackaging due to container failure and/or, as required for final transporting and burial as per DOT and burial site criteria.
Contamination isolation and decontamina-tion capabilities should be developed. Whereby signifi-cant handling and personnel exposure can be anticipated, ALARA mathodology should be incorporated as per Regulatory Guides 8.8 and 8.10.
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R uL il (5)
Procedures should be developed and implemented for early detection, prevention and mitigation of acci-dents (e.g., fires). Storage areas and facility de-
. signs should incorporate good engineering features and contingencies so as to handle accidents and provide safe-guard systems-such as fire detectors and suppression systems. (e.g., smoke detector and sprinklers), person-nel training and administrative procedures to insure -
both control of radioactive materials and minimum personnel exposures.
Fire suppression devices may not 1
be necessary if combustible materials are minimal in l
the area.
(6)
Provisions should be incorporated for collecing liquid i
drainage including provisions for sampling all col-lected liquids. Routing of the collected liquids should be to radwaste systems if contamination is detected or to normal discharge pathways if the water innress was from external sources and remained unconta' inated.
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(7)
Low level solidified waste stored in outside areas should be held securely by installed hold down systems.
The hold down system should secure all containers dur-ing severe environmental conditions up to and includ-ing the design basis event for this waste storage facility.
(8)
Container integrity should be assured against cor-rosion from the external environment; external weather protection should be included where necessary and prac-tical. Storage containers should be raised off storage pads where water accumulation can be expected to cause external corrosion and possible degradation of container integrity.
(9) The quantity of radioactive material allowed and the shielding configurations will be dictated by the dose-rate criteria for both the site boundary and unrestrict-ed area on-site. The 40 CFR 190 limits will restrict the annual dose from direct radiation and effluent re-leases to the Public (individual) to less than 25 mrem per year to the whole body from all sources of the Ura-nium fuel cycle; therefore, off-site doses from on-site storage must be sufficiently low to account for ather sources (e.g., < 1 mrem / year).
On-site dose limits as-sociated to temporary storage will be controlled per 10 CFR Part 20 including the ALARA principle of 10 CFR 20.1.
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.. (10) Total curie limits should be established based on the design of the storage area and the safety features provided.
(11)
Inventory records of waste types, contents, dates.of storage, shipment, etc., should be maintained.
V.
Low Level Ory Wast 7 Storage (a) Low level dry waste is classified as contaminated material (e.g.,
paper, trash, air filters) which contains sources of radioactive material that is dispersed in small concentrations throughout large volumes of inert material which contain no free water.
Generally, this consists of dry material such as rags, clothing, contaminated materials and small equipment (i.e., tools and in-struments) which cannot be easily decontaminated.
(b) Licensees should implement controls to segregate and minimize the generation of Low Level Dry Waste to lessen the impact on waste storage.
Integration of Volume Reduction (VR) hardware should be considered to minimize the need for aiditional waste storage fa-cilities.
(c) The following design objectives and criteria are applicabic for low level dry waste storage containers and facilities.
(1) All dry or compacted radwaste should be located in re-stricted areas where effective material control and accountability can be maintained. While structures are not required to meet seismic criteria, protection should be afforded to insure the radioactivity is contained safe-ly by use of good engineering judgment.
(2)
The waste container should be designed to insure radio-active mat:-fal containment during normal and abnormal occurrences. The waste container materials should not support combustion. The packaged material should not cause fires through, spontaneous chemical reactions, re-tained heat, etc.
(3)
Potential release pathways of all radionuclides preser t in the solidified waste form shall be monitored as per 10 CFR 50 Appendix A.
Surveillance programs shall in-corporate adequate methods for detecting failure of con-tainer integrity and measuring releases to the environ-ment.
For outside storage periodic direct radiation and surface contamination monitoring shall be conducted to in-sure that levels are below limits specific in 10 CFR 20.202, 20.205, and 49 CFR 173.397. All containers should-be decontaminated to these leeels or below before storage.
4.
(4) Containers should generally comply with the criteria of 10 CFR 71 and 49 CFR 170 to minimize the need for
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repackaging for shipment.
(5)
Increased container handling and personnel exposure can be anticipated, consequently, all ALARA meth.
odology should be incorporated per Regulatory Guide 8.8
. and 8.10.
(6)
The quantity of radioactive material allowed and the shielding configurations will be dictated by the dose-rate criteria for both the site boundary and unre-stricted areas on-site. The 40 CFR 190 limits will re-strict the annual dose from direct radiation and ef-fluent release to the Public (individual) to less than 25 mrem per year to the whole body from all sources of the Uranium fuel cycle; therefore, off-site doses from on-site storage cust be sufficiently low to account for other sources (e.g., < 1 mrem / year). On-site dose limits associated to temporary storage will be control-led per 10 CFR Part 20 including the ALARA principle of 10 CFR 20.1.
l (7)
Total curie limits should be established based on the design of the storage area and the safety features provided.
(8)
Provisions should be incorporated for collecting liq-uid drainage ir:cluding provisions for sampling all col-lected liquids. Routing of the collected liquids should be to radwaste systems if contamination is detected or to normal discharge pathways if the water ingress was from external sources (e.g., rain water or moisture) and remained uncontaminated.
(9)
Low-level waste stored in outside areas should be held securely by installed hold down systems. The hold down system should secure all containers during severe en-vironmental conditions up to and including the design j
basis event for this waste storage facility.
(10)
Container corrosion should be assured against from both the internal and external environment. Special internal liners and external weather protection should be in-cluded where necessary and practical. Storage containers should be raised off storage pads where water accumula-tion can cause external corrosion and resultant loss of container integrity.
(11)
Inventory records of waste types, contents, dates of storage, shipment, etc., should be maintained.
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