ML20036F240
| ML20036F240 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/07/1998 |
| From: | Robertson G WASHINGTON, STATE OF |
| To: | Bangart R NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML20036F238 | List: |
| References | |
| NUDOCS 9808240022 | |
| Download: ML20036F240 (7) | |
Text
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07 '98 01 36PM BDH PAD PPoVECTICri p,373
,r h...
I STATE OF WASHINGTON I
DEPARTMENT OF HEALTH DIVISION OF RADIATION PROTECTION 7171 Cleanwater lane, Bldg. 5
- P.O. Eos 47827
- Olympia, WasMngton 96504-7827 i
TDD Relay 1 800 833-6388 August 7,1998 l
Richard L Bangart, Director Office of State Programs i
U.S. Nuclear Regulatory Comnussion i
One White Flint North t
Washington, D.C 20555
Dear Mr. Bangart:
' Itis letter is in response to our telephone conversation in June 1998, regarding a potential request by the Department of Health in the review of the Portland General Electric (PGE)
Trojan reactor vessel pathway analysis. I had told you that when we were further along in i
our review of the pathway analysis, I would know if we needed. technical assistance from the NRC We have completed our review and are awaiting PGE's response to our comments (copy enclosed for your information), and do not feel that the NRC's technical assistance will be necessary after all. However, I am very grateful for your willingness to provide technical assistance in this matter.
If you have any questions, please feel free to contact me at (360) 236-3241.
Sincerely,
)
i Gary p. crtson, Head i
Wastb fanagement Section GR:krf Enclosure j
9808240022 9000t7 CF ADOCK 05000344 CF 1
ATTACHMENT 2 g
~
A.G 12 '99 SO:88AM DoH RAD PROTECTION P.2/5 i
STATE OF WAsHINCTON DEPARTMENT OF HEALTH l
DIV!sION OF RADIATION PROTECTION 7171 Cleamsater Lane, Bldg. S * !.O. Bos 47827 e Olympia. Wadington 98504-7827 rDD Relay 1 800-8334388 August 7,1998 l
t l
Lanny Dusek Portland General Elecuic 71760 Columbia Highway Rainier, Oregon 97048
Dear Mr. Dusek:
i After reviewing the submittal from Chase Environmental Group, Inc. regarding the disposal i
I of the intact rescor vessel from Portland General Electric, the following comments are provided for your review and reply:
j i
Comment #1:
i In severallocations in the document (e.g., Executive Summary, third paragraph), it is implied that the 200 Area plateau will not be released for future human habitation.
l While this assumption is probably correct, the state of Washington has not seer. nor l
heard of any official (e.g., US DOE) proclamation stating such. If such a document can be located, please submit it for our review.
Comment #2:
In Section 3.3.4.1, it is stated that the disposal site is located in an area of net l
deposition. The footnote in the PGE submittalis referenced the US Ecology Closure
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Plan, which makes the same supposition. Please cite the scienti5c studies that support this statement.
Comment #3:
In Section 3.3.4.1, it is stated that the long-lived radionuclides will decay before the stainless steelinternals oxidize. Is th2re any estimate as to ho ' long it would take to oxidize the internals?
Comment #4:
In Section 4.1.3 (page 35), it is assumed that complete mixing occurs when the leachate reaches the aquifer. Are there any radionuclides that remain strati 5ed in the groundwater (e.g., H-3) at the level where the proposed well would be screened?
ws G
AUG 21 98 20:18At1 DoH RAD PROTECTION P.3/5 Lanny Dusek Page 1 4
camment #5:
An onsite fanning scenario with the dwelling and drinking water / irrigation well above the reactor vessel needs to be developed for review, or described whyit is not appropriate.
i Comment #6:
I In Section 7.0, all references to 10 CFR 61 should be changed to WAC 246 250.
1 Comment #7:
Please provide figure and sample calculations that will support what is being described and how the percentages were determined in Atta^ ment A, Section 3.1.1, third paragraph (page 6).
j Comment #8-In Au=Amant B, there is significant discussion about the factors affecting corrosion.
l Emnlifying conditions are used in the discussionin a conservative manner. However, WDON is under the belief that the reactor vessel will be coated with the sarbe blue material that was applied to the steam generators. How does this coating affect the l
corrosion rate? Does it effectively preclude corrosion by preventing oxygen from j
ran^ing the vessel's surface? Or does it enhance the corrosion rate? Please provide t
sufficient references to substantiate your conclusions.
Comment #9:
In Atta^mant B, there is discussion about the various layers of soil and the moisture content, versus depth. After disposal of the reactor vessel, it is proposed that the vessel be immediately covered. WDOH assumes that the material used to backfill the vessel will essentially be a homogenous mixture of the soil removed in the cacavation of Trench 12. In order to evaluate the corrosion potential, it is necessary to determine the clay and silt content of this backfill material Please provide i
bannMng estimates of these percentages for the backfill material.
Comment #10:
In A*=^=ent B (page 5 and 6), parameters affecting the corrosion rate were based upon the levels of variables in the Faninrd groundwater. Since the vesselis to be buried in relatively dry soil, are there any soil. specific data from studies at Hanford?
Sparme=11y, what is the buffering capacity of the soil (mmol/kg), the sulfide content (in mg/kg), the snifar, content (mg/kg), the degree of horizontal and vertical homogeneity of the soil resistance (in ohm-cm), and the electrochemical potential (mV).
4 9
- AUG 2A '98 20:19AM DOH RAD PROTECTZON P.4/5 Ianny Dasek Page 3 Comment #11:
- In Attnehment B, Appendix A, page A-2, it is stated that magnetic particle orliquid penetrant will be used to verify the weld. Will any welds require a root weld and several subsequent build-up passes? Will radiography be used in these cases?
cnmm,nt #12:
In the analysis, there is no credit taken for corrosion potential of the low-density grout that will fill the internal voids of the vessel. While it should maintain the pH of the void space in the region (4<pH<10) where corrosion is independent of pH, l
it would be beneficial to determine (or cite a published paper) whether the grout will i
retard corrosion and oxidation, or promote it. Additionally, will the grout cause any pH excursions that will enhance the mobility of any isotopes within the vessel, in the l
event that water is present?
l Comment #13 In Artmehment C, page 7, the terms used in the equations must be defined.
Comment #14:.
In Att=chmant C, pages 15 and 16, the solubility assigned to C-14 and Tc-99 are not consistent with Hanford site documents (e.g., DOE RI/FS). Please re-evaluate the doses, using the solubility values from these Hanford sources.
Comment #15:
In At+= ehment C, Section 4.2, (page 30) last bullet, please demonstrate that 1900 feet is the correct distance for the "streamtube".
Comment #16:
In A1'*ehmant C, page 38, it is stated that Beatty and Hanford have reasonably simnar geology. Please substantiate this statement with a comparison of soil parameters that are criticalin the performance assessment.
Comment #17:
In At+=ehment C, page 45, Card 13, the FORT value is set equal to 03 and noted that this is trench porosity at the Hanford site. Since water transport parameters are critical, please substantiate this trench porosity value.
Comment #18:
In Attachment C, page 45, Card 13, the DENCON value is set equal to 2.0, based upon the PRESTO manual. Since the density of the undisturbed soilis 1.6 gm/cm',
- kJG 11 '98 10:19R1 DOH RAD PROTECTION P.5/5 i
_ Lanny Dusek Page 4 j
l l
and in view of the fact that low-density grout will be used, the selection of 2.0 needs to be substantiated.
Cnmment #19:
It should be noted that for leeching to occur, it appears that the most direct route i
(at least vertically) is through the 1/2" welds attaching the cover plates to the inlet / outlet nnntes. What kind of analysis has been performed and documented on the corrosion properties of the welds?
Comment #20:
By PGE's calculations, the C-14 and Tc-99 activities are predominantly located in l
core baffles, core formers, lower core barrel, and lower core plate. How was this l
determined? What computer code (s) were used to determine these activities? How i
were these codes validated for use in the Trojan reactor vessel?
l
~
Commant #21:
In Attechmant E, page 3, the last sentence should read
- the Intruder Residential l
Scenario."
l l
Comment #22:
Since the vessel has experienced some neutron embrittlement, this topic needs to be i
addressed.
i 1
If you have any questions regarding these comments, please do not hesitate to call me at l
I (360) 236-3241, or Earl Fordham at (509) 377-3869.
Sincerely, Wr C) d AJxtJthAMp/7 Gay R rison, Head Waste Management Section ec:
WDOH, Richinnr1 file A
e O
.; The Commissiorcrs,
r: view cnd his sent 1:chnical questions to U.S. Ecolcagy. In cddition, on August 7,1998, ths
,r State informed the staff that it did not intend to seek technical assistance from the NRC for the
(
review of the pathway analysis (Attachment 2). Although some NRC staff expressed a preference for the NRC staff to conduct an independent NRC review to confirm PGE's classification of the waste, the staff has reconsidered its plans and is not planning to co cian l
independent review of PGE's waste classification. Given the State's position declinin assistance from NRC, and the fact that Washington, as an Agreement State, has necessary competence and authority to review the U.S. Ecology submittal, use of NRC' imited resources to conduct a duplicative review is not warranted. The staff recognizes, as flected in SECY-97-244, that NRC has an independent role to assure that PGE properl lassifies the waste shipment. However, NRC's role does not oblige the staff to indepen ntly review PGE's waste classification documentation including the pathway analysis. The aff believes it can I
reasonably rely on the State's review of that documentation. T is the course the staff now plans to follow. While it is a change in approach from that d cribed in SECY-97-244, which was approved by the Commission, it is consistent with the pproach by which NRC performs its i
waste classification role for the vast majority of low-level aste shipments by NRC licensees.
)
The staff's review of the transportation aspects of P E's proposal will continue. After completing the transportation review, the staff int ds to transmit its conclusions along with the results of the Washington State review for Comjoission consideration by October 2,1998. If i
NRC were to conduct an independent review 'f the pathway analysis, the review would have to be initiated by August 26,1998, to avoid ne ative impacts on the PGE schedule for grouting the RV in December 1998 and shipping in A ust 1999.
The staff intends to proceed in accor nce with the change in plans described above and, thus, to refrain from conducting an inde ndent review of the pathway analysis from PGE's proposal, unless directed otherwise by the ommission before August 26,1998.
Attachments:
- 1. Ltr to J. L. Erickson did 30/98
Central File LLD r/f NMSS r/f PUBLIC DWM r/f PTrcssler HT ompson LCallan RJohnson NMSS Dir. r/f CPol nd O r/f i
gkd
- SEE PREVIOUS CONCURRENCE Pcth and File Name:. VESSEL 2.OGC OFC LLDPi*/ E OSP*
E OGC NRR*
E SFPO*
E DWM DWM)
NAME JHi y/cv PLohaus b 'bf JRoe SShankman MWeber e~ves DATE
/12/98 8/12/98 8f;/98 8/12/98 8/12/98 8/098 8//r/98 OFC / NMSS DEDR EDO j
NAMI CPaperiello HThompson JCallan DATE 8/ /98 8/ /98 8/ /98 OFFICIAL RECORD COPY l
ACNW:
YES _ NO _
Category: Proprietary _ or CF Only _
i IG:
YES _ NO _
LSS:
YES _ NO _
Delete file after distribution: Yes _ No _
The Commissioners to avoid negative impacts on the PGE schedule for grouting the RV in December 1998 and shippirigin August 1999. Although some NRC staff expressed concems about the need for an independent NRC review to confirm PGE's classification of the waste, the staff is not planninho conduct a review of the proposed disposal because of resource constraints, the State's' position declining assistance from NRC, and the fact that Washington, as an Agreernent State, has the necessary competence and authority to review the U.S. Ecology submbl.
The staffs review of the transpor\\
tation aspects of PGE's proposal will continue. After s
completing the transportation review, thbqtaff intends to transmit its conclusions, along with the results of the Washington State reWew, for Commission consideration by early October 1998.
Attachments:
- 1. Ltr to J. L. Erickson did 1/30/98
- 2. Lir to R. L. Bangart did 8/7/98 cc: OGC SECY
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'N OPA
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OlG
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TICKET: N/A DISTRIBUTION:
Central File LLDP r/f NMSS r/f PUBLIC DWM r/f PTressler HThompson LCallan RJohnson NMSS Dir. r/f CPoland EDO r/f Path and File Name:A:tTROJAN.JW OFC L{Dk E
_OSP L
SFPO E.
DWM DWM
.w
,. u u.,
anp NAME JHickey/cv i c/4 1,ech;J A c 4 M' MWeber JGreeves 7
DATE 8/d/98 8/l498 8/ /98 8////98 8/W98 8/ /98 8/ /98 OFC NMSS DEDR EDO NAME CPaperiello HThompson JCallan DATE 8/ /98 8/ /98 8/ /98 OFFICIAL RECORD COPY ACNW:
YES _ NO _
Category: Proprietary _ or CF Only _
IG:
YES _ NO _
i LSS:
YES _ NO _
Delete file after distribution: Yes _ No _
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