ML20079N139
| ML20079N139 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/20/1984 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8401300070 | |
| Download: ML20079N139 (3) | |
Text
a l
l lHsconsin Electnc eomcoumr 231 W. MICHIGAN, P.O. BOX 2046. MitWAUKEE, WI 53201 January 20, 1984 Mr. H.
R.
Denton, Director Office cf Nuclear Reactor Regulation U.
S. NUCLEAR REGULATORY COMMISSION Washington, D.C.
20555
Dear Mr. Denton:
10 CFR 61 IMPLEMENTATION DOCKET NOS. 50-266 AND 50-301 POINT BEACH NUCLEAR PLANT As you are aware, there has been considerable discussion regarding the appropriate implementation of the new 10 CFR 61 regulation which became effective on December 27, 1983.
Meetings between the Nuclear Regulatory Commission and the Utility Nuclear Waste Management Group (UNWMG) took place before the regulation became effective.
Since we maintain membership in the UNWMG and parti-cipated in the discussions with NRC, we are aware of the clarifications afforded by those meetings.
The purpose of this letter is to document our implementation of 10 CFR 61 at Point Beach Nuclear Plant.
1.
Waste classification Waste classification at Point Beach is based on gamma spectrometric analysis to the extent practicable.
For transuranics and the other non-gamma emitting nuclides whose quantification is required for waste classification, a scaling procedure based on historic analyses performed on our wastes'by outside laboratories is used.
These special analyses will be performed on each major waste stream (resins, evaporator concentrates, and compacted trash) at least annually.
For those nuclides not successfully determined by either the on-site gamma spectrometric analysis or the off-site special analyses, a calculational procedure is used, similar to that in the AIF/NESP-sponsored NSA/IMPELL report entitled " Methodologies for Classification of Low-Level Radioactive Wastes from Nuclear Power Plants".
A basic on-site gamma spectrometric analysis is per-formed for each waste batch of resins or evaporator concentrates.
For compacted trash, the analysis is performed at least annually, and the results are scaled to individual shipments relative to external radiation readings. 1 8401300070 840120 dN8 PDR ADOCK 05000266 X
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lir. H. R.
Denton January 20, 1984 2.
Waste Form It is our understanding that the three established solidification media (cement, vinyl-ester-styrene, and asphalt) are acceptable on an interim bacis, without extensive testing, based on their satisfactory historical performance.
Specifically, it is our understanding and belief that solidification in cement meets the requirements and satisfies the intent of 10 CFR 61, provided that procedures are in place to ensure that a free-standing monolith is consistently produced.
Since we hava concluded that quantitative control of the cement-water-waste mixture is a preferable means of providing that assurance (rather than after-the-fact determination), we will be modifying or replacing our semi-automated waste solidification system.
In the interim, we are relying on vendor-supplied mobile systems and on our manual mixing system which can be quantitatively controlled.
3.
High-Integrity Containers It is our understanding that those high integrity containers for which topical reports exist or for which state certificates of compliance have been issued are acceptable for demonstrating compliance with 10 CFR 61.
4.
Other Items The other requirements of 10 CFR 61, such as changes pertaining to shipping manifests, have been implemented at Point Beach.
Procedures for implementation of the requirements of 10 CFR 61, as discussed above, are in place at Point Beach.
However, it should be noted that while our procedures do ensure that waste classification is carried out by the appropriate cognizant personnel, we have not proceduralized the detailed derivation of scaling factors.
Because this is a developing area of technology, responsibility for the details is assigned to knowledgeable individuals.
After more experience with the data is achieved, it may become appropriate to proceduralize the details of scaling factor determination.
Similarly, we have not yet proceduralized the steps to be taken to investigate the shipments not acknowledged received by a burial site within twenty days of transfer.
The details of an investigation procedure need to be worked out with the burial site operators.
In the interim, cognizant personnel will contact the burial sites by phone to assure that shipments arrive intact.
Mr.
H..R.
Denton January 20, 1984 Finally, we note that, while appropriate procedural modifications were required for all wastes prepared after December 27, 1983, a corresponding updating of the Process Control Program (PCP) was not immediately required.
Our PCP, which primarily consists of a directory of applicable procedures, will be updated by July 1, 1984.
Very truly yours,
/fs t/
v Vice President-Nuclear Power C. W. Fay Copies to Leo Higginbotham, NRC R. E. L. Stanford, UNWMG NRC Resident Inspector
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