ML20040B253

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Forwards Updated Sys Descriptions, Standby Reactor Coolant Pressure Control Sys & Fuel Pool Waste Storage Sys (Tank Farm), Technical Evaluation Rept for Interim Solid Waste Staging Facility
ML20040B253
Person / Time
Site: Crane Constellation icon.png
Issue date: 01/20/1982
From: J. J. Barton
GENERAL PUBLIC UTILITIES CORP.
To: Dnyder B
Office of Nuclear Reactor Regulation
Shared Package
ML20040B254 List:
References
4400-82-L-0009, 4400-82-L-9, NUDOCS 8201250313
Download: ML20040B253 (1)


Text

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GPU Nuclear UC Gar P.O Box 480 Middletown, Pennsylvania 17057 717-944-7621 Wnter's Direct Dial Number:

January 20, 1982 Q

4400-82-L-0009 C

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TMI Program Office g3 g 2 Z 1982* $

Attu:

Dr.

B. J.

Snyder, Program Director p erc n s U. S. Nuclear Regulatory Commission

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f Washington, D.C.

20555 9

Dear Sir:

/

ro Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Recovery System Description and Technical Evaluation Report Update Your letter of July 20, 1981 requested that we provide periodic updates of Technical Evaluation Reports (TER's) and System Descriptions for major post-accident recovery systems.

Enclosed are updated System Descriptions for the Standby Reactor Coolant Pressure Control (SPC) System and the Fuel Pool Waste Storage System (Tank Farm) and the Technical Evaluation Report for the Interim Solid Waste Staging Facility.

As discussed with Dr. R.

R. Bellamy, of your staff, System Descriptions for the Mini Decay lleat Removal (MDliR) System, the Auxiliary Building Emergency Liquid Clean-up System (EPICOR-II), the Submerged Demineralizer System (SDS),

and the Interim Solid Waste Staging Modules are undergoing internal review and approval and will he provided to you as they become available, with all of the System Descriptions listed above provided by March 1, 1982. Addition-ally, the Technical Evaluation Report for the SDS is being updated to include Reactor Coolant System Processing and will be provided to you by April 1, 1982.

Additionally, the requirement of updating these System Descriptions and Technical Evaluation Reports every six(6) months as stated in your letter of July 20, 1981 is inconsistent with the one(l) year frequency for FSAR updates required by 10CFR50.71. Therefore, we request that the frequency for the System Descriptions and Technical Evaluation Report updates he reduced to once per year.

If you have env further questions, please contact Mr. J. E. Larson, of my staff.

Sincerely, R

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$f 8201250313 020120 A

PDR ADOCK 05000320

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Harton I-P PDR Ac.

g Director, TMI-2 h

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Attachment A

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L. 11. Barrett, Deputy Program Director b'

GPU Nuclear m a part of the General Pubhc Utihties System

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13587-2-G03-105 t.

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TECHNICAL EVALUATION REPORT i

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1 INTERIM SOLID WASTE STAGING, FACILITY 1

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THREE MILE ISLAND - UNIT 2 t

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Bechtel Northern Corporation i

l Bechtel Job 13387 I

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May 1981 1

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R REVISION STATUS SHEET JOB / GROUP 13587 REV.

2 DISCIPLINE I

Technical Evaluation Report for Nuclear 3

Interim Solid Waste Staging Facility

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DOCUMENT TITLE:

PAGE 1 OF 1

13587-2-G03-105 TABLE OF CONTENTS M

1.0 INTRODUCTION

1-1 1.1 General 1-1 1.2 Organization of Report 1-1 I

1.3 Conclusion 1-1 2.0 FACILITY DESCRIPTION 2-1 2.1 Purpose of the Facility 2-1 2.2 Summary Description e' 2-1 1

2.2.1 Location 2-1 2.2.2 Design Basis 2-1 2.2.3 Building Description 2-1 2.2.4 General Arrangement 2-2 7

2-3 2.3 Major Systems i

2.4 Material Handling Operations 2-3 2.4.1 Description of Packages 2-3 2.4.2 Unloading and Stacking of the Packages 2-4 2.4.3 Removal of Packages 2-4 Table 2-1 Design Storage Requirements Figure 2-1 Recovery Facilities Plan Figure 2-2 ISWSF General Arrangement l

3.0 TECHNICAL EVALUATION

3-1 l

3.1 Licensing Issues 3-1 3.2 Dose Assessment 3-1 3.2.1 Off Site 3-1 j

3.2.2 On Site 3-5 3.3 Occupational Exposures 3-5 j

3.3.1 Design Features 3-6

)

3.3.2 Man-Rem Estimate 3-6 Table 3-1 Area Radiation Levels with Six Months Design Basis Inventory 4.0 COMPARISON WITH PROGRAMMATIC ENVIRONMENTAL 4-1 IMPACT STATEMENT (PEIS)

Table 4-1 Contents of Staging Facility i

Rev. 0

13587-2-G03-105 5.0 SAFETY EVALUATION 5-1 5.1 Technical Specifications 5-1 5.2 Unreviewed Safety Question 5-1 11 Rev. O

13587-2-G03-105 e

1.0 INTRODUCTION

1.1 General The cleanup effort at Three Mile Island Unit 2 is expected to result in the generation of a significant quantity of low level (Note 1) solid or solidified radioactive waste.

In addition, low level solid or solidified radioactive waste is also being generated in Unit 1.

Due to limitations on low level radioactive waste disposal sites and limited onsite staging capacity, an additional facility for the collec-tion and temporary staging of low level solid or solidified radioactive waste is needed.

The facility proposed to fulfill the need identified above is the Interim Solid Waste Staging Facility (ISWSF).

This Technical Evaluation Report (TER) demonstrates that the ISWSF has been designed and will be operated in such a manner as to provide assurance that:

The health and safety of the public will be protected.

a.

Occupational exposures will be as low as reasonably b.

achievalle (ALARA).

There will be no adverse impact on the environment.

c.

1.2 Organization of Report This report is organized in the format of a combined safety analysis and environmental report. Following this introduction, a description of the design and operational considerations is presented.

This is followed by a discussion of the safety and environmental issues associated with the facility. A comparison of the ISWSF design with the The report Programmatic Environmental Irpact Statement is presented next.

concludes with the safety evaluation required by 10 CFR 50, paragraph 50.59,

" Changes, Tests, and Experiments."

1.3 Conclusion The information provided in this report results in the following conclusions:

The ISWSF fulfills the need for a facility in which a.

to temporarily stage low level solid or solidified radioactive waste.

As used herein the term " low level" refers to the dose rate on Note 1.

The contact with the waste packages as defined in Table 2-1.

term gives no indication as to the isotopic or elemental content of the package.

Rev. O 1-1

13587-2-G03-105 b.

The operation of the facility is not an unreviewed safety question as defined in 10 CFR Part 50, para-graph 50.59.

i 1-2 Rev. 0

13587-2-G03-105

' FACILITY DESCRIPTION 2.0 Purpose of the Facility

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2.1 The ISWSF is to be used for the staging of low level solid or solidified radioactive waste packages from both Units 1 and 2 The packages will be staged in prior to shipment offsite for disposal.

the facility for up to 2 years.

2.2 Summary Description 2.2.1 Location As shown on Figure 2-1, the ISWSF is located east of the l

Unit 2 turbine building and between the offsite transmission lines for j

It is surrour.ded by an outer fence which aids in restricting Unit 2.

Access to the l

access to the area immediately surrounding the facility.

area enclosed by the outer fence will be controlled by established plant The only activities occurring within this area will be j

procedures.

those associated with the ISWSF.

l 2.2.2 Design Basis The ISWSF has no safety design basis.

i The facility is designed to provide a controlled but ready access for material handling operations to ensure that operator exposures are as low as is reasonably achievable (ALARA). The facility is sized to I

The accommodate the wastes generated in 6 months from Units 1 and 2.

monthly waste generation rates used in the design are given in Table 2-1.

In addition, the ISWSF is designed to maintain the dose rate at the outer fence surrounding the facility at 0.6 mrem /hr, in 4

accordance with 10 CFR Part 20, paragraphs 20.105(b)(2) and 20.202(a)(1).

190 The facility is also designed to meet the requirements of 40 CFR Part at the site boundary and beyond.

r.

2.2.3 Building Description The ISWSF, shown in Figure 2-2, is a non-seismic Category I, Shielding concrete floor slab, covered by a prefabricated metal roof.

partitions of grout-filled concrete masonry units are used to satisfy A roof is provided the dose rate criteria specified in Section 2.2.2.

to minimize the volume of rainwater entering the facility which could potentially become contaminated and thus require monitoring and I

ing.

weather conditions.

An 8-inch-high curb is provided around the perimeter of the floor slab to contain any rainwater that may enter the building.

The Ramps are provided to allow passage of a forklift over the curb.

floor slab is sloped so that any water entering the facility will be With the use of portable directed toward one of the six sumps provided.

pumps, water collected in these sumps will be disposed of in accordance Rev. 0 2-1

2}587-2-G03-105 with established plant operation procedures. The sumps are provided with manually actuated heaters to facilitate disposal of collected water l3 during the winter.

The floor slab, sumps, and curb are epoxy coated for ease of decontamination should the need arise. The exposed structural steel columns in the storage areas are also epoxy coated to a height of 8 inches for compatibility with the curb. The remaining portions of the steel columns and the roof framing have a protective finish. The shield-ing partition surfaces facing the storage areas are epoxy coated to a height of 8 inches and painted with a sealer above 8 inches. The outside surfaces of the partitions are painted with a sealer.

In addition to the outer fence surrounding the area around the ISWSF, there is an 8-foot-high inner fence provided around the unwalled sections of the facility (see Figure 2-2).

With the exception of small quantities of electrical cable associated with electrical power and the in-plant paging system, all materials used in the construction of the facility are noncombustible.

2.2.4 General Arrangement The ISWSF consists of six basic areas:

(1) loading /

unloading, (2) survey, (3) open staging, (4) Unit I shielded staging, (5) Unit 2 shielded staging, and (6) personnel monitoring / analysis. A discussion of these areas follows. The general arrangement of the facility is shown in Figure 2-2.

2.2.4.1 Loading / Unloading Area The loading / unloading area consists of a truck bay, a ramp into the facility, and an area for the loading and unloading of a standard flatbed trailer or enclosed van by a standard forklift.

2.2.4.2 Survey Area A survey area is provided to allow for radiation surveys of the waste packages prior to placing them on a truck for shipment off site. This area is separated from the truck bay and the open staging area by shield partitions.

2.2.4.3 Open Staging Area The open staging area is separated from the survey area by a shield partition. For administrative purposes, it is divided into a section for Unit I wastes and a section for Unit 2 wastes. The Unit I and Unit 2. areas are flexible and shown in Figure 2-2 for illustration.

These areas may vary throughout the life of the facility. These sections are separated by a portable barrier consisting of stanchicus connected by a chain. Access routes, or aisles, with gates at the entrance, allow for the movement of the containers by a forklift to the appropriate area.

l 2-2 Rev. 3 i

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13587-2-G03-105 It should be noted that the segregation of wastes by unit is not required by federal regulations. Rather, it is solely for utility administrative purposes.

2.2.4.4 Shielded Staging Areas Shielded staging areas are provided in order to meet the dose rate limits specified in the design basis, Section 2.2.2.

Separate shielded areas are provided in order to maintain separation between wastes from each unit. Access to these areas is by means of the aisles identified in Section 2.2.4.3.

Access will be controlled by administra-tive procedures.

2.2.4.5 Personnel Monitoring / Analysis Area The personnel monitoring / analysis area is a small cubicle at the end of the loading / unloading area. This area contains equipment J

for personnel monitoring and for the analysis of swipe samples of the waste packages.

2.3 Major Systems The only systems provided for the operation of the ISWSF i

are electrical power for lighting, receptacles, sump heaters, and the l3 in plant paging system. None of these systems serve any safety-related function.

No radiation monitors are provided in the facility.

i This is because the facility is a radiological controlled area and access is controlled at the outer fence.

2.4 Material Handling Operations 2.4.1 Description of Packages l

The packages to be staged in the ISWSF are of several types. These are described below.

Four 55-gallon drums of compacted trash and/or solidi-fied radiac waste will be placed on 4-foot by 4-foot pallets. Depending on the weight.of each drum, they may be banded together.

A single 50-cubic-foot liner of solidified evaporator bottoms will be placed on a 4-foot by 4-foot pallet. The dimensions of the liner are 4 feet in diameter and 4 feet high.

There will also be metal LSA boxes containing cc.mpacted trash satisfying the requirements of 10 CFR Part 71.

The dimensions of the LSA boxes are 4 feet x 4 feet x 7 feet. These boxes will arrive at the facility with a spacer between each box to allow a forklift to readily lift the box.

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13587-2-G03-105 All waste packages received in the ISWSF will be com-pletely prepared for shipment. All counting, swiping, decontamination, and weighing will be done prior to the transfer of the pact. ages to the ISWSF. Provisions have been included in the design of the ISWSF to allow additional counting and swiping in the ISWSF.

2.4.2 Unloading and Stacking of the Packages The packages of waste will arrive at the ISWSF on either a standard flatbed trailer or in an enclosed van. Upon arriving at the facility, the vehicle containing the waste will be parked in the truck bay located in the loading / unloading area. At this point a 3,000-pound to 5,000 pound capacity forklift will unload the packages and transport them to the proper area of the facility.

Upon arriving at the proper location within the facility, the packages will be stacked. The pallets and boxes will be stacked no more than three high, which is consistent with current GPUSC practice.

In general, the pallets will be stacked in a staggered manner. The LSA boxes will be stacked one on another with spacers.

The required lif t height of approximately 10 feet is well within the 16-foot lifting height of the forklift. The capability of the pallets to carry the load has been checked for the design basis arrangement and has been found acceptable. The pallets are of four stringer design, with solid planking top and bottom.

2.4.3 Removal of Packages When a package is removed for shipment, the reverse of the procedure described in the previous section will be followed.

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13587-2-G03-105 TABLE 2-1 DESIGN STORAGE REQUIREMENTS l

Quantity Container /

Unit (per month)

Trash Type Radiation Level 1

37 55 gal drum / compacted trash up to 50 arem/hr 1

19 55 gal drum / compacted trash 50 to 100 mrem /hr 1

15 55 gal drum / compacted trash 100 to 200 arem/hr 1

4 55 gal drum / compacted trash 200 - 400 arem/hr 1

1 4'x4'x7' box / compacted trash up to 200 arem/hr 1

10 50 ft3 liners / solidified evaporator bottoms 200 - 500 mrem /hr 2

9 55 gal drum / solidified radiac waste up to 100 arem/hr 2

16 55 gal drum / compacted trash 0 to 1 arem/hr 2

6 55 gal drum / compacted trash I to 2 arem/hr 2

11 55 gal drum / compacted trash 2 to 5 arem/hr 2

9 55 gal drum / compacted trash 5 - 20 mrem /hr l

2 5

55 gal drum / compacted trash 20 - 100 arem/hr 2

2 55 gal drum / compacted trash 100 - 500 mrem /hr 2

1 55 gal drum / compacted trash 500 - 1000 arem/hr 2

1 55 gal drum / compacted trash 1000 - 2000 arem/hr 2

2 4'x4'x7' LSA boxes 0 - 1 arem/br i

2 2

4'x4'x7' LSA boxes 1 - 2 mrem /br 2

3 4'x4'x7' LSA boxes 2 - 10 arem/hr 2

3 4'x4'x7' LSA boxes 10 - 20 arem/hr 2

3 4'x4'x7' LSA boxes 20 - 100 arem/hr 2

1 4'x4'x7' LSA boxes 100 - 200 ares /br Rev. 0

13567-2-G03-105 3.0 TECENICAL EVALUATION This section summarizes the licensing issues which were considered in the design of the ISWSF. These issues deal with the expected performance of the facility during normal operation and various design basis events.

3.1 Licensing Issues The licensing issues associated with the operation of the ISWSF are:

Demonstrating compliance with 40 CFs Part 190 with a.

respect to offsite doses.

4 b.

Demonstrating c'ompliance with 10 CFR Part 20 with respect to onsite dose limits.

Demonstrating that the design basis events for the c.

facility have been properly considered. The design basis events for this facility are high winds, OBE, fire, and flooding.

d.

Demonstrating compliance with the principles of ALARA.

Each of these issues is addressed in the following sections.

3.2 Dose Assessment The ISWSF is designed so that during normal operation (1) the requirements of 40 CFR Part 190 are met at the site boundary and beyond, and (2) the dose rate at the outer fence is limited to 0.6 mrem /hr or less.

In addition, the consequences of design basis events have been evaluated to assure that public use of areas beyond the exclusion areas is not interrupted or restricted.

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l This section presents the analyses that demonstrate the above objectives are met.

3.2.1 Off Site 3.2.1.1 Normal Operation The total annual offsite dose from the site to any individual is limited to 25 arem by 40 CFR Part 190. The nearest' site boundary foy-the ISWSF is the normal high water mark on the east bank of the island.

3-1 Rev. O

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13587-2-G03-105 As applied to the site boundary, the 40 CFR Part 190 limits equate to a 0.3 arem/hr dose rate based on a 67 hr/yr occupancy (Note 2) with an 8C percent contribution factor (80 percent of the total 1

25 arem). As explained in Section 3.2.2 the dose rate at the fence inside the site boundary, and approximately 240 feet from the ISWSF, is below 0.6 arem/hr. The dose rate at the %ite boundary at the normal high water line of the river will be much less than the 0.3 arem/hr allowable, due to the shielding effect of the flood protection dike.

In addition to satisfying 40 CFR Part 190 at the site boundary an analysis was performed to determine the dose resulting from the ISWSF at the nearest residence. The dose at the nearest residence, located approximately 1550 feet ENE of the facility, was determined to be 13 mrem /yr.

A general purpose gamma ray scattering code was used to determine the annual dose from direct and scattered radiation at the 4

3 nearest residence. The code used was the G-33 version of "G : A General Purpose Gamma-Ray Scattering Program," described in Los Alamos Scientific Laboratory publication LA 5176, dated June 1973.

l The calculation of the dose rate at the nearest residence I

included the following considerations:

The ISWSF was assumed to contain the waste generated l

a.

in six months at the monthly generation rates given i

g in Table 2-1.

b.

The predominant radionuclide encountered in the Unit 2 containment, Cesium-137, was assumed to be the source of radiation in all waste packages.

The factor of 0.7 specified in Regulatory Guide 1.109, c.

Revision 1, was used to account for shielding and occupancy characteristics at the nearest residence.

3.2.1.2 Design Basis Events Design basis events considered were high winds, an operating basis earthquake, a fire, and flooding.

3.2.1.2.1 High Winds l

From the THI-2 FSAR the design wind velocity, based on the 100-year recurrence interval, is 80 miles per hour at 30 feet above grade. A review of the waste pack ges in the ISWSF resulted in the determination that the only waste packages that may move when subjected to the design basis wind were the drums of compacted trash located in the open staging areas.

It was determined that a single 55-gallon drum weighing less than 250 pounds might move under design wind conditions.

l Note 2.

Regulatory Guide 1.109, Rev. 1, Table E-5 Page 40--Recommended values for the maximum exposed individual in lieu of site-specific l

data, l

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3-2 Rev. 0 i

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13587-2-G03-105 Host drums are expected to weigh more than 250 pounds.

As noted in the " Recovery Quarterly Progress Report for the Period Ending September 30, 1980," the average weight of 55-gallon. drums con-taining compacted trash is 315 pounds.

It was determined that drums weighing less than 250 pounds can be strapped together in groups of four, so that their total weight is greater than 600 pounds, thus pre-venting their movement under high wind conditions.

Administrative procedures will be written to assure that drums will be heavy enough to prevent their movement by design wind forces.

Although the movement of drums in the unshielded por-tions of the ISWSF will be precluded as noted above, an analysis of the radiological consequences of high wind conditions was made. The resulting maximum dose to the public from the postulated airborne release was less than 0.01 arem for the inhalation pathway. The following considerations l2 were made in this analysis:

All drums containing compacted trash in the unshielded l2 o

portions of the ISWSF were assumed to be damaged by the high wind forces.

The predominant radionuclide encountered in the Unit 2 o

containment, Cesium 137, was assumed to be the source of radiation in all waste packages. Approxi-mately 12 curies of Cesium 137 are estimated to be contained in the drums of compacted trash in the 2

unshielded portion of the ISWSF. Since Strontium 90 is also present in the containment, the drums were assumed to contain an additional 1.2 curies of strontium.

o A release fraction of 10 4 of the contents of the damaged drums was assumed based on extrapolation of data presented in " Environmental Survey of Transporta-tion of Radioactive Materials to and from Nuclear Power Plants," december 1972.

The release was assumed to occur over a one-hour o

period.

An atmospheric dilution factor of 2.4 x 10~5 o

3 sec/m was used, based on an 80 mile per hour wind and a distance of 1150 feet from the ISWSF to the nearest 2

boundary of the exclusion area.

Stability Clast D conditions were assumed with no credit taken for building wake effect.

3.2.1.2.2 Operating Basis Earthquake (OBE)

In the event of an OBE, the ISWSF may collapse; however, the radioactive waste packages would remain in the general area of the 2

facility. The resulting maximum dose to the public from a postulated 3-3 Rev. 2

13587-2-G03-105 airborne release would be less than 0.03 mrem for the inhalation path-The following considerations were made in this analysis:

way.

All drums containing compacted trash and all LSA o

boxes in the facility were considered as a potential source of an airborne release.

The estimated content of these drums and boxes was o

81 and 8.1 curies of Cesium 137 and Strontium 90, respectively.

~6 of the contents of the A release fraction of 10 o

drums and boxes was assumed, based on the data presented in " Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants," December 1972.

4 3

The atmospheric dilution factor of 8.1 x 10 sec/m o

was used, based on a Stability Class F, 1 m/sec wind speed, and 1150 feet to the nearest boundary of the exclusion area. No credit was taken for the building wake effect.

3.2.1.2.3 Fire A fire in the ISWSF will not result in the release of radioactive material. This is based on having all the radioactive material in sealed metal containers or fixed in place such that radio-nuclides cannot become airborne.

In addition, the amount of combustible material, the wooden pallets and small amounts of electrical cable, exposed to an ignition source is insufficient to burn through a container.

Also, based on available information regarding the contents of the waste packages, spontaneous combustion within a container will not occur.

3.2.1.2.4 Flooding The Three Mile Island site is protected against a design 1,100,000 cfs flow in the Susquehanna River. This protection flood of is furnished by the site diFe, which has a minimum elevation of 304 feet aleng the southern end of the island. In the event of a design flood, which is equivalent to a river level of approximately 300.5 feet, the drainage culvert gate at the southeast dike will close, isolating the site storm drain sys*.em from the river.

Consequently, the TMI site design flood will have no adverse impact on the ISWSF.

In the event of a probable maximum flood (PMF), the river flow rate will slowly increase to the calculated maximum of 1,625,000 The cis. As the river level increases it will overtop the south dike.

water level on the island will then rise to a maximum PMF flood height of 308.5 feet. As noted in Figure 2.4-7 of the THI-2 FSAR, an advance 3

warning of at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> will precede the arrival of PMF.

3-4 Rev. 3

a 13587-2-G03-105

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1 The ISWSF is not protected against the PMF; therefore, the ISWSF will be inundated in the very unlikely event a PMF occurs.

The following discussion addresses the possible offsite releases of radioactive materials that could result from submergence of radioactive waste drums and boxes.

Since the waste packages are sealed and ready for offsite shipment, they will resist water intrusion.

Should the waste packages leak, releases would be minimal due to the absence of a driving force for release except for diffusion of radionuclides in water. Therefore, in light of the extremely low probability of occurrence of the PKF (recurrence interval greater than 100 years) and the expected minimal leakage into the waste packages, the design of the ISWSF regarding flooding is considered to be adequate.

3.2.2 On Site The dose rates at the outer fence surrounding the ISWSF were calculated to ensure that the values are less than the 0.6 mrem /hr in accordance with 10 CFR Part 20.

This was done by calculating the gamma dose rates from a planar source to a point at a given distance from the source.

The major assumptions made in the performance of this analysis were:

The only contributing isotope was Cesium-137.

a.

b.

All waste packages were at the maximum contact dose rate given in Table 2-1.

The facility was assumed to contain the waste generated c.

in six months, based on the generation rates given in Table 2-1.

The resulting dose at the outer fence surrounding the ISWSF is calculated to be less than 0.6 arem/hr.

Although the dose rates at the fence have been determined to be less than 0.6 mrem /hr, this is based on the information presented in Table 2-1.

In order to allow for deviations from this list, a radia-tion survey will be performed whenever the quantity or arrangement of packages in the ISWSF is significantly altered to ensure that the dose rate at any given point around the outer fence does not exceed 0.6 mrem /hr.

3.3 Occupational Exposures Use of the ISWSF will result in occupational radiation exposure to personnel. The operational and maintenance activities to be performed in the facility have been evaluated to determine the length of time workers will be exposed to a radiation environment. This informa-tion has been combined with expected radiation fields in the ISWSF to 2

3-5 Rev. 2

13587-2-G03-3D5

-e arrive at a projected annual exposure of from 17 to 22 man-rem for this facility. Of this exposure, approximately 80 percent is attributable to j

radioactive waste originating in Unit 1.

3.3.1 Design Features Several design provisions have been included in the ISWSF to minimize occupational exposures. These provisions include segregation of waste with higher radiation levels from those with lower radiation levels, use of shielding, and other provisions as noted below.

The arrangement of the ISWSF allows containers to be stored in the low radiation (unshielded) sections of the facility without entering the higher radiation (shielded) sections. The shield wall between the truck loading / unloading area reduces the dose rate in this area from the material in storage.

A roof has been provided for the facility to minimize the intrusion of rain water which must be collected and sampled prior to disposal. The sumps have been designed so that the shielded areas need i

not be entered to pump the sumps.

1 Location of the forklift truck aisles on the outside of the facility rather than using a single central aisle results in a lower l

radiation field at the aisle.

(

3.3.2 Man-Rem Estimate The duration of activities occurring in the ISWSF was estimated by considering the number of radioactive waste packages to be 1

placed in the facility. Factors considered in the analysis of time spent in the radiation area included the following:

55-gallon drums are handled by an unshielded fork-a.

lift in groups of four drums on a single pallet.

The drums are stored on the pallet.

3 containers are handled one b.

LSA boxes and the 50 ft at a time by the forklift.

The speed of the forklift was assumed to be three c.

miles per hour except when maneuvering to pick up or store a load.

d.

Approximately one-half the time the forklift is in operation it is not carrying a load. This accounts j

for the return trip to or from the loading / unloading area to the staging areas to pick up another load.

4 i

e.

Two forklift breakdowns per year in the radiation areas were assumed.

3-6 Rev. 2 2

13587-2-G03-105 f.

Allowances for time spent in the radiation area by other than the forklift operator were made to account for the shipment vehicle driver, health physics technician, and a laborer to assist the~ forklift operator.

An allowance has been made for relocating containers g.

within the facility.

The radiation fields in which the activities in the ISWSF occurred were estimated using the number of radioactive waste packages in the facility, and the dose rate of each package. Factors considered in the determination of the radiation fields included the ic11owing:

a.

The LSA boxes were assumed to be planar sources, with the dose calculated on a perpendicular to the plane at the desired distance, b.

For cylindrical containers, the source was modeled as an infinite cylinder and only cylindrical spread-ing was assumed, No credit was assumed for the shielding effect of c.

the content of one container on an adjacent container 3

except in the case of solidified waste in 50 ft liners.

d.

The ISWSF was assumed to contain a six ionth inven-a tory of containers at all times.

The area radiation levels calculated for the various areas in the ISWSF are given in Table 3-1.

The man-rem assessment combined the radiation fields described above with each of the handling, maintenance, and vehicle survey activities. The evolutions evaluated included transit of a loaded vehicle from Unit 1 or Unit 2 to the ISWSF, placing the con-tainers in storage, removing the containers from storage to the shipment vehicle at a later point in time, and a health physics survey of the shipment vehicle.

Assuming that the man-rem exposures from the ISWSF activities control the number of workers required to conduct material handling operations, the following approximate number of personnel would be required for the operation of this facility during the year:

3-7 Rev. 2 2

13587-2-G03-105 Number of Dose per Function Workers Worker Health Physics

.1

.5 rem Technicians Forklift Operators 4

4 rem (max.)

All other functions 1 equivalent 5 rem total (laborers, truck worker drivers, maintenance personnel) l l

l2 3-8 Rev. 2

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13587-2-G03-105 TABLE 3-1 i

AREA RADIATION LEVELS WITH SIX MONTHS DESIGN BASIS INVENTORY Radiation Area Level (arem/hr)

Survey Area 0.5 Open Staging Area l

Unit 2 LSA boxes 60 Unit 2 drums 180

.e Unit 1 drums 180 Shielded Staging Area Unit 1 1600 Unit 2 1170 l.

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j 13587-2-G03-105 1

COMPARISON WITH PROGRAMMATIC ENVIRONMENTAL IMPACT 4.0 STATEMENT (PEIS)

Section 9.2.1.1 of the PEIS describes a facility The for the temporary storage of certain low level radioactive wastes.

contents of the facility are given in Table 4-1.

The radiation levels at the fence surrounding the facility will be less than 0.6 arrm/br.

This facility is judged in Section 9.5.1.2 of the PEIS to have negligible environmental exposures to the general population.

There are some minor differences between the ISWSF described in this report and the facility described in the PEIS.

These differences are primarily in the number of containers to be stored in the ISWSF. Table 4-1 contains the design basis contents of the ISWSF. However, as shown in this report, the ISWSF will result in negligible environmental exposures to the general population.

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1 CONTENTS OF STAGING FACILITY 4

1 1

PEIS Facility ISWSF 55-Gallon Drums 800 810 LSA Boxes 150 90 (4 ft x 3 ft x 6 1/2 ft)

(4 ft x 4 ft x 7 ft) wooden metal il 3 Liners 60 60 50-ft 1

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13587-2-G03-105

- o 5.0 SAFETY EVALUATION 10 CFR 50, paragraph 50.59, " Changes, Tests, and Experi-ments," permits the holder of an operating license to make changes to i

the facility provided the change does not involve a modification of the plant technical specifications and the change is determined not to be j

an unreviewed safety question. As summarized below, the operation of the ISWSF neither requires a modification to the plant technical specifi-cations nor is it deemed to be an unreviewed safety question as defined i

in 10 CFR 50, paragraph 50.59.

5.1 Technical Specifications There are no Recovery Technical Specifications regarding the storage of solid or solidified radioactive waste. The proposed change does not require any additional technical specifications in order to satisfy the licensing basis of the plant. Therefore, the operation of the ISWSF does not require changes to the existing technical specifi-cations.

5.2 Unreviewed Safety Question The operation of the ISWSF will not increase the prob-ability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report. This is based on the location of the facility being such that there is no interface with existing safety-related equipment or structures.

The possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report will not be created by the operation of the ISWSF. This is due to the passive nature of the facility and the fact that all the radio-active waste is in either a solid / solidified or fixed form.

As stated in Section 5.1, the operation of the ISWSF will not result in a reduction in the margin of safety as defined in the basis for any technical specification.

Based on the above, the operation of the ISWSF is deemed not to be an unreviewed safety question as defined in 10 CFR 50, para-graph 50.59.

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