ML20045F272

Rev 10 to TER for Interim Solid Waste Staging Facility

ML20045F272
Person / Time
Site:	Crane
Issue date:	06/18/1993
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20045F265	List: ML20045F264 ML20045F272
References
3230-008, 3230-008-R10, 3230-8, 3230-8-R10, NUDOCS 9307070159
Download: ML20045F272 (24)

Text

{{#Wiki_filter:i Nualear TER 3230-00s ggy 10 June 1b93 l ISSUE DATE G sis-O won i O wits DIVISION t TECHNICAL EVALUATION REPORT FOR INTERIM SOLID WASTE STAGIt!G FACILITY DATE f M 8 8 / COG ENG <dA' /Jb)E2 RTR DATE O E7 DATE COG ENG MGR. ~ V E 3 5 E l' 24 DOCUMENT PAGE OF 9307070159 930629 TP) DR ADOCK 0500 0

ENuclear l2i008 INTERIM SOLID WASTE STAGING FACILITY Page , of '4 3 TECHNICAL EVALUATION REPORT Rev.

SUMMARY

OF CHANGE Approval Date 0 No History Available 1 No History Available [fg 2 No History Available h[ 3 Reissue per GPU Nuclear Letter 4410-82-L-0009. [ I 1/82 ~ 4 Reissue per GPU Nuclear Letter 4410-83-L-0020. [ 7/83 5 Revise and reissued per ECA 3184-84-0030. b l I 6 Revised and reissued incorporating comments on Rev. 5. d 5/85 7 Revised and reissued to include transuranics in the 6/86 f waste. l 8 Revised Sec.tions 1.1, 2.1, 2.2.4, and added new Section C 9/88 l 2.2.4.6 to clarify that the ISWSF consists of the building and yard area. Revised Sections 1.1,1.3a, 2.1, 2.4.1, 2.4.2, 5.1, and 5.2 to indicate that the ISWSF area may be utilized for temporary storage of radioactive material under certain conditions. Revised 2.2.4.5 to clarify that the Personnel Monitoring / Analysis Area may contain equipment for personnel + monitoring or may be used for swipe sample analysis. Revised Section 3.2.1.1 to delete distance references since distances may vary depending on whether radio-active material is located in the yard area. Revised Sections 2.2.4.1, 2.2.4.2, 2.2.4.4, 2.4.1, and 2.4.2 to reflect current ISWSF operations / conditions. 9 Revised Section 2.4.1 to allow more flexible packaging 6/91 l of items for short-term storage, j 10 Ad'ded pg. 4 note 2 to reference estimated site boundary dose rate calculation for the period of interim storage i should the disposal optioit not be available or chosen. Revised sections 2.2.3, 2.2.4, 2.2.4.4, 2.2.4.5 and = 2.4.1 to clarify facility operation or describe modifi-l i [ cations made in preparation for the interim storage per-f iod. Revised section 3.2.t.1 to clarify the location of g the limiting individual and the possible fraction of i 5 permissible annual dose rate per 40 CFP, part 190. Re-4 vised figure 2-2 to reflect current modified configur-ation. j i

i I 3230-008 TABLE OF CONTENTS P;1gg i

1.0 INTRODUCTION

4.0 ) i 1.1 General 4.0 1.2 Organization of Report 4.0 1.3 Conclusion 5.0 i 2.0 FACILITY DESCRIPTION 5.0 .i 2.1 Purpose of the Facility 5.0 t 2.2 Summary Description 5.0 t 2.3 Aiajor Systems 8.0 2.4 Afaterial Handling Operations 8.0

3.0 TECHNICAL EVALUATION

11.0 3.1 Licensing Issues 11.0 3.2 Dose Assessment 11.0 l 3.3 Occupational Exposures 16.0 4.0 COMPARISON WITH PROGRAhiMATIC ENVIRONhfENTAL IAiPACT 20.0 STATEhfENT (PElS) T 5.0 SAFETY EVALUATION 22.0 i 5.1 Technical Specifications 22.0 { 5.2 Unreviewed Safety Question 22.0 i i l i 3 i 3.0 Revision 10 p

i t 3230-008

1.0 INTRODUCTION

1.1 General t 4 The cleanup effort at Thme 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 l in Unit 1. Due to limitations on low level mdioactive waste disposal rites and limited on-site staging capacity, an additional facility for the collection and tempomry staging of low level solid or solidified radioactive ma'erial is needed. l The facility proposed to fulfill the need identified above is the Interim Solid Waste Staging Facility (ISWSF) which is described in Sections 2.2.3 and 2.2.4. j This Technical Evaluation Report (TER) demonstrates that the ISWSF has been j designed and will be operated in such a manner as to provide assurance that: I a. The health and safety of the public will be protected. 1 b. Occupational exposures will be as low as reasonably achievable (ALARA). c. There will be no adverse impact on the envimnment. i 1.2 Organization of Report j This report is organized in the format of a combined safety analysis and environmental mport. 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 Programmatic Environmental Impact Statement is presented next. The report concludes with the safety evaluation required by 10 CFR 50, pangraph 50.59, " Changes, Tests, and Experiments." l 1 Note 1. As used herein the term " low-level" refers to the dose rate on contact with the waste i packages as defined in Table 2-1. The term gives no indication as to the isotopic l or elemental content of the package. -l Note 2. A calculation of dose rates from the ISWSF containing 5 years of TMI radwaste has been performed. Results may be found in Radiological Engineering calculation no. 6612-92-012. 1 4.0 Revision 10 i I

i i 3230-008 1.3 Conclusion The information provided in this report results in the following conclusions: a. The ISWSF fulfills the need for a facility to temporarily stage low level solid or solidified radioactive material. b. The operation of the facility is not an unreviewed safety question as defined ' in 10 CFR Part 50, paragraph 50.59. 2.0 FACILITY DESCRIPTION 2.1 Purpose of the Facility The ISWSF may be used for the staging of low level solid or solidified radioactive waste packages from both Units 1 and 2 prior to shipment off-site. Additionally, the ISWSF area may be utilized for storage of radioactive material pursuant to Section 2.4.1. The packages shall not be staged in the facility for a period greater than 5 years. 2.2 Summary Description 2.2.1 Location As shown on Figure 2-1, the ISWSF is located east of the Unit 2 turbine building and between the off-site transmission lines for Unit 2. It is surrounded by an outer fence which aids in restricting access to the area immediately surrounding the facility. One section of the outer fence is common to the switchyard fence, and another section is part of the site fence located on the island along the east channel of the river. Access to the area enclosed by the outer fence will be controlled by established plant procedures. The only activities occurring within this area will be those associated with the ISWSF. 2.2.2 Design Basis The ISWSF has no safety design basis. The facility is designed to provide a controlled but ready access for material - handling operations to ensure that operator exposures are maintained ALARA. 5.0 Revision 10

3230-008 I The facility is sized to accommodate the wastes generated in 6 months fmm Units 1 and 2. The monthly waste generation rates used in the design are given in Table 2-1. l The ISWSF is designed to conform with 10 CFR Pan 20, paragraph l 105(b)(2). This is accomplished by establishing a restricted area around the l facility, composed of the area inside the outer fence and a section of the adjacent switchyard enclosure. The facility is also designed to meet the i requirements of 40 CFR Part 190 at the site boundary and beyond. 2.2.3 Building Description l The ISWSF building, shown in Figure 2-2, is a pre-engineered metal building { on a non-seismic Category I concrete floor slab. Shielding partitions of solid or grout-filled concrete masonry units (CMUs) are used to satisfy the dose rate criteria specified in Section 2.2.2. A roof is provided over the truck bay [ to allow unloading and loading of trucks during adverse weather conditions. i A curb to elevation 302'-8" is provided around the perimeter of the floor slab l to contain any rainwater that may enter the building. The floor slab is sloped 'j so that any water entering the facility will be directed toward one of the two t (2) sumps provided. With the use of ponable pumps, water collected in these sumps will be disposed of in accordance with established plant operation } procedures. The sumps are pmvided with manually actuated heaters to facilitate disposal of collected water during the winter. l The floor slab, sumps, and curb are epoxy coated for ease of decontamination, should the need arise. The steel columns, siding and the mof framing have a protective finish. The shielding partition surfaces are painted with a sealer. I With the exception of small quantities of electrical cable associated with [ electrical power and the in-plant paging system, all materials used in the l construction of the facility are non-combustible. 2.2.4 General Arrangement 3 The ISWSF consists of six (6) basic areas: (1) loading / unloading, (2) survey, [ (3) open staging, (4) shielded staging, (5) personnel monitoring / analysis, and (6) yard area. A discussion of these areas follows. The general arrangement 6.0 Revision 10 l l

.. ~.. j t i 3230-008 l of the facility is shown in Figure 2-2. 2.2.4.1 L.oading/ Unloading Area l The loading / unloading area consists of a tmck bay, an asphalt pad, ramps into [ the facility, and areas for the loading and unloading of vehicles. i 2.2.4.2 Suivey Area A survey area is pmvided to allow for radiation surveys of radioactive material packages. This area is separated fmm the truck bay and the open staging area by shield panitions. 'l 2.2.4.3 Open Staging Area t The open staging area is separated from the survey area by a shield panition. Access routes, or aisles, with gates at the entrance, allow for the movement i of the containers by a forklift to the appropriate area. A unique number that identifies each container and its unit of origin will be assigned to each waste j container stored in the area. i 2.2 4.4 Shielded Staging Area j t A shielded staging area is provided in order to meet the dose rate limits specified in the design basis, Section 2.2.2. Access to this area is through a j sliding gate by means of the aisles identified in Section 2.2.4.3. Access will be controlled by administrative procedures. 2.2.4.5 Personnel Monitoring / Analysis Area l The personnel monitoring / analysis area is a small cubicle at the end of the 4 loading / unloading dock area. This area may contain equipment for personnel l monitoring or may be used for swipe sample analysis. 2.2.4.6 Yard Area [ i The yard area surrounds the ISWSF building and is enclosed by the outer fence as described in Section 2.2.1. i I 7.0 Revision 10 l, i z. I

I I i 3230-008 i l 2.3 Major Systems j l The only systems provided for the operation of the ISWSF are electrical power for i lighting, receptacles, sump heaters, roll up door and the in-plant paging system. j None of these systems serve any safety-related function. i No fixed radiation monitors are provided in the facility. Radiation monitoring will be performed by Radiological Controls Personnel according to approved procedures. Access is controlled to the area inside the outer fence and to the switchyard, where i dose rates could exceed allowable limits for an unrestricted area. l 2.4 Material Handling Operations 2.4.1 Description of Packages The packages to be staged in the ISWSF are of seveml types. Examples of l these are described below. 55-gallon drums of compacted trash and/or solidified radioactive waste placed i on 4-foot by 4-foot pallets. Depending on the weight of each drum, they may i be banded together. s 50-cubic-foot liners of radioactive waste placed on 4-foot by 4-foot pallets. The dimensions of the liner are approximately 4 feet in diameter and 4 feet high. There will also be metal boxes containing compacted or non-compacted waste. The dimensions of the boxes are approximately 4 feet x 4 feet x 7 feet. These boxes will arrive at the facility with a spacer as necessary to allow a s forklift to readily lift the box. l All waste packages received in the ISWSF will be properly prepared for shipment or storage as appropriate. Packaging of items for shipment will meet 49 CFR Criteria when placed into the staging area. Counting, swiping, j decontamination, and weighing will be done prior to the transfer of the packages to the ISWSF. Provisions have been included in the design of the ISWSF to allow additional counting and swiping in the ISWSF. j l Radioactive waste received for shipment or temporary storage may be placed inside or outside the ISWSF building. The placement should consider dose 8.0 Revision 10 j . ?

r 1 3230-008 rate, handling, storage duration, and the container's ability to withstand f environmental conditions..No container shall be opened for repackaging or inspection in this area. l [ Storage of items to be reused within the plant will be considered on a case-by-case basis and will be approved by the Waste Management l Depanment and Radiological Controls Director and should be in writing. Packaging of these items will meet criteria specified by the above j depanments. Storage of these items within the ISWSF should be minimized. l Storage will consider the item's use frequency need, and the areas availability to support its primary function, especially during the period when a disposal option may not be available. i 2.4.2 Unloading and Stacking of the Packages { Upon arriving at the facility, the vehicle containing the package (s) will normally be placed either in the Tmck Bay or the loading / unloading area on the asphalt pad located on the south side of the facility. At this point, a forklift will normally unload the packages and transpon them to the proper area of the facility. i For packages which are to be stored in the ISWSF yard area, the vehicle will be parked in an appropriate location to facilitate unloading. Upon arriving at tN proper location within the ISWSF building, the packages may be stacked, as necessary. The pallets and boxes will be stacked no more j than three high, which is consistent with current GPU practice. In general, l pallets will be stacked in a staggered manner. The LSA boxes will be stacked one on another with spacers. These spacers are normally an integral pan of the LSA box. The required lift height of approximately 10 feet is well within the 16-foot l 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. Items / packages that may be stored in the ISWSF yard area shall not be [ stacked and will be handled in accordance 'vith proper accepted rigging and .j handling practices. 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. i 9.0 Revision 10 i

i 3230-008 f TABLE 2-1 L DESIGN STORAGE REQUIREMFNI'S l Quality Unit (Per month) Canister / Trash Type Radiation Level 1 37 55 gal dmm/ compacted trash up to 50 mrem /hr 1 19 55 gal dmm/ compacted trash 50 to 100 mrem /hr 1 15 55 gal dmm/ compacted trash 100 to 200 mrem /hr 1 4 55 gal drum / compacted trash 200 - 400 mrem /hr 1 1 4'x4'x7' box / compacted trash up to 200 mmm/hr 1 10 50 ft' liners / solidified 200 - 500 mrem /hr evaporator bottoms 2 9 55 gal drum / solidified up to 100 mrem /hr mdiac waste i 2 16 55 gal dmm/ compacted tmsh 0 to 1 mrem /hr 2 6 55 gal dmm/ compacted trash I to 2 mrem /hr 2 11 55 gal dmm/ compacted trash 2 to 5 mmm/hr 2 9 55 gal dmm/ compacted trash 5 - 20 mrem /hr t 2 5 55 gal drum / compacted trash 20 - 100 mrem /hr 2 2 55 gal dmm/ compacted trash 100 - 500 mrem /hr 2 1 55 gal dmm/ compacted trash 500 - 1000 mrem /hr 2 1 55 gal dmm/ compacted trash 1000 - 2000 mrem /hr 2 2 4'x4'x7' LSA boxes 0 - 1 mmm/hr 2 2 4'x4'x7' LSA boxes 1 - 2 mrem /hr 2 3 4'x4'x7' LSA boxes 2 - 10 mrem /hr 2 3 4'x4'x7' LSA boxes 10 - 20 mmm/hr 2 3 4'x4'x7' LSA boxes 20 - 100 mrem /hr 2 1 4'x4'x7' LSA boxes 100 - 200 mmm/hr l 10.0 Revision 10 j l

2 3230-008 1

3.0 TECHNICAL EVALUATION

i 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 l operation and various design basis events. -l 3.1 Licensing Issues The licensing issues associated with the operation of the ISWSF are: a. Demonstrating compliance with 40 CFR Part 190 with respect to off-site doses. b. Demonstrating compliance with 10 CFR Pan 20 with respect to on-site dose limits. l c. Demonstrating that the design basis events for the facility have been properly considered. The design basis events for this facility are high winds, operating basis earthquake, fire, and flooding, d. Demonstrating compliance with the principles of ALARA. 9 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 _j CFR Pan 190 are met at the site boundary and beyond, and (2) the dose rates at the boundary of the restricted areas conform to 10 CFR, Pan 20, paragraph 105 (b)(2). This paragaph requires that the radiation levels in unrestricted areas be such that if an individual were continuously present in the area for seven consecutive days, l he would not receive a dose in excess of 100 millirem (0.6 mrem /hr). The consequences of design basis events have been evaluated to assure that public use i of areas beyond the exclusion areas is not intermpted or restricted. j i This section presents the analyses that demonstrate the above objectives are met. l 3.2.1 Off-Site i 3.2.1.1 Normal Operation j The total annual off-site dose from the site to any individual is limited to 25 mrem by 40 CFR Pan 190. The nearest site boundary for the ISWSF is the t owner controlled area fence on the east bank of the island. i 11.0 Revision 10 l

t t 3230-008 As applied to the site boundary, the 40 CFR Pan 190 limits equate to a 0.2 l f mrem /hr dose rate based on a 67 hr/yr occupancy (Note 2) with an 80 percent contribution factor (80 percent of the total 25 mmm). In addition to satisfying 40 CFR Pan'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 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 nearest residence. The code used was the G-33 version of "G : A General Purpose Gamma-Ray [ 3 Scattering Program," described in Los Alamos Scientific Laboratory publication LA 5176, dated June 1973. 1 The calculation of the dose rate at the nearest residence included the following considerations: P a. The ISWSF was assumed to contain the waste generated in six months at the monthly generation rates given in Table 2-1. b. The predominant mdionuclide encountered in the Unit 2 containment, Cesium-137, was assumed to be the source of radiation in all waste - packages. c. The factor of 0.7 specified in Regulatory Guide 1.109, Revision 1, was used to account for shielding and occupancy characteristics at the nearest residence. i In the future, the waste from Unit 1 to be staged in the facility is likely to l contain Co-60. An assessment of the effect of Co-60 on the off-site dose calculation is summarized below. The skyshine dose calculation was performed using a point-kemel theory computer code which accounts for the scattering in air. The degradation of the scattered photon's energy is determined from the incident energy and i angle of scatter of the uncollided photons. The Klein-Nishina differential scattering cross section formulation is used to assess the probability of scattering from the differential scattering volume (air). Multiple scattermg m air is also accounted for by applying a buildup factor. The actual skyshine analysis was performed assuming the source was Cs-137 (.662 MeV). To assess the impact of this assumption the effect of changing the source to Co-60 (1.2 MeV) was evaluated. This evaluation was l 12.0 Revision 10 P

t -i 3230-008 performed recognizing that there are two major energy dependent parameters used in the analysis which must be addressed to evaluate the effect of changing the incident photon energy: E 1. Impact on total source strength, and 2. Impact on the scattering cmss sections. The incident energy used in the actual analysis was 0.662 MeV to represent. Cs-137. The total source strength (panicles /second) used in the analysis was detennined from the contact dose rate for the waste containers along with the flux-to-dose rate conversion factor (DCF) obtained using ANSI /ANS 6.1.1-1977 (N666), " Neutron and Gamma-Ray Flux-To-I'ose Rate Factors,"- March 17,1977. To assess the impact on the total source strength caused by changing the source energy to that of Co-60, a new source strength is again deduced assuming the same contact dose rate along with the appropriate energy dependent DCF from ANSI /ANS 6.1.1;1977. Based on the above, the total source stmngth would be reduced by 50 percent if the source is assumed - to be 1.2 MeV photons. The resulting change to the scattering. pmbability is indicated by the magnitude of the buildup factor. For a given number of mean-free paths the buildup factor will be higher for the lower energy. Hence, if Co-60 is assumed to be in the waste packages, the total source strength and the degree of scattering would decrease. Themfore, considering Co-60 in place of Cs-137 for pan of the Unit I waste would not increase the resultant off-site dose. i 3.2.1.2 Design Basis Events Design basis events considered were high winds, an operating basis eanhquake, a fire, and floodmg. Note 3. Regulatory Guide 1.109, Rev.1 Table E-5 Page 40--Recommended values for the maximum exposed individual in lieu of site-specific data. 13.0 Revision 10

3230-008 3.2.1.2.1 High Winds i F From the TMI-2 FSAR the design wind velocity, based on the 100-year recurrence interval, is 80 miles per hour at 30 feet above gade. The ISWSF building is enclosed by a combination of CMU walls and galvanized steel siding and is designed to withstand a wind loading of.20 pounds per square l foot, which corresponds to a wind speed of more than 80 miles per hour. Therefore enclosure of the ISWSF building protects the radioactive waste containers within the ISWSF building from the effects of the design basis wind loading. 3.2.1.2.2 Operating Basis Earthquake (OBE) In the event of an OBE, the ISWSF building may collapse; however, the radioactive waste packages would remain in the geneml area of the facility. The resulting maximum dose to the public from a postulated airborne release would be less than 3.8 mrem for the inhalation pathway. The following considerations were made in this analysis: A six month accumulation of vein based on the requirements listed in Table 2-1, was considered a3 a y ~ ufal source of an airborne release. } The estimated activity of the waste was 100 curies. It was conservatively assumed that the isotopic distribution for this waste is Cs-137 (78%), Sr-90 (18%) and Pu-239 (4%). These isotopes have high dose conversion factors, therefore this assumption will maximize i the estimated dose. t The assumed percentage of transuranics was determined from the ratio of the transuranics to Sr-90 activities calculated from an estimate of the core inventory for TMI-2 using the ORIGEN-2 computer code. A release' fraction of 104 of the contents of the 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. The atmospheric dilution factor of 8.1 x 10 sec/m' was used, based on 4 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. i 14.0 Revision 10

i 3230-008 I i 3.2.1.2.3 Fire [ A fire in the ISWSF will not result in the release of significant quantities of l radioactive material. This is based on having the stored radioactive material in scaled metal containers and the surface activity within limits for { unrestricted use. In addition, the amount of combustible material, the wooden pallets and small amounts of electrical cable, exposed to an ignition source is [ insufHcient to bum through a container. Also, based on available information regarding the contents of the waste packages, spontaneous combustion within l a container will not occur. Based on the above the off-site dose resulting l from a fire is bounded by the evaluation presented in section 3.2.1.2.2. j 3.2.1.2.4 Flooding The Three Mile Island site is protected against a design flood of 1,100,000 cfs flow in the Susquehanna River. This protection is furnished by the site [ dike, which has a minimum elevation of 304 feet aEng the southern end of ( the island. In the event of a design flood, which is equivalent to a river level j of approximately 300.5 feet, the drainage culveN gate at the southeast dike will close, isolating the site storm drain system from the river. Consequently, the TMI site design flood will have no adverse impact on the ISWSF. j In the event of a pmbable maximum flood (PMF), the river flow rate will slowly increase to the calculated maximum of 1,625,000 cfs. As the river level increases it wil! evenop the south dike. The vater level on the island will then rise to a maximum PFM flood height of 308 5 feet. As noted in l Figure 2,4-7 of the TMI-2 FSAR, an advance warning of at least 36 hours will precede the arrival of PMF. l The ISWSF is not protected against the PMF; therefore the ISWSF will be -l inundated in the very unlikely event a PMF occurs. The following discussion I addresses the possible off-site releases of radioactive materials that could i result from submergence of radioactive waste drums and boxes. Since the waste packages are sealed and mady for off-site shipment, they will r 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 i of radionuclides in water. Therefore, in light of the extremely low probability l of occurrence of the PMF (mcarmnce 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. 15.0 Revision 10

3230-008 4 r 3.2.2 On-Site i The dose rates outside the restricted areas surrounding the ISWSF were calculated to ensure that the values are less than the 0.6 mrem /hr in acconlance with 10 CFR Part 20. This was done by calculating the gamma dose rates from a planar soume to a point at a given distance from the source. The major assumptions made in the performance of this analysis were: j a. The only contributing isotope was Cesium-137. b. All waste packages were at the maximum contact dose ate given in Table 2-1. i c. The facility was assumed to contain the waste generated in six months, i based on the generation rates given in Table 2-1. i i The resulting dose at the outer fence surrounding the ISWSF and outside the j switchyard enclosure is calculated to be less than 0.6 mrem /hr. These dose rates have been determined to be less than 0.6 mmm/hr based on the information presented in Table 2-1. In order to allow for deviations fmm this j list, a radiation survey will be performed whenever the quantity or arrangement of packages in the ISWSF is significantly altemd to ensure that i the dose rate at any given point outside the restricted area does not exceed 0.6 mrem /hr. t i 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 information has been combined with expected radiation fields in the ISWSF to arrive at a pmjected annual exposum of from 17 to 22 person-rem for this facility. Of this exposure, appmximately 80 percent is attributable to radioactive waste originating in Unit 1. 3.3.1 Design Features I Several design pmvisions have been included in the ISWSF to minimize occupational exposures. These provisions include segregation of waste with higher radiation levels fmm those with lower radiation levels, use of -l shielding, and other provisions as noted below. i 16.0 Revision 10 -I

l r i 3230-008 i 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 j storage. i A roof and siding have been provided for the facility. Siding on the north, south and west sides enclose areas not constructed of CMU walls 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 not t be entered to pump the sumps. j Location of the forklift truck aisles on the outside of the facility rather than l using a single central aisle results in a lower radiation field at the aisle. 3.3.2 Person-Rem Estimate The duration of activities occurring in the ISWSF was estimated by considering the number of radioactive waste packages to be placed in the i facility. Factors considered in the analysis of time spent in the radiation area included the following: a. 55-gallon dmms are handled by an unshielded forklift in groups of four drums on a single pallet. The dmms are stored on the pallet. i b. LSA boxes and the 50 fP containers are handled one at a time by the i forklift. 5 c. The speed of the fWift was assumed to be three 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 for the return trip to or from the loading / unloading area to the staging areas to pick up another load. l e. Two forklift breakdowns per year in the radiation areas were assumed. j f. Allowances for time spent in the radiation area by other than the forklift i operator were made to account for the shipment vehicle driver, health physics technician, and a laborer to assist the forklift operator. g. An allowance has been made for relocating containers within the facility. t 17.0 Revision 10

3230-008-i 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 following: 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 spreading was assumed. c. No credit was assumed for the shielding effect of the content of one container on an adjacent container except in the case of solidified waste in 50 ft' liners. d. The ISWSF was assumed to contain a six-month inventory of containers at all times. l The area radiation levels calculated for the various areas in the ISWSF are given in Table 3-1. The person-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 containers in storage, removing the containers fmm sterage to the shipment vehicle at a later point in time. and a health physics survey of the shipment vehicle, i Assuming that the person-rem exposures from the ISWSF activities control the ' i 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: i Number of Total l Function Workers Rose o P Health Physics .I .5 rem r Technicians Forklift Operators 4 16 rem (max.) { All other functions 1 equivalect 5 rem total (laborers, tmck drivers, worker maintenance personnel) 18.0 Revision 10

l l 3230-008 TABLE 3-1 AREA RADIATION LEVELS WITH SIX MONTHS DESIGN BASIS Ih7/ENTORY - Radiation [ Area Level (mmm/hr) Survey Area 0.5 3 Open Staging Ama i Unit 2 LSA boxes 60 Unit 2 drums 180 Unit 1 dmms 180 ? Shielded Staging Area Unit 1 - 1600 Unit 2 1170 + 1 i i 19.0 Revision 10

j 3230-008 4.0 COMPARISONWITH PROGRAMMATIC ENVIRONhfENTALIhfPACTSTATEhfENT (PEIS) l Section 9.2.1.1 of the PEIS describes a facility for the temporary storage of cenain low level radioactive wastes. The contents of the facility are given in Table 4-1. The radiation i levels at the fence surrounding the facility will be less than 0.6 miem/hr. This facility is l judged in Section 9.5.1.2 of the PEIS to have negligible environmental exposures to the j general population. { l 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 l to be stored in the ISWSF. Table 4-1 contains the design basis contents of the PEIS l Facility compared to the ISWSF. However, as shown in this report, the ISWSF will result l in negligible environmental exposures to the general population. l ) t i i } t h i i i l l i i ? i 20.0 Revision 10 i A

t -l 3230-008 TABLE 4-1 i CONTENTS OF STAGING FACILITY f PEIS Facility ISWSF 55-Gallon Drums 800 810 1 LSA Boxes 150 90 l (4 ft x 3 ft x 61/2 ft) (4 ft x 4 ft x 7 ft)- wooden metal -j i 50-ft' Liners 60 60 i t . l i i Y .I [ t t i i i 1 21.0 Revision 10 l i 4 l

3230-008 5.0 SAFETY EVALUATION 10 CFR 50, paragraph 50.59, " Changes, Tests, and Experiments," permits the holder of an operating license to make changes to the facility provided the change does not involve a modification of the plant technical specifications and the change is determined not to be 1 an unreviewed safety question. As summarized below, the operation of the ISWSF neither requires a modification to the plant technical specifications nor is it deemed to be an unreviewed safety question as defined 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 material. 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 i technical specifications. 5.2 Unreviewed Safety Question The operation of the ISWSF will not increase the probability of occurrence or the i consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis repon. This is based on the location of the facility being such that there is no interface with existing safety-related equipment or stmetures. The possibility of an accident or malfunction of a different type than any evaluated pmviously in the safety analysis repon will not be cmated by the opemtion of the ~ ISWSF. This is due to the passive natum of the facility and the fact that all the radioactive material 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, paragraph 50.59. I 22.0 Revision 10 \\

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