ML20077H614

Requests Approval to Dispose of Slightly Contaminated Fuel Oil by Incineration.Proposed Disposal Procedures Encl,Per 10CFR20.302.Proposed Changes to Tech Specs to Permit Burning Contaminated Oil on Infrequent Basis Under Consideration

ML20077H614
Person / Time
Site:	FitzPatrick
Issue date:	08/09/1983
From:	Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
References
JPN-83-74, NUDOCS 8308110134
Download: ML20077H614 (8)

Text

12'3 Main Street

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August 9,1983 JPN-83-74 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comnission Washington, D.C.

20555 Attention:

Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Licensed Material Disposal Procedures 10 CFR 20.302

Dear Sir:

A small quantity of fuel oil containing very low levels of radioactive contamination has a m - lated at the Power Authority's FitzPatrick plant. Disposal of this oil using currently approved methods would require solidification and burial at a low level comnercial waste-disposal site. Disposal of the oil in this manner is unnecessary, expensive, and is contrary to NBC policy which calls for minimizing the quantity of waste disposed of in connercial waste-disposal sites. Werefore, the Authority proposes to dispose of the contaminated oil by burning it in the FitzPatrick auxiliary boilers.

In accordance with the provisions of 10 CFR 20.302 (" Method for obtaining approval of proposed disposal procedures"), the New York Power Authority hereby applies for approval to dispose of this oil by burning it. As required by 10 CFR 20.302 (a), a description of our proposed disposal procedure is included as Attachment No. 1.

W ese procedures apply only to the quantity of fuel oil described.

We Authority is considering the submittal of proposed changes to the FitzPatrick Technical Specifications that would allow the burning oF very low level contaminated oil on an infrequent basis.e6I I i 3308110134 830809 PDR ADOCK 05000333 p PDR

Your pronpt review and approval of this request will be greatly appreciated. If you have any questions regarding the enclosed evaluations please contact Mr. J. A. Gray, Jr. of my staff. Very truly yours, 'g,,p Oap - Executive Vice President Nuclear Generation cc: Mr. J. Linville Resident Inspector U.S. Nuclear Regulatory Conmission P.O. Box 136 Lycoming, New York 13093

O l ATTACHMENT NO. L TO JPN-33-74 NEW YORK POWER AUfdORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT Proposed Disposal Procedures for Radioactively Contaminated Fuel Oil

1.0 INTRODUCTION

j In accordance with the provisions of 10 CFR 20.302(a), this docament dascribes procedures proposed by the New York Power Authority for the incineration of radioactively contaminated fuel oil at the James A. FitzPatrick Nuclear Powar Plant.

2.0 DESCRIPTION

OF LICENSED MATERIAL 1 Seven 55-gallon drums filled witn 46 fuel oil nave become contaminated with very low levels of Co-60 and Cs-137. The total activity of these drums is approximately 4L micro C1. l This contaminated fuel oil das recovered f rom the Auxiliary Boiler Room Floor Drain Oil Separator. '(Refer to Table 1.) 2.1 Other Radioactive Material Involved 1 No other radioactive material will be involved. 2.2 Proposed Manner and Conditions of Disposal I Tne oil will be incinerated in the auxiliary boilers at the Authority's James A. FitzPatrick Nuclear Poder Plant. The contaminated oil will be transferred from seven, fifty-five gallon drums to underground auxiliary boiler storage tank 1A where it will be used as fuel i for the boilers. The auxiliary boiler storage tank has a capacity of 30,000 gallons wnich will further dilute the contaminated fuel oil. The average burn rate of i' fuel oil in an auxiliary boiler is 387 gal /hr. Tne gases are vented through a boiler outlet equipped with a dust collector and a fly-ash collection afstem. 4 No special conditions will be imposed on auxiliary boiler operation.- l l Tne release of the particulates will be included in tne ) approporiate seminannual report as a batch release occurring on the day that the drum's contents were added to the fuel oil tank. -i-

2.3 Analysis and Evaluation Radiological Effects Using the current Technical Specifications formula for particulate and nalogen airborne releases to the environment, a 41 micro ci release would result in 8.2E-3h of Technical Specifications LLaits. Based upon actual quarterly releases, this release would result in an average percentage increase of 4.6E-2 percent. I No credit is taken for treatment of releases in the exhaust path and the assamption is that the contaminated oil would be burned and the total activity released in one hour. The instantaneous release rate to the environs of I-131 equivalent halogen and particulates with half-lives - greater than eight days is limited by Environmental Technical Specifications section 2.3.8.2. The portion of the formula limiting ground level release from FitzPatrick ist + + Qv FITZ 6i ~~ 8.9E-8 and the estimated duration of the release ist (385 gals 387 gal /hr) x 3600 sec/hr = 3581 see or approximately 3600 see therefore the instantaneous release ist 41E-6 Ci/3.6E+3 sec 0.128 = 8.9E-d i oc approximately 134 for one hour. When averaged over a calendar. quarter in accordance i with semiannual radiological effluent reporting requirements, that average is: 41E-6 Ci/7.7E+6 sec 5.92E-5 = 8.9E-d or approximately 0.0061 -

M FitzPatrick T;chnical Specifiestions currsntly limit i the dose to persons within unrestricted areas to 500 mrem /yr. This limit applies to whole body or any organ doses from airborne halogens and particulates with half-lives greater than eight days. This limit applies to releases from the main stack and vents of both FitzPatrick and Nine Mile Point Unit 1. The dose attributable to the proposed contaminated oil is calculated as follows: 500 mrem /yr. x 5.92E-5 = 2.96E-2 or approxiastely 0.03 mrem /yr. A second calculation using the draft ODCM (Offsite Dose Calculation Manual) methodology agreed with the whole body or any organ dose of 0.03 mrem within + 25%. Nature of Environment 3 Refer to the James A. FitzPatrick Final Safety Analysis Report (FSAR), Chapter 2 (Site and Environment) for pertinent information as to the nature of the environment, including topographical (Section 2.1.1), geological (Section 2.5), meteorological (Section 2.2), hydrological (Section 2,4) characteristics; usage of ground and surface waters in the general area (Sections 2.1.2, 2.4.1 and 2.4.2) and location of other potentially af fected facilities (Section 2.1.3). Alternate Disposal Costs Disposal of fuel oil by this method will save approximately $25,000 in burial costs (including absorbant material, preparation and handling time and transportation fees) and will save approximately 250 cubic feet of space in a commercial waste-disposal site. Table 2 describes our estimate of the disposal costs associated with burial. 4 f i L ;

l 2.4 Procedures to Minimize Risk of Unexpected or Hazardous Exposures Prior to transferring the contents of the seven fuel oil drums to Fuel Oil Tark 1A, a sample from each drum will be taken. These samples will be subjected to Ge"Li" isotopic analysis. Analysis results will be compared with prior samples to ensure accuracy and consistency. Other than this analysis, the Authority does not propose using any special procedures related to the incineration of this fuel oil. The analysis presented in Section 2.3 of this document clearly shows that the incineration of this fuel oil represents an insignificant change in the amount of radioactive effluents released and no significant environmental impact can be attributed to the proposed action. Therefore no special procedures are proposed.

3.0 REFERENCES

1. Code of Federal Regulations, Title 10, Part 20.302, " Method for obtaining approval of proposed disposal procedures." 2. 10 CFR 20.305, " Treatment or disposal by incineration." 3. USNRC Office of Inspection and Enforcement Information Notice No. 83-05, " Obtaining Approval for Disposing of Very-Low-Level Radioactive Waste - 10 CFR Section 20.302," d3ted February 24, 1983. 4. NRC Policy Statement on Low-level Waste Volume Reduction, October 16, 1981 - 46 FR 51100. 5. 10 CFR 61, " Licensing Requirements for Land Disposal of Radioactive Waste," July 24, 1981 - 46 FR 38031. 6. James A. FitzPatrick Nuclear Power Plant Environmental Technical Specifications, Section 2.3.B, " Airborne Effluents." 7. James A. FitzPatrick Nuclear Power Plant Final Safety Analysis (FSAR), Revision 0 dated July 1982, Chapter 2, " Site and Environment." l F. e

.. -~. .-~. TABLE 1

1. 6 FUEL OIL SAMPLE AND ANALYSIS

. JANUARY 11, 1983 diste 011 a(Ci/al-Total Activity in a(Ci Labeled As Co-60 Cs-137 Co-60 Cs-137

1. 1 3.37E-5 ND*

7.02 ND

1. 3 3.44E-5 ND 7.16 ND
2. 4 3.77E-5 ND 7.84 ND

,^

1. 5 1.49E-5 ND 3.10 ND
2. 6 5.31E-5 ND 1.10 ND
3. 7 4.705-6 ND 0.93 ND 3
4. 8 6.14E-5 4.40E-6 12.8 0.92 TDTAL 40.0 0.92 1

• ND-Not Detected

'I .l l i i l l

+

I e l- .m

e. TABLE 2 COST OF BURIAL DISPOSAL OF SEVEN DRUMS OF NUMBER 6 FUEL OIL Solidification 7 drums of 86 oil x 10 solidified drums x $130/ drum = $ 9,100 Cost drum of #6 oil 9,960 Burial Cost 70 drums x 7.5 cu. ft. x $18.97/cu ft = drum 300 Labor Cost 20 hours x $ 15.60 = hour 5,000 Transportation = TOTAL $24,360 i Notes for Table 23 a. Because of the viscosity of 36 fuel oil, Speedy Dry type absorbants cannot be used. Instead, contractors are retained to perform the required solidification. Based upon previous experience, the cost for solidifying 96 oil using concrete, soaps, etc., is approximately $130 per solidified drum. b.- For the purpose of estimation, a 10:1 solidification factor is used. c. The current cost of burial is $18.97/ cubic foot. d. 20 man-hours would be expended for preparing the load for shipment at an average rate of $15.60/hr. 4 e.- Transportation cost is approximately $5,000., w ~r a e w -}}