ML20027D820

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Forwards Outline of safety-related Info Re Design & Operation of Low Level Waste Incinerator,In Response to Re Application for Amend to License SNM-7
ML20027D820
Person / Time
Site: 07000008
Issue date: 10/12/1982
From: Rouse L
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Toy H
Battelle Memorial Institute, COLUMBUS LABORATORIES
References
NUDOCS 8211100151
Download: ML20027D820 (6)


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Docket 70-8 NMSS R/F FCAF R/F PDR LCRouse Battelle Columbus Laboratories PLoysen ATTN: Mr. Harley L. Toy WBurkhardt NRC Licensing Coordirator apoth C. S k k N 505 King Avenue Region lIE Columbus, OH 43201 FBrown (LA File)

Fsher1 Gentl snen:

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On August 20, 1982 you requested that we provide infonnation that would assist you in preparation of an application for amendment of your Special Nuclear Material and Byproduct Material License Sle-7 to authorize the incineration of low-level radioactive waste in a denonstration program. We have prepared an outline of the type of safety-related infomation that we believe is appropriate to include in such an application.

It is included as Attachment A.

In addition, you should submit an enviromental report which describes the estimated impacts from conduct of the proposed incinerator denonstration progren.

The draft staff technical position " Preparation of Environmental Reports for Nuclear Fuel Fabrication Plants," may provide some guidance in the development of your report.

The draft staff technical position is included as Attachment B.

e The safety-related'infomation should be submitted in the fonnat of added or revised pages (including the use of appendices, ay appropriate) to your renewal application document (BCL-1081).

Limiting conditions and specifications, including administrative controls and procedures, for receipt and storage of waste, incinerator operations, and packaging of waste for disposal should be incorporated in Part I of the document referenced above through added or revised pages.

Some of the items contained in our -

outline may already be addressed in your renewal application.

The envirormental infonnation should focus on the incremental impacts (radiological and chemical) posed by construction and operation of the incinerator.

However, the enviromental report should specify the environmental monitoring progrart for the site, modified as necessary to account for the incinerator operation.

In view of the fact that we will prepare a safety evaluation report and an environmental impact assessment and that we plan to coordinate the review of your application with our Office of Nuclear Reactor Regulation and ' Division of Waste Managenent, we estimate that the time required to review the application and issue a license amendment would be about 9 to 12 months fran the time of receipt of the application. This estimate does not include any allowance for an adjudicatory hearing, if one should be requested and granted.

The completeness and quality of the application, of course, will be a major factor in the time required for the licensing process.

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NRC FORM 318110,80l NRCM O240 OFFICIAL RECORD COPY

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.. t We suspect that, aside from the operation of the incinerator itself, a principal concern will be identification of nuclides in the incinerator product. This may be difficult if different types of waste feeds are combi ned.

It will be important if commingled product is returned to waste generators.

It will also be important fran the standpoint of meeting the requirenents of 10 CFR Part 61, Management and Disposal of Low-Level Wastes by Shallow Land Burial and Alternative Disposal Methods.

Enclosed as Attachment C is a copy of 10 CFR Part 61 as presented to the Commission and recanmended for issuance by the staff as a final rule. While some changes may occur as a result of further review by the Camissioners, no substantive modifications are expected.

In particular, your attention is directed to the proposed addition to 10 CFR Part 20, Section 20.311. We recommend that you incorporate infomation in the preparation of your application on the measures and procedures that you will enploy to assure compliance with these requirenents, even though Part 61 has not yet been issued as an effective rule. (Note that the proposed requirenents of Section 20.311 would not become effective until one year after Part 61 is published.)

To our knowledge, the ATCOR Engineered Systens, Inc. incinerator is not designed to process high activity, low-level waste such as spent resins from nuclear power reactors.

If you propose to denonstrate the incinerator's use for such resins, we would expect the application to contain additional detailed infomation on the control of radiation exposure to laboratory

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personnel during both nomal incinerator operation, maintenance and product and byproduct handling. The Attachment A outline should be suitable for presenting this additonal infomation.

If you have any questions or comments about this letter or wish to arrange another meeting to discuss your proposed application for license amendment, please contact me or Mr. Peter Loysen of my staff (301-42.7-4205).

Si ncerely, Original signed by, Leland C. Rouse /

Leland C. Rouse, Chief Advanced Fuel and Spent Fuel Licencing Branch Division of Fuel Cycle and Material Safety

Enclosures:

1. Attachment A -- Outline
2. Attachment B -- Draft Staff Technical Position
3. Attachment C -- SECY-82-204 and SECY-82-204A (Proposed 10 CFR Part 61) g

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NRC FORM 31B ilO/80l NRCM O240 OFFICIAL RECORD COPY

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4 OUTLINE OF SArETY-RELATED TOPICS FOR DESIGN AND OPERATION

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0F LOW-LEVEL WASTE INCINERATOR Principal Design Criteria Purpose of Incinerator Program Incinerator Feed Incinerator Products and Byproducts Incinerator Functions Structural and Mechanical Safety Safety Protection Systems Confinement Barriers and Systems Offgas Treatment and Ventilation Controls and Instrumentation ljuelear Criticality Safety Radiation Protection Fire and Explosion Feed and Product Handling and Storage Decomissioning Facility Design Summary Description l

Location and Facility Layout Principal Features Incinerator Building Structural Specifications Building Layout i

l Incinerator Description Support Systems

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Support Requirements Support Systems Description ATTACHMENT A

'I Service and Utility Systems Building Ventilation Incinerator Fuel Electrical, Steam, Water Safety Comunications and Alarms Firo; Protection Maintenance Process Systems Process Description Narrative

. Flow Sheets Process Chemistry and Physic-Chemical Properties MechanicaiProcessSystems Waste Receiving, Storage and Handling Waste Feeding Product Handling, Packaging and Storage Chemical Process Systems Incineration -- Trash, Resins, Liquids, etc.

Process Support Systems Instrumentation and Control Maintenance and Repair Waste Feed, Product and Byproduct Analyses Process Confinement'and Manaaement Ventilation and Offgas Treatment Waste Feed Ventilation Incinerator Ventilation

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. Offgas Treatment Equipment and Systems Description Operating Characteristics Operating Procedures Product Handling Ventilation Product Handling, Packaging and Storage Equipment and Systems Description Characteristics, Concentrations and Volumes Packaging

, Storage Effluent Sampling and lionitoring Radiation Prot'ection Radiation Sources Radiation Protection Design Features Facility Design Shielding Ventilation Area Radiation and Airborne Radioactivity Monitoring ALARA Design Considerations Operational Considerations Safety Analyses Accidents Analyzed Dose Assessment

i I) 4-Conduct of Operations Operating Organization Personnel Qual.ifications Personnel Training Preoperational Testing Incinerator Test Program

' Decommissioning 4

Quality Assurance a

j Instructions and' Procedures Quality Control L

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Feed Process Product Solidification Records 3

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