ML20032A066
| ML20032A066 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 08/31/1977 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20032A062 | List: |
| References | |
| NUDOCS 8110280230 | |
| Download: ML20032A066 (29) | |
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l Nuclear Regulatory Staff Interim Safety-Evaluation I August 1977 Docket No. 50-201 Nuclear Fuel Services, Inc.
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and New York State Energy Research and Development Authority Western New York Nuclear Sarvice Center West Valley, New York l
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TABLE OF CONTENTS M
A.
Introduction...................................................
1 B.
Fuel Receipt and Storage.......................................
2 C.
Reprocessing Plant................
4 1.
Earthquake......................
6 2.
Tornado.............
6 3.
Use of the Plcnt..........................................
7 D.
High-Level Liquid Waste Storage................................
7 E.
Low-Level Liquid Waste Treatment..............................
11 F.
High-Level Solid Waste Burial Ground...........................
11 G.
Low-Level Solid kaste Burial Ground............................
13 H.
Supporting Services and Passivity..............................
13 i-I.
Management Organization........................................
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J.
Technical Specifications......................................
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K.
Srmmary and Conclusions........................................
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~1 APPENDIX I. Seismic Recurrence Intervals.............................
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i FIGURES P_agt Figure 1 NFS Organizat:on Chart....................................
16 Figure a Less Conservative Estimate of Recurrence of Earthquakes at West Valley, New York..................................
21 Figure b More Conservative Estimate of Recurrence of Earthquakes at West Valley, New York..................................
22 TABLES Table 1 Radiation Le"el in the Process Cells..........
5 Table 2 Tornado Criteria for the West Valley Site.................
5 Table 3 Radiation Levels in Support Areas.........................
8 Table 4 Technical Specifications No Longer Needed.................
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A.
Introduction On September 22, 1976, the Nuclear Fuel Services corporation (NFS) announced its intention to withdraw from commercial nuclear fuel reprocessing.
Reprocessing operations had ceased at its -facility at the Western New York State Nuclear Service Center in West Valley, New York in early 1972.
Since that time, NFS had been considering possible expansion of capacity and modernization of the plant through a modification program.
The purpose of this report is to provide the NRC Staff's evaluation of the safety of the present reduced activities at the West Valley site. We have considered all of the information presently available to us and the inactive status of the site. Where we were able to draw conclusions based on tha available information, we have done so. When precise information was not available conservative " bounding" assumptions are made to estimate the maximum consequences.
In some instances we have identified areas where development of additional information is prudent to confirm our judgment, particularly with respect to the longer-term prospects for the site and the possible impact of remote, but credible, natural phenomena.
The report includes consideration of the management of radioactive wastes at the site, the storage of spent fuel, the surveillance of the reprocessing plant and present administrative requirements.
Each of the these topics is related to the present facility license, CSF-1.
The staff's original safety evaluation for the West Valley reprocessing plant was issued in August 1965, based on the information then available.
Since that time the staff has developed more stringent criteria, parti-cularly with respect to the impact of natural phenomena.
These newer criteria are considered herein.
B.
Fuel Receipt and Storage Based on the discussion below, the staff concludes that there is no undue risk to the health and safety of the public or employees due to the con-tinued receipt and storage of spent fuel at the West Valley site.
The staff considered the effect of natural phenomena and man-aused accidents on the stored fuel and pool in this evaluation.
The NFS fuel storage pool contains approximately 170 MT of fuel.
Fuel was last received in 1975 and the licensee has no plans for receiving any additional fuel.
This represents about 70% of the pool capacity.
The pool was emptied and cleaned in late 1971 following termination of fuel reprocessing operatior.s.
Since completion of cleaging the pool, the radioactivity level in the pool has averaged about lx10 3 pCi/ml, 97% of which is ta4Cs and 137Cs.1 The radiation level over the pool, measured i
approximately one foot above the pool surface, is 2 to 5 mr/hr with the L
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higher readings occurring around the edge of the pool, probably because of the " bathtub ring" effect.
The FRS cr2nes, fuel handling equipment, and pool water cleanup and cooling systems are operational.
It has not been necessary to use the pool water cooling system because of the low fission product heat content of the fual in storage, and the pool water temperature has been low (85 F).1 Both earthquake and tornado are remote occurrences, particularly ' nose of sufficient size to cause damage.
Although an earthquake could c' adibly result in failure of pool water containment, even this extreme accident would probably not result in the break of fuel and subsequent release of radioactivity.
Because of the protection afforded by the pool water even an unlikely direct strike by a tornado would not result in a significant release of radioactivity.
Other accidents such as dropping a cask or fuel assembly would have very little radiological effect on-site and no effect o f f-s i te.
NFS originally recognized that seismic activity could be expected in the West Valley area and designed all structures in accordance with the appli-cable building codes as if the facility were located in Zone 3 (area of poss.ble major damage). However, as discussed in Appendix I, the staff has recently concluded that new design and construction should be based on a peak horizontal acceleration of 0.2g.
It is not known if the fuel storage pool can withstand this acceleration.
It is expected that the pool can withstand a sizable fraction of the 0.2g.
This should give it substantial capacity for all but the most severe earthquake events.
The staff has considered the possibility that the pool water surrounding and shielding the stored spent fuel could be completely lost by seismic cracking of the pool walls and floar even though NFS reports that the silty till surrounds the pool acting as a second containment barrier.2 The Sandia Laboratories have considered the possibility of complete water loss for the considerably more severe case of recently discharged reactor fuel in a report prepared for the NRC staff.a Figure B.10 of that report shows the variations in maximum peak cladding temperatures at different assembly decay heat powers. The decay heat is directly related to the cooling time since discharge.
We have compared the average decay heat generation rate of the long cooled fuel currently stored at West Valley (ca.1 kilowatt) with the curve of the figure.
For that storage situation a kilowatt of decay power corre-sponds roughly to about 100 C peak clad temperature.
The storage configuration at West Valley is sufficiently similar to the model configuration in the Sandia report, considering the very low maximum peak cladding temperature predicted, that we have concluded that there would be no danger of cladding failure due to the thermal environment from
loss of pool water.
Thus, there would be no resultant release of radioactivity from this postulated event.
Since, as discussed ab7ve, complete loss of water would probably not result in a release of radioactivity, the principal concern would be the risk to employees.
In order to better determine this risk, we have requested an analysis of the effect of earthquake on the fuel storaga pool by the Lawrence Livermore Laboratory. We expect results from this analysis by the end of this year.
No off-site impact would be expected fram the effect of a tornado on the spent fuel stored in the FRS, even if that unlikely event occurred. We state in Section C., 2, that the frequency of a site strike of the largest tornado imaginable is less than once in ten million years.
The only tornado effect of interest is the missiles it could generate.
In an almost identical review situation for the Midwest Fuel Recovery Plant (Docket 50-268), the staff's analysis showed that there was no off-site risk from missile strikes of the pool.
First, the probability of a missile of potential harm striking the pool is very remote (and superimposed on the already low chance of a tornado strike).
Second, the fuel contains very little radioactive gas to be released even if all the fuel pins were somehow ruptured.
Third, the missile damage is selective, i.e., only a canister or two of fuel would actually be effected.
Fourth, a critical excursion would be unlikely, even if a tornado struck, since the fuel would still be restraiaed from close spacing and there would be insuffi-cient fuel to sustain a chain reaction.
Lastly, the staff has calculated a maximum dose of only 1 millirem per hour at the surface of the pool,4 even if a critical excursion did occur.
The pool water cooling system for the FRS consists of two coolers, each having a 6x108 Btu /hr capacity.5 The actual heat load is much less, about one million Btu per hour since the fuel has cooled for a few years.8 Water is circulated through each cooler by an electrically driven 1,200 gpm pump.
The coolers may be operated independently.
Because of heat transfer to the ground, there may not be any need for forced cooling.
The coolers have not been needed during the winter.
Even if the coolers are needed to meet water temperature requirements (not a Technical Specifica-tion), their loss would be more a nuisance than a real ' safety problem, i.e., the high vapor pressure might over-humidify the FRS air and there could be some slight contamination, but water losses can be easily made up so there would be no loss of shielding problem. At any rate, because of the heat capacity of the water it would take three weeks or greater to reach boiling. A control system shuts off the pump when the pool level drops six inches.
If this interlock should fail, the pool level can drop only 18 inches more since the pump suction line 1 be uncovered.
Plant water is used for the secondary coolant with blowdown going to the sludge pond.
The blowdown is monitored by a radiation detector which detects tne
presence of radioactivity if pool water should leak to the secondary side of the cooler.
The cooling system is not protected against natural phenomena, but, as indicated above, cooling system loss is not a severe safety problem.
NFS has stated that they do not expect to' receive any more spent fuel.
Even if this situation should change, their previous experience with cask receipt and unloading of assemblies provides assurance that this activity will be conducted safely.
There is some possibility for occurrence of accidents such as a cask or assembly drop or for release of contaminated cask coolant during these operations.
Considering the case of a cask drop, NFS has stated in their Safety Analysis Report (p. X-3-3) for their proposed modifications that the pool is situated entirely within the impermeable silty till formation.
If the cask should penetrate the concrete bottom or walls of the pool, significant loss of pool water will be prevented by the imparmeable till.
In previous analyses for other sites, as well as the West Valley site, the staff has considered the types of accidents which can occur during fuel receipt.
Based on our analyses and the experience of these operations, there is no reason to expect significant radiological consequences due to this type of accident.
The ventilation system for the Fuel Receiving and Storage building has been upgraded and is considered to be in good condition.
It incorporates a recirculation system passing the air through HEPA filters. On February 12, 1976 the staff requested information from NFS concerning the FRS off gas system.
The staff's concern was the possibility for increased occupa-tional exposure from an improperly installed off gas duct.
Since NFS has not supplied the requested information and is no longer pursuing its application for construction of stored fuel, and,ur review has terminated, we have no. bases for a conclusion regarding this system. Because of the j
relative-inactivity in the FRS, very little load is being handled by the off gas system.
Primary scurces of off gas would be the venting of shippin]
casks (none being received) and from changing of filter and ion exchange l
media. Over a period of time the radiation background to personnel could be increased from this inadequate system.
The staff considers this a minor safety question of employee exposure.
We recommend that the NFS health physics staff monitor this area and corrective action be taken if there is a measurable change in radiation level.
C.
Reprocessing Plant Based on the further discussion below the staff concludes that there is very little risk to the health and safety of the public from the' dormant reprocessing plant.
The plant was designed and constructed for active reprocessing operations and is now in standby.
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. 4 Earthquake occurrence at the site is infrequent and even if one did occur it is doubtful that radioactivity would be released.
The total inventory of radioactivity in the building's process cells is small and a portion of that is " fixed" on walls and equipment.
Tornado occurrence is very infre-quent and, again, it is doubtful that the small amount of radioactivity could be removed from the cells by a tornado.
Other accidents involving potential for the release of significant amounts of radioactivity to the environment are virtually incredible because of the pastive nature of the activity in the plant.
Following plant shutdown in 1972, NFS began preparation for their proposed modifications.
Equipment was flushed out and decontamination began in the plant.
Extractica cells 2 and 3 were decontaminated to permit beginning modification wor' Decontamination in the plant as a whole was not completed.
Current radiati. levels in the cells (secured during a site' visit in October 1976) are shown in Table 1.
TABLE 1 Radiation Levels in the Process Cells 1 Location mR/hr 5
Process Mechanical Cell 1.42 x 10 6
General Purpose Cell 0.7-1.8 x 104 Chemical Process Cell 1.2-3.2 x 104 Extraction Cell I 0.2-2.5 x 10 Extraction Cell II 32-140 Extraction Cell III 3-17 Plutonium Product Cell 0.5 Uranium Product Cell 0.5 Most of the equipment remains intact in the cells, although some equip-ment, such as the shear has been partially disassembled.
Since the cells are still contaminated they would require extensive decontamination prior-to decommissioning.
While there are no process activities in the cells at present, the con-tained radioactivity could be subject to release through the impact of natural phenomena, earthquake and tornado.
Because of the terrain of the site, flooding is incredible.
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Based on calculations from estimates given in a consultant's draft report 7
on decommissioning the Process Mechanical Cell contains 1,000 to 10,000 curies of radioactivityt principally strontium and cesium.
About one-half i
of the radiation is gamma activity.
A substantial portion of this activity is probably fixed, i.e., sufficently held by walls and floor to resist becoming airborne during ventilation flow pattern changes.
1.
Earthquake As discussed in Appendix I, a recent analysis by the staff indicated that about 0.2 g free field acceleration at the surface would be a suitable design basis value for new construction at the West Valley site.
This value is related to the largest earthquake which could be expected to occur at the site.
Both the Lawrence Livermore Laboratory (LLL) and the Los Alamos Scientific Laboratory (LASL) have been analyzing the effect of an earthquake on the reprocessing plant.
The staff has not yet received a completed report from these consultants on this effect.
Information to date indicates that under these dormant conditions, the cells containing substantial quantities of radioactivity (see Table 1), would probably not release radioactivity at seismic accelerations far below 0.2 g.
For example, onset of failure of the General Purpose Cell is predicted to occur at about 0.1 g, but because it is embedded, the radioactivity would not be available for atmospheric dispersal.
The Chemical Process Cell and the Process Mechanical Cell would be expected to withstand 0.15 g or greater.s Based on Figuru a and b in Appendix I an earthquake af this severity is not likely once in a thousand vears.
In any event, the release and dispersal of the radioactivity would still be unlikely, taking into account the lack of a dispersal mechanism within the building, i.e., temperature or pressure gradients and the fact that " failure" as defined in the analysis is the value at which stresses exceed elastic limits such that structural materials could yield or cracks could appear, but it is still unlikely that the confinement of radioactivity would be lost.
2.
Tornado On May 24, 1974, the staff sent tornado design criteria to NFS which it considered applicable to the West Valley site.
The criteria are:
TABLE 2 Tornado Criteria for West Valley Site Maximum wind speed 325 mph Rotational speed 270 mph Translational speed 55 mph Radius of maximum rotational wind 265 ft Total pressure drop 2.6 psi i
Rate of pressure drop 0.8 psi /sec.
These values are based on the staff's analysis of tornado data pro-vided by NFS covering the period 1950-1970 for Erie, Cattaraugus, and Chautaugua Counties, New York.
Based on a calculated average tornado path size of 1.4 square miles, the recurrence interval for a tornado of any size at the plant site is 3,400 years.
Tha design basis tornado has a recurrence interval of 10,000,000 years.
The effect of a tornado of this size on the existing West Valley structure has not been determined.
The principal concern in a rein-forced concrete structure of this nature is the effect on the ventila-tion system. The Los Alamos Scientific Laboratory (LASL) has recently completed writing a computer program capable of analyzing the effect of a tornado on a ventilation system of a nuclear structure.9 LASL has also completed testing of the effect of severe pressure drops (3 psi in 3 seconds) on (8" X 8") ventilation filters.10 The 8" x 8" filter successfully withstood the imposed pressure drop at the design rate.
The installed size for this application is 24" x 24".
We cannot state at this time that the ventilation system can withstand any size tornado, but the available evidence indicates 1) that any.
tornado hit is unlikely, 2) the largest size tornado is almost, if not, incredible, and 3) the ventilation system can probably withstand most tornadoes.
These factors, taken together with the relatively small quantities of radioactivity in the process cells with the most contamination, lead us to conclude that the risk of release from the process cells from tornado is acceptably low.
Notwithstanding this conclusion, the staff intends to obtain additional information on the effect of a tornado on those areas of the plant which may have some potential for the release of radioactivity.
We have asked ORNL to assist us in this effort.
3.
Use of the Plant The plant is not being used for any processing at the present.
All of the solvent extractant has been removed and buried. Table 3 shows the radiation levels in areas accessible by personnel.1 Because work is limited to surveillance activities, occupational exposure has steadily decreased over recent years.
If the plant were to be reused for any purpose, there would have to be addicional decontamination of these areas.
D.
High-Level Liouid Waste Storage High-level liquid waste from plant operation from 1967 through 1971 is presently being stored in two tanks at the site.
The larger volume, about 600,000 gallons, is contained in a carbon steel tank which is within a-reinforced concrete vault.
This liquid waste was neutralized with excess sodium hydroxide before transfer to the storage tank. The smaller volume, about 12,000 gallons is acidic high-level waste, containing thorium stored l
TABLEj[RadiationlevelsinSupportAreasl Location mR/hr Below grade 100-150 Crane room (GPC) 0.5 GPC operating aisle 1.6 Ventilation duct
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First floor Scrap removal room 20 Equipment decontamination room 30-200 3
Off gas blower room 0.3-1.0 x 103 Acid recovery pump. room 0.5-1.0 x 10 South stairwell (failed line) 5-10 3
Liquid waste cell 0.5-1.0v 10 Lower warm aisle 20-30 Ram equipment room 30 3
Manipulator repair room 2 x 10 Mechanical operating aisle 0.5 Uranium loadout area 0.5 Head-end ventilation duct 20-50 Second floor Upper warm aisle Flush Penetration 50 Acid leak Ventilation washrocm 5
3 1-2 x 10 Ventilation duct 120 3
Crane room (PMC) 0.3-1.2 x 10 Equipment decontamination room 30-200 Third floor Vantilation duct (near Spectrographic Laboratoryl 150 Ventilation washroom 10 Chemical crane room 50-100 Solvent storage tank (empty) 100 Process mechanical cell-door wall 50-150 Fourth Floor Control Room 2.5 Stack area 10 Process mechanical cell-door well 100-200 Chemical process cell-door well 10-20 l
Chemical process cell roof 2.5 i
Fifth floor Pulse equipment aisle 20 Cell ventilation duct (XCR) 50
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in a stainless steel tank..
Each tank has a spare; the carbon steel spare is in a separate vault, the stainless spare is contained in the same vault as the tank in use.
In a memorandum dated March 1, 1977 (Smith to Chapman) the staff discussed, among, other things, the evaluation of the was;e tank safety.
The staff concluded specifically that:
1.
No leaks have been detected from the tanks since they were placed in operation about ten years ago.
2.
Recent inspection of corrosion coupons indicates that general corro-sion rates are much less than those allowed for by design.
(Corro-sion rate is about 1/10 design allowable.)
3.
Temperatures in the tank are less than boiling and are dropping
(<185 F). As a result, general corrosion is expected to decrease and stress corrosion cracking becomes more unlikely.
4.
The occurrence of stress corrosion cracking is difficult to predict but all welds in the tank were stress relieved to prevent it from happening.
The pH and nitrate concentrations are at levels which experience indicates are favorable for preventing stress corrosion cracking.
Furthermore, in the event a leak were to occur it would have little effect on the public because:
1.
The tanks stand within a separate steel liner and are encased in underground concrete vaults to contain any leakage, if it should occur.
2.
Experience at ERDA sites indicate that leaks which develop in tanks containing neutralized wastes tend to be self-healing.
Salt crystals form at the crack and seal off or slow down leakage providing time for corrective action to be taken.
3.
Tank liquid waste contents can be pumped to adjacent spare tanks if a leak occurs.
4.
Soil surrounding the tank and vaults is notably impenetrable to water flow and seepage. Thus, transport of radioactivity offsite and consequent exposure to people cff the 3300-acre site from a leak through the multiple containment barriers is highly unlikely.
In our present evaluation, we consider the effect of natural phenomena and other occurrences on the high level liquid waste storage.
In this regard,
we have received a report from our consultants at the Oak Ridge National Laboratory (ORNL), dated February 7,1977. ' ORNL reviewed information received from NFS on these effects and performed their own independent analyses. We agree with the ORNL conclusion that there would be virtually no impact off-site from tank failure caused by catastrophic events such as tornado or earthquake. General flooding of the site is incredible. A constant head of water surrounding the vaults is maintained by a feed water, drainage, and pumping system beneath the tanks.
For this reason, local flooding will not be a problem.
Althougn the staff expects no offsite impact from waste tank failure, regardless of cause, some difficulties would be posed by the recovery from failures, particularly structural failure of the tank-vault system.
In order to gain additional insight into the risks involved, we have asked our consultants at Lawrence Livermore Laboratories (LLL) to investigate the effect of earthquake on the waste tank-vault systems.
Preliminary information based on an equivalent static analysis is expected by mid-year. The " floating" incident discussed below is included in this analysis.
The large waste tanks and vaults " floated" during construction in April 1965.
The incident is described in a report by Bechtel consultant Louis S.
Barnstein, who recommended corrective action, primarily grouting under-neath the vault slab to remove bending stresses on the slab.11 The correc-tions were implemented in 1965 and accepted by NFS on January 24, 1966 through their consultants, Nussbaumer, Clarke and Velzy, Inc.
Since the operating license was issued on April 19, 1966, the AEC Regulatory staff also accepted this correction.
In addition to these analyses, the staff has asked ERDA for assistance in providing additional confirmatory information on the present condition of the waste tanks.
The wastes are confined within the several barriers preventing their release--the steel tanks, the vault liner and sump systems, the concrete vault, and the silty till. As discussed in detail n, the staff memorandum, A. T. Clark, to R. M. Bernero, dated January 19, 1977, there has been a growth in technology applicable to liquid waste management :ince the NFS tanks were commissioned.
This information would provide additional assurance that these wastes can be safely confined until their final disposition.
The purpose of this evaluation is not to consider the ultimate disposition of the waste.
The staff has been preparing for the rulemaking proceeding contemplated by Appendix F to 10 CFR Part 50.
The rulemaking will provide the framework for an acceptable disposition.
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E.
Low-Level Liouid Waste Treatment The West Valley plant was designed to rel,ase liquid effluents containing small quantities of radioactivity during operation.
These releases were controlled through the use of settling lagoons, a weir, and further dilu-tion in on-site streams.
All of these releases have been monitored.
On January 14, 1971, NFS submitted its safety analysis of a low-level waste treatment plant proposed for use in reducing radioactive content of the liquid effluents. The plant began operation in May 1971.
The plant is conveniently located between and adjacent to the settling lagoons and separated from the reprocessing building.
Suspect water is fed to the plant from one lagoon and discharged to another.
In September 1971. NFS suspended releases in order to scrape and remove silt and settled radio-activity from the bottom of the discharge lagoon (No. 3). Although liquids can still be celeased from the reprocessing plant for treatment, one principal use of the low-level waste treatment which has continued to the present is the treatment of pump discharge from the New York State licensed low-level waste burial ground.
Because of the low levels of radioactivity involved in this plant, the staff does not consider its potential loss through accident to be of significance.
Operation of the plant is considered by the staff to be necessary and beneficial for reducing radioactive concentration to as low as practicable.
F.
High-level Solid Waste Burial Ground Based on the following discussion the staff concludes that there have been no problems with the operations of the high level solid waste burial ground since operations of the West Valley plant began in 1966.
It is not expected that any releases of radioactivity will occur over the short term.
The high level solid waste burial ground at the NFS West Valley site is operated under the provisions of the license for the Fuel Reprocessing Plant, CSF-1.
All of the buried high level waste originated in the West Valley operations.
The waste consisted of process waste such as fuel hulls and contaminated equipment.
The site area for high level burial is about 7.2 acres and is located about 1,400 feet southeast of the process building.
It is completely within the plant security fence.
Leached hulls and other high level solid waste which can be packaged in 30 gallon steel drums are buried in holes about 32-inches by 78-inches by up to 50 feet deep.
Thase disposal holes are dug using a crane and " clam shell." Earth removed from the hole is inspected to make sure that burial is completely within the silty till. After completion of the hole, the i
surface area is mounded and drainage trenches provided to minimize drain-age of surface water into the disposal hole.
Colid waste drums are normally brought to the high level burial ground in groups of three.
The three drums are placed in the hole one at a time using a crane and a lifting device wnich engages and releases the drum automatically. When the three drums are in place, a predetermined amount of backfill is added to the disposal hole to cover the drums.
This procedure is continued with added drums and backfill until the hole is filled to near the top.
Larger holes or trenches are prepared for equipment or material which cannot conveniently be fitted into the deep burial holes.
This includes large process equipment and fuel assembly components, tanks filled with sorbed solvent, and used ventilation filters.
Since the beginning of operation at the NFS plant about 150,000 cubic feet of material containing about 500,000 Ci of radioactivity have been buried in the high level burial ground.
This waste is buried in a thick layer of silty till.
Each burial location is backfilled with a minimum of 4 feet of the silty till.
The surface of the burial area is graded to minimize erosion and also drainage into the disposal area.
Concrete monuments or cairns will be used tn mark the location of burials and the location and general type of burials are recorded on a plot of the site.
Duplicate copies of the burial records are maintained at separate locations to minimize the pos3ibility of loss by fire.
It is believed that the material buried in the high level burial ground is secure from natural phenomena.
Flooding at the burial site is incredible and an earthquake having an acceleration of 0.2 gravity would not affect the material confined in the burial ground.12 The bulk of the radioactivity buried as high level solid waste is induced radioactivity and residual fission product contamination associated with the cladding hulls.
This induced radioactivity can be released only by dissolution of the highly insoluble hulls and any residual fuel material in the ground water.
Dissolution rates may be expected to be very low in view of the refractory nature of the zirconium alloy or stainless steel hulls and of the fact that hot nitric acid has been used to dissolve the fuel from the hulls.
It should be noted that a number of NPR fuel assemblies (AEC owned fuel furnished as part of the guaranteed base load) were received at NFS in poor condition.
It was decided by NFS in consultation with the AEC1a not to process this fuel because of problems due to its leaky condition.
About one ton of this fuel was returned to the Hanford Works and the remainder was encased in cement within 30 gallon drums and buried in the high level waste burial ground.
Release of radioactivity from the high level waste burial ground has been evaluated by NFS. " Mechanisms considered included retention of the radio-activity in the burial hole, retention of radioactivity in the soil near the disposal hole or trench, dilution of radioactivity bearing water by rain water filtering down through the soil, and decay during travel through the earth.
The NFS study indicates that an escape rate of 10 7 from the trench is highly conservative.
Passage thrgugh 4 feet of_8 silty till results in a fractional release of 6.4 x 10 8 to S.4 x 10 and_through 100 feet of surficial till an additional 2.5 x 10 5 to 5.0 x 10 7 Accorcing to NFS overall releases off the site including dilutions in on-site streams and by Cattaragus Creek result in stream concentrations many orders of magnitude below allowable concentrations.
The NFS analysis appears to be adequately conservative and is included here because of its availability within the time frame of this evaluation.
The staff is considering the value of reanalyzing the health and safety and environmental impact of the burial of these wastes over the long-term.
W recommend that confirmatory data be obtained on soil permeability, ion exchange properties, slope stability, and possible future slumping of disposal holes and trenches. We have asked the New York State Geological Survey to assist in this investigation.
G.
Low-level Solid Waste Burial Ground The low level waste burial ground at the West Valley site has been operated by NFS under license from the State of New York.
New York is an Agreement State, i.e., has assumed authority from the NRC for regulating activities involving radioactive materials such as the low-level waste burial ground.
A detailed discussion by the staff of the low level burial ground is presented in the staff's response to comments on the NRC's environmental survey of the reprocessing and waste management portions of the LWR fuel cycle-(Appendix H, NUREG-0216, page H-7).
Additional staff views may be found in Congressional corresoondence, viz. staff letter, dated March 2, 1977, W. J. Dircks to Congressman Stanley N. Lundine, and staff letter, dated April 9, 1976, K. R. Chapman to Senator Pastore.
H.
Supporting Services and Passivity The plant operations for which utility services are essential are the high-level waste storage, spent fuel storage and process building safe-keeping.
Electricity and natural gas are the two primary sources of energy supplied from off-site.
Diesel fuel oil is stored on-site (40,000 gallons) as an alternate.
Electricity is used to drive ventilation fan motors and air compressors.
Natural gas fuels a boiler to make steam. Water is supplied from two on-site lakes.
The pumps for this water supply are powered from a separate electric supply.
. Complete electrical failure is relatively remote since there are two independent off-site supplies of electricity and an emergency generator, supplied by the on-site diesel fuel oil.
If electricity were completely lost, the main building ventilation fans and the waste tank off gas blowers would shut off.
Since there are no peccess activities, the loss of building ventilation fans over the short time span required to return to normal power or to repair the generator, will not cause any problems.
Without the off gas olowers the waste tanks will lose their low vacuum, thereby increasing the potential for some contamination around access risers.
Pressure relief would still be available through the vent system, but the condenser fans would be shut off.
Natural convection alone will provide some cooling and water could be sprayed on the heat transfer pipes as a temporizing measure.
Steam and electricity are used to compress air. One 300 horsepower com-pressor is driven by an electric motor; a second 300 horsepower compressor by steam turbine. Air is used in the waste tanks to circulate the waste to prevent " hot spot" boiling and smooth out the heat distribution.
Compressed air is also used for liquid level and specific gravity determi-nation (bubblers), and to operate pneumatic instruments.
Steam also finds use for heating and liquid transfers.
The sump eductors identified in Technical Specification 6.2 are steam jets.
Even though the vessels of concern are no longer in use, NFS continues to test the eductors because it is required by the Technical Specification.
At any rate, if cell decontalcination is planned, these eductors, and the motive steam, will be needed.
A steam eductor also is necessary for removing liquids from the high-level waste vault sumps.
Liquid collecting in the sump may be either intrusion water or radioactive waste leakage.
There is no dirhet radiological safety reason for heating the process building and, therefore, no steam is needed for this purpose.
The staff cannot determine, from the type of information we receive, what effect loss of heat would have on the process building, i.e., whether or not pipes can be drained or will freeze and burst.
The only solution of concern in the process building is the depleted uranium stared in the Uranium Product Cell (UPC) in t.
,coduct tanks.
The UPC could be heated separately to keep this solur. ion from freezing.
The staff concludes that electricity, steam, water, and air are needed at the site, but at a much reduced rate of use.
NFS has kept this service equipment repaired and operable.
The supporting services are more than sufficient to meet current needs.
NFS should pursue additional remedies to reduce dependence on off-site energy supplies.
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I.
Management Organization The Technical Specifications for West Val'.ey require a staff which is competent to operate a reprocessing plant.
These staff positions are:
General Manager, Assistant General Manager, Production Manager, Health and Safety Director and Technical Services Manager.
In addition, the Technical Specifications require a Plant Safety Committee consisting of all of the above positions as a minimum.
On November 22. 1976, we received information from NFS on their current organization.
It is shown in Figure 1.
All of the positions required by the Technical Specifications are filled by individuals with many years experience at the site.
Because of the passive nature of the operation a large staff is not required at the site.
However, competent staff is required at the site to exercise the good judgment necessary in the event of adverse.ircumstances.
I In addition to the on-site staff, we have recently been informed by NFS that a supervisor of the Health and Safety Department at the Erwin, Tennessee plant has visited the West Valley site several times to audit the health and safety program.15 Technical Specification 7.1.6 requires periodic audit of the operation by competent NFS or other personnel not directly responsible for the operations.
Based on the above discussion we conclude that the NFS management is capable of safely conducting their present activities.
.J.
Technical Specifications We have reviewed license CSF-1 including its Technical Specifications.
Since NFS no longer plans to reprocess, many Technical Specifications no longer are necessary.
These Specii'ic:tions are listed in Table 4 below.
T1BLE 4 Technical Specifications No Longer Needed No.
Title 4.4 Dissolver Charging 4.5 Feed Solution Concentration 4.6 Fissionable Isotope Concentration in Solvent Extraction 4.7 Extractant Concentration 4.9 Plutonium Ion Exchange Operation 4.0 Plutonium Solution Storage 4.11 Rework Solution Concentration 4.15 Evaporator Steam Pressure 6.1 Boron Raschig Rings 6.6 Dissolver Dilution Air 6.7 Boric Acid l
6.10 Poisoned Dissolver Baskets L
i 6.11 Solvent Analysis 7.2 Category 10 Fuels l
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Based on our review of these Technical Specifications and considering their application to activities with much greater potential for release of radioactivity, we conclude that these Technical Specifications are adequate j
for the present dormant activities.
K.
Summary and Conclusions In the previous sections the staff has considered and evaluated the radio-logtcal safety of the present activities at the West Valley, New York site.
These activities include the storage of spent fuel, the management of radioactive wastes, and the ongoing surveillance of the dormant reprocessing
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plant.
NFS maintains a staff of about fif ty people at the site to conduct these limited activities.
We have considered the impact of the failure of structures, systems and components important to the health and safety of the public and employees.
Such failure can be caused by human error or natural phenomena such as earthquake or tornado.
The staff concludes that because of the passive nature of the present activities in a plant designed for operation with a much greater risk potential there 's no undue risk to the health and safety of the public or to the employees.
This conclusion is based on the discussion in the previous sections. There are a number of long-term questions associated with the use of the site. Where pertinent in the evaluation, further actions are recommended which should be helpful in resolving these long-tarm questions.
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REFERENCES i
1.
Letter, R. E. Brooksbank to R. M. Bernero, dated November 9, 1976, Oak Ridge National Laboratory, Oak Ridge, TN..
4 2.
Safety Analysis Report, NFS' Reprocessing Plant, West Valley, N.Y.,
4 Docket No. 50-L01, 1973, Vol. III. p. X-3-3.
3.
Letter, David J. McCloskey to James E. Slider, dated March 24, 1977, Sandia Laboratories, Albuquerque, NM.
4 4.
NRC memorandum, C. R. Marotta to J. R. Milles, dated November 20, 1975,
Subject:
Fuel Storage Pool Dose Rate Estimates As A Result of a Criticality Incident.
5.
Letter, Nuclear Fuel Services, Inc., dated May 17, 1972, J. R. Clark to S. H. Smiley, Occket 50-201.
4 l
6.
Letter, J. R. Clark to Richard E. Cunningham, dated January 30, 1976, Re:
Letter from J. R. Clark, Nuclear Fuel Services, Inc., to Mr. Richard E. Cunningham, U.S. Nuclear Regulatory Commis ion, dated August 4, 1975.
7.
Draft report by Battelle Pacific Northwest Laboratories, " Technology, l
Safety and Costs of Decommissioning a Reference LWR Nuclear Chemical Separatione Facility." Tables A.5-6 and A.5-4.
i 8.
Draft reports by Los Alamos Scientific Laboratory and Lawrence Liver-i more Laboratory in preparation.
t 9.
W. S. Gregory, and G. A. Bennett, " Ventilation Systems Analysis During Tornado Condition," LA-5894-PR, March 1975, Los Alamos Scien-tific Laboratory, Los Alamos, NM.
I 10.
W. S. Gregory, "HEPA Filter Effectiveness During Tornado Conditions,"
LA-5352-MS, August 1973, 'Los Alamos Scientific Laboratory, Las Alamos, NM.
11.
Internal AEC memorandum, Leo Dubinski to John A. McBride, dated September 9,1965,
Subject:
Nuclear Fuel Services, Inc., West Valley, N.Y., License No. SN-857 and Construction Permit CPCSF-2, Docket No. 50201, Consultant's Report Providing Recommendations on Corrective Action to be Taken Relative to the Waste Tank Vaults 8-D-1 and 8-0-2.
12.
Letter, William J. Dircks to the Honorable Stanley N. Lundine, dated March 2, 1977.
(Response to Congressman Lundine's request for informa-tion on West Valley.)
=
- 13. Quarterly Report, Nuclear Fuel Services, Inc., for period April 1, 1976 through June 30, 1969.
14.
Safety Analysis Report, NFS' Reprocessing Plant, West Valley, NY, Docket No. 50-201, 1973, Vol. III, p..X-3-20.
15.
Letter, J. R. Clark to R. M. Bernero, dated May 24, 1977.
16.
Internal NRC memorandum, J. C. Stepp to W. Burkhardt, dated March 5, 1976,
Subject:
Seismology Position on SSE.
17.
Internal NRC memorandum, J. C. stepp to R. M. Bernero, dated April 6, 1977,
Subject:
West Valley, NFS Site.
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APPENDIX I SEISMIC RECURRENCE INTERVALS An important aspect in evaluating the safety of the West Valley site is the possibility of an earthquake occurring and causing damage or failure of safety related structures or equipment.
In April 1976, the staff concluded that the maximum earthquake appropriate to assume for design purposes at the site was a modified Mercalli intensity VIII earthquake occurring on the Clarendon-Linden structure (fault) 23 miles from the site.
The free field ground motion (peak horizontal acceleration) at the site from an earthquake of this size would be 0.2g.18 The Geosciences Branch has recently provided us with ir. formation on the relationship between the frequency of earthquakes and their size (magnitude, intensity or peak acceleration) for the West Valley site.17 Two curves of acceler-ation as a function of frequency (acceleration plotted on the abscissa) are shown in Figures a and b.
The curve of Figure a represents a fit to Central Stable Region earthquake histories from Intensities IV, VII and VIII.
The Figure b curve was fit to Intensities V, VI, and VII, and is more conservative than Figure a.
These curves are based on simple assump-l tions and are not considered rigorous.
They are considered to be conserv-ative estimates, however.
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.010 Figure a Less Consavative Estimate of Recurrence of Earthquake at West Valley, N.Y.
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NUCLEAR FUEL SERVICES - WEST VALLEY, N.Y.
1.
Licensees a.
Nuclear Fuel Services, Inc. - Lite operator Responsible for current operation of site b.
New York State Energy Research and Development Authority - Site owner Responsible for long-tem care of wastes c.
Low level Wasce Burial Ground licensed by NYS Department of Environmental Conservation 2.
Operating History i
a.
Licensed in April 1966 (18 months previsional) b.
Processed about 640 tonnes through April 1972
- 1) 380 tonnes Hanford "N" Reactor fuel
- 2) 245 tonnes power reactor fuel
- 3) 15 tonnes unirradiated fuel c.
Shutdown for modification and expansion 1972 d.
NFS withdrew from reprocessing September 1976 3.
Plant Status a.
Separations plant contaminated b.
High-level waste stored at site
- 1) 600,000 gallons neutralized waste a,arbon steel tanks
170 tonnes power reactor fuel stored in pool d.
Burial grounds
- 1) Low level closed voluntarily by NFS after discovery of surface water leakage
- 2) No leakage at high-level burial location 4.
Issues a.
Technical
- 1) Disposal scheme for high-level waste 2). Decontamination and disposition of facilities
- 3) Future use of burial grounds b.
Financial Responsibility for cost of decontamination, decommissioning and waste disposition c.
NYSERDA has requested DOE (ERDA) takeover of site 5.
NRC Actions a.
Published initial interim safety evaluation report on reduced activities, more to follow b.
Studies under way on earthquake and tornado effects c.
Requested DOE:
- 1) Look at risk of current waste storage
- 2) Provide technical support on high level waste disposition L
TECHNICAL REASONS FOR RAVING A DECOMMISSIONING PLAN AT THIS TIME (JANUARY 1978) 1.
The NFS plant has been contaminated as a result of previous operaticns. Some cells have been partially decontaminated, but considerable work remains to identify degree of contamination in other areas.
In general we only have the radiation levels from which one can estimate contamination levels.
The basic structure will not change. Wall penetrations are fixed; equipment locations probably will not change. Even if the plant finds some new use, it will be done in the existing building.
3.
NFS has intimate knowledge of the building - where the radio-activity is and how it got there. They would have a much superior notion about the best way to decontaminate and decom-mission.
4 We are, or will be, asking all licensees and applicants to provide a decommissioning plan prior to operation, before even being contaminated. There is a technical advantage in having' operated (and contaminated a building) in preparing plans for decommissioning.
5.
Preparing the plan does not mean it must be implemented. Although it should be prepared as though it wculd be implemented rather than be a " paper study".
6.
The sooner NFS gets to work on the plan the better, since loss of knowledgeable personnel and/or information will increase with time.
~
7.
The existence of a plan can sharpen perspectives on the cost of decanmissioning and be useful to Congress, NRC, DOE and others for consideration of alternative uses.
Knowledge of decontamination needs and associated costs is an essential element of a decommis-sioning plan.
8.
The insight provided by the NFS operators will be useful feedback -
in the development of NRC requirements for generic application.
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WEST VALLEY CONTRACTUAL ARRANGEMENTS (NFS) 1.
Base Load Contract with AEC (AT [38-1]-344)
The AEC agreed to deliver fuel to NFS for reprocessing._ NFS would also have to process commercial reactor fuel. Charges were $23.5K per ton.
2.
Facilities Contract (NFS & NYSERDA)
Essentially the contract to construct plant. NFS owns repr] cessing plant. ARDA (NYSERDA) owns everything else. NFS constructs every-thing (using Bechtel):
Fuel receipt and storage, waste storage, lagoons, maintenance shop, utility building, warehouse, and offices.
3.
Waste Storage Agreement (NFS & NYSERDA)
NFS constructs tanks on behalf of NYSERDA. Title rests with NYSERDA.
NFS has responsibiiity for eneration, surveillance, maintenance replacement, and insurance.
NFS can voluntarily surrender responsibility during " initial term" (to December 31,1980)..NYSERDA will assume authority 'if:
(a) tanks are in good condition (b) records are intact (c) there is ne contractual default (d) all licenses and permits are obtained (e) all payments are met (f) NFS pays $50K This " surrender" requires a writtea notice. The contractor L3ys that NYSERDA will cooperate fully with NFS "in achieving timely surrender."
i Requirements for " good ~ condition" (1) tank integrity not breached (2) the authority shall be permitted to conduct " reasonable tests" to insure integrity (3) spare facilities maintained and available (4) all working components functioning properly (5) NFS in compliance with legal requirements 4
(6) all storage parameters observed NFS paynents for S waste tanks
- cost <S4 M
- replacement fund:. (1) 23.3% of cost paid at completion of tank coni.ruction, or (2) quarterly payments equal to (1) by December 31, 1980 (including interest).
- maint2 nance fund:
5140K/yr to 12/31/80
- total in 1980 $4.8M
- additional payments required if tanks not in " good condition" i
Title to waste - NFS until surrender to NYSERDA
~
-Chemical. composition limits given in Schedule 1, part 4.
Schedule 2 requires waste records such as volume, concentration, heat load. Reports required monthly and quarterly.
l 4.
Lease 1
Includes land, waste facilities and FRS rent:
$660K/y (+ $2.2E/MT processed)
Required NFS to build plant on site New legal costs for (regulatory) requirements paid for by NYSERDA I
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Requires NFS to carry liability insurance
- $500K/ person injury
$2M for accident
_ $2M property damage i
1 NFS will "use its best effort to maintain" Price-Anderson 4,
coverage.
i Lease terminates if NFS " defaults" e.g., NFS must pursue operating license NFS must surrender facilities in " good order, condition and repair" NFS does not have to decontaminate if "normally" contaminated Upon termination of lease, plant shall Ebe and become the abso'ute, entire and exclusive property of the NYSERDAl 4
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