ML20114D254
| ML20114D254 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/31/1992 |
| From: | Lyster M CENTERIOR ENERGY |
| To: | NRC |
| References | |
| FRN-57FR29105, REF-WM-3 57FR29105, PY-CEI-NMSS-002, PY-CEI-NMSS-2, NUDOCS 9209080059 | |
| Download: ML20114D254 (2) | |
Text
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CENTERDOR ENERGY
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PERRY NUCL EAR POWER PLANT Mad Address P O DOX 97 Michael. Lyster, 10 CENTER ROAD PERRY, OH10 44081 VICL PREF %NT NUC1 EAR PERRY. OHIO 44081
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(216) m 3737 PY-CEI/NHSS-0022 L g
August 31, 1992 u
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G Chief, Rules and Directives Review Hanch U. S. Nuclear Regulatory Commission Vashington, D. C. 20555 Perry Nuclear Power Plant USNRC Proposed Concentration Averaging and Encapsulation Technical Position Gentlemen Pursuant to the letter dated June 26, 1992, from Richard L. Bangart, Director, Division of Lov-Level Vaste Management and Decommissioning, NHSS, ve respectfully submit the following comments on the NRC's Proposed Concentration Averaging and Encapsulation Technical Position, which provides clarification to 10 CFR 61.55.
On page 3 of the Proposed Technical Position, " Mixing of similar homogeneous veste streams," the statement is made "... mixing with the sole intent to dilute radionuclide concentrations to lover a vaste's classification is not permitted." This requirement is overly restrictive and does not provide any added measure d safety for the following reasons:
1.
It is understood that the classification requirements are designed to protect an inadvertent intruder from coming in contact with the vaste.
More stringent requirements are placed on the protection of the vaste as the concentration of certain radionuclides increases. Therefore, it is reasonable to assume that if non-homogeneous vastes of different classifications vere placed together in a disposal container, there is the remote possibility that an intruder may come in contact with the higher classified activated component or filter that was placed in the disposal container. This vould support the requirements of not mixing vastes to lover a vaste classification for these non-homogeneous vastes.
It is not, however, reasonable to asw ae that there is even a remote possibility that an inadvertent intruder would come in contact with a homogeneous vaste (e.g. soils and resins) and vill be able to segregate the higher classified vaste from the lover classified vaste. Therefore, there is no increase in risk associated with mixing homogeneous vastes.
2.
The mixing of homogeneous vastes is many times performed to reduce the radiation levels of the vaste container, thereby maintaining exposures AIARA for both the licensee and the burial facility.
The requirement prohibiting the mixing of homogeneous vastes to reduce classification requirements vould inhibit this ALARA pcactice, resulting in increased personnel doses, ow ' W m ~ s 9209080059 920031 PDR PR eww rec t
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USNRC PY-CEI/NHSS-0022 L August 31, 1992
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3.
The requirement that the licensee must document that the mixing of homogeneous vastes was "not undertaken solely to lover the classification l
of a vaste stream" effectively eliminates the ability to classify the mixture using volumetric or veight-averaged nuclide concentrations (method b).
It appears that the only way a licensee can show that the mixing of the vaste was not undertaken solely to lower the classification of a vaste stream is by classifying the vaste using the his; hest nuclide concentrations in any of the individual vaste streams contributing to the mixture (method a).
It is recommended that the position paper be revised to allow the mixing of homogeneous vastes, except tnat non-radioactive vastes may not be mixed with radioactive vastes for the purposes of reducing the classification of a vaste stream.
Thank you for_your consideration of our comments.
Should you need any further informatlon, please call.-
Sineerely, b>~
Hichael D. Lyster MDL: AllLt ss e
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