ML20079N335
| ML20079N335 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/11/1991 |
| From: | FLORIDA POWER CORP. |
| To: | |
| References | |
| RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110164 | |
| Download: ML20079N335 (9) | |
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l$P nun ac INDUSTRY DURVEY IE SUPPORT OF LICENSE RENEWAL RU.LEMAKldG RESPol!BE TO WASIE MANAGEMENT OUESTIONS A.
Spent Puel Ouestiqna 1.
Currently, Florida Power Corporation (FPC) uses exter.ded fuel burnup and has reracked one of our two fuel pools (Fool "A") to enhance our at-reactor spent fuel store.ge capacity.
2.
FPC plans to continue these storage enhancement techniques during the remaining time of our Operating Licnnse.
3.
FPC plans to also rerack fuel pool "B"
to provide further storage capacity in the near future.
4.
FPC expects these actions to provide the necessary spent fuel storage with allowance for full core off-load capability through the year 2010.
Should the Department of Energy (DOE) be unable to fulfill its contractual obligation to accept our spent fuel in a timely fashion, consideration will be given to technigoes such as, fuel pin consolidation or above ground dry storage to obtain additional storage spece.
5.
PPC does not intend to obtain additional land for storage of spent fuel.
Our plant is located in a coastal region and it surrounded by a
100 year flood plain.
This area is undesirable for waste storage activities.
6.
No 7.
N/A D.
Lay-Level Radioactive Waste Managsment Guestions 1.
FPC is an active supporter of t',)e Southeast compact.
This Compact is one of the strongest in the country and has made significant progress in siting a second licensed, regional, low-level radioactive waste (LLRW) disposal facility.
This
- facility, hosted by North Carolina, will close after 20 years of operation or upon disposal of 32 million cubic feet of waste.
The process of selecting the third host state has already begun.
Based upon the probable success of the compact in obtaining an appropriate site and assuming no 1
9111110164 911111 PDR NUREG 1437 C PDR
f changes in the current scheme, FPC expects to have capacity available for LIEW disposal throughout the license renewal period.
2.
tio formal plans have been developed.
FPC has the immediate capacity to store up to six months' worth of LIEW and could creatively increase that capacity to some extent if needed.
FPC, as a member of a sited compact, has access to the Barnwell LLRW Disposal Facility located in South Carolina.
Barnwell has not closed during its 19 years of operation, and FPC maintains its relationship with Barnwell and the South Carolina Department of Ilealth and Environmental Control (DHEC) through strict compliance with requirements.
FPC has identified its concern with loss of disposal capacity during the interval between the closure of Barnwell and the operation of the now facility in North Carolina to the Southeast Compact Commissioners, and will be wcrking with them to develop contingency plans for interim storage capacity within the region.
3.
The following respont.,es are based on the results cf the 1989 LLRW survey completed for the Florida Department of Health and Rehabilitative Services (FDHRS):
a.
Of the LLRW generated, 47 percent was compacted on-site and 16 percent was supercompacted off-site by a waste processor, b.
Waste minimization is employed to reduce the amount of material taken into the Radiation Controlled Area (RCA),
which could ultimately become LLRW.
This concept is considered by employees as a standard work practico.
Specially marked containers are placed at radiation control points to encourage segregation of reusable materials, such as washable protective clothing, from waste materials.
In addition, color-coded bags are used to transport and identify radiologically contaminated reusarle tools and equipment destined for decontamAnition.
c.
Only 4 pe x int of the LLRW is documented to have been managed by decontamination.
This represents a large component that was commercially decontaminated and sold as radiologically " clean" scrap metal.
A significant volume of material is processed by decontamination. This material is not generally considered LLRW at this point and the management inventories of this material were not designed to determine the volume that would constitute LLRW if decontamination was not employed.
Because of 2
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this fact, accurate data is not available to determine the-actual volume of LLRW that is managed by l
decontamination.
d.
Waste sorting prior to shipment is used to segregate compactable from non-compactable
- material, and to segregate LLRW from " Hot Particle Areas."
This latter material is sent of f-site for commercial supercompaction
~
and is reflected in response 3(a) above, e.
Over 9 percent of our LLRW was comprised of sec.ondary resin that was disposed of in an innovative way.
The vendor completing the supercompaction used the resin to fill the void spaces in the outer waste container holding the supercompacted waste packages.
In this way the material requires no additional disposal trench space for its ultimate disposal.
An additional 9 percent of our LLRW was disposed of in -
the county sanitary landfill utilizing th' 10 CFR 20.302 process.
4.
FPC's anticipated plans for LLRW have not extended as yet to the license renewal period.
Existing plans for future LLRW management are found below:
n.
Reliance on waste compaction will be reduced to 15-20 percent with incineration at a vendor facility making up the difference.
- b. Waste segregation will be further developed with the use of. computer-based inventory systems for tools and materials employing "bar codes" for identification,
- c. _ Decontamination will continue to be used extensively for ruusable contaminated materials and will be used increasingly to allow the
" free release" of large components traditionally disposed of as LLRW.
Decontamination could potentially manage up to 15 percent of the LLRW volume.
d.
If-some form of "Below Regulatory Concern" (BRC) regulations are adopted, a significant volume od our LLRW-could be sorted and released as radiological 1y " clean" material.
No percentage can be accurately estimated until the BRC options are worked out.
e
-In the absence of a generic BRC' exemption,10 CFR 20.302 alternate disposal requests will play an increasing role l
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f' in the management of LLnW, possibly up to 15 percent of the volume.
'1-i 5.
11 o additional land is expected to be needed for the management of LLRW in the future.
6.
11/A 7.
Yec 8.
The existing Radioactive Materials Storage Warehouse lacks the storage conditions required for
" quality Related Components" and does not have the capacity or features desirable for officient storage and retrieval of contaminated materials.
Several studies have examined options for replacing this facility.
Many of these options include additional storage space for LLRW.
It is expected that some new construction will occur on existing FPC property within the operatirq lifetime of the plant.
9.
Additional or modified waste streams are expected in the near iuture when source reduction activities, euch as hydrogen peroxide injections and steam generator chemical decontamination programs, are impicmented.
The need for specific plant modifications and large-scale equipment refurbishment necessary to achieve license renewal has not been determined at this time.
C.
liijced Low-Level Radioactive _ Waste Ouestior)
RESPO_NBE TO _ AQUATJC RESOURSE OUESTIONjl 1.
Some changes have been made to the circulating water system pumps and motors.
These changes have not resulted in an increase in total permitted flow.
Therefore,;,the aquatic resource impacts are not expected to bc different than at the time of initial unit operation.
4 m
- 2. On Septetber 18, 1981 EPA issued a notice of violation for discharges from the evaporation condensate storage tanks (ECST),
the laundry and shower sump tank (LSST), and the regeneration waste neutralization tanks (SDT-1).
fps worked with EPA to resolve the violation.
Administrative Order No. 83-17 (wcab) imposed effluent 1. imitations on these discharges.
These point sources are now covered by NPDES FL000159.
Since theses low volume sources have been limited in the NPOES permit there have been occasional exceedances of the ef fluent limitations. To the best M our knowledge, there have been no adverse aquatic resource impacts related to these exceedances.
There have been some minor exceedences of the 17. 5*F delta T limit.
Since the permitted delta T limit is high, these minor exceedent s would not be expected to increase mortality to entrained 3rganisms.
This is true because the EPA assumes 100%
mortality at the permitted delta T limit.
It is not expected that the delta T exceedences have resulted in any impacts to aquatic resources.
Waste discharges from the evaporation 3.
Low Volume Wastes condensate storage tank (ECST), the laundry and shower sump tank (LSST), and the regeneration waste neutralization tanks (SDT-
- 1) which were unpermitted have been incorporated into the NPDES permit.
These limits were established in January, 1983.
Emergency Need for Power - FPC could declare an energency need for power due to conditions on the Florida power grid system.
During this period temperature limits were not applicable.
EPA determined this authority was not justified, and this provision was deleted from the NPDES permit in September 1988.
Delta T - In order to minimize impacts to aquatic resources due to entrainment, FPC is required to reduce total site flow during a portion of the year.
With this requirement, EPA has deleted the delta.T temperature limitations.
This was incorporated in the 9-1-88 NPDES permit, bu delta T limitations will remain in effect until the site flow reduction project is completed.
- 4. Please refer to the enclosed Section 316a and 316b studies conducted.
- 5. Please refer to the enclosed Section 316a and 316b studies.
6.
Please refer to the enclosed Section 316a and 316b studies.
- 7. Other uses of the waters near Crystal River site are primarily commercial and recreational fishing and boating.
No data is available to document whether boating has increased or 5
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decreased.
S.ince two coal units were already present at the time of construction of unit 3, it is unlikely that unit 3 has had any impact on the amount of u seational boating.
Comments presented at the publAc hearing on the 1988 NPDES per ait were varied, but most indicated that commercial and recreational fishing were still viable industries in the vicinity of Crystal River Site.
Actual creel data or harvest data cre not readily available.
- 8. Discharges of solids from the Withlacoochee River and Cross Florida Barge Canal contribute sediment loads which impact the seagrass communities.
Erosion of the dredged spoil islands, created during construction of the Cross Florida Barge Canal, also contribute sediment loads. It is FPC's position that these sources are the major contributors to seagrass impacts.
9.
Please refer to the enclosed Section 316a and 316b studies.
EPA determined that significant adverse biological effects were associated with the siting and operation of Crystal River Units 1,
2,
& 3.
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w EEBPONSE TO BOCIOECONOMIC_OUESTIONS 1.
1989 average number of workers was 768.
2.
Approved permanent complement was:
IgAI Positions 1978 192 1983 588 1988 792 3.
Outage data is:
Additional Workers Outace
.Date Cqs_t Durati2D A) 850*
Refuel VI 9/87
$28M 114 days B) 1,200*
Refusi 'v 3/85
$?SM 165 days' C) 1,563**
Pefucl VII 3/30
$28M 101 days i
- Estimated
- Not all on-site for full duration occupatiqpal Dose Estimates for a Typical Planned Outace 1.
Adelitional Workers 1,500 wcirkers(800 expected for future outages) 2.
Length of Planned Outage 50 days 3.
Occupational Doses Total Permanent contractor Staff Staff i
Refueling Operations om 35 rem 35 rem ISI Work p.m 1 rem 9 rem Pump Maintenance
.c rem 20 rem O rem Motor Operated Valve Actuator Testing 10 rem 10 rem 0 rem Valve Maintenance 15 rem 15 rem 0 rem Health Physics, Decon, Radwaste 100 rem 10 rem 90 rem Steam Generator Work 60 rem 5 rem 55 rem Scaffolding and Insulation 80 rem 20 rem 60 rem Other Work 35 rem 20 rem 15 rem Totals 400 rem 136 rem 264 rem 7
i
Qccuoational Dose Estimates for an_
ISI Outace (Mid-Cycle Maintenance) l l
1.
Additional Workers 500 workers 2.
Length of Hidcycle Outage 35 days 3.
Occupational Doses Total Permanent Contractor Staff Staff Maintenance Activities Valve Work 20 rem 15 rem 5 rem Pump Work 10 rem 5 rem 5 rem Head Work 10 rem 10 rem 0 rom Other 20 rem 10 rem 10 rem Insoections and Test LLRT 5 rem 5 rem 0 rem Snubbers 5 rem 5 rem 0 rem Valves 10 rem 10 rom 0 rem ISI Work 20 rem 10 rem 10 rem MOVATS 10 rem 10 rem 0 rem Other 10 rem 5 rem 5 rem suonort Work Health Physics, Decon, Radwaste 30 rem 10 rem 20 rem Scaffolding and Inrulation
?.0 rem 5 rem 15 rem Other 30 rem 25 rem 5 rem Totals 200 rem 120 rem 80 rem Occupational Dose Estimates for Larcest Sincle Outace This case is nearly the same as that of a typical outage, i.e.,
Refuel VII involved the largest number of additional workers (1563) and the length was 101 days.
Radiological dose data are slightly higher (450 rem ) than the breakdown provided for a typical outage.
4.
Crystal River Unit 3's 1989 assessed value for tax purposes was l
$249,633,989, and the 1989 taxes were $4,210,243. Prior year figures are not readily available.
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