ML20127P592
| ML20127P592 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/25/1985 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| References | |
| 0279A, 279A, 4410-85-L-0138, 4410-85-L-138, NUDOCS 8507020462 | |
| Download: ML20127P592 (7) | |
Text
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Nuclear
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Route 441 South Middletown, Pennsylvania 17057-0191 717 944-7621 TELEX 84 2386 Writer's Direct Dial Nurnber:
(717) 948-8461 4410-85-L-0138 Document 10 0279A June 25,1985 TMI Program Office Attn: Dr. B. J. Snyder Program Director US Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Snyder:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 10 CFR 20.311 Exemption Request GPU Nuclear letter 4410-83-L-0259 dated October 26, 1983, requested from the State of Washington a variance to the Class "A" waste criteria of 10 CFR 61.55 regarding the TMI-2 EPICOR II liners. This variance request proposed an increase in the upper Class "A" limit for Sr-90 from 0.04 uC1/cc to 1.0 uCi/cc. The State of Washington forwarded this request to the NRC for their technical review.
On May 8, 1985, the NRC transmitted a memorandum to the State of Washington recommending approval of GPU Nuclear's variance request. This recommendation was based on an NRC safety evaluation performed in October of 1981.
However, in order to implement this variance request, GPU Nuclear requires an exemption from the requirements of 10 CFR 20.311(b) and 20.311(d)(1), (2), and (3). Specifically, exemption is required from those portions of the above regulations which require the classification of wastes in accordance with 10 CFR 61.55. Therefore, based on the attached evaluation, GPU Nuclear is requesting exemption from these requirements.
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l GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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4 Dr. B.-J. Snyder-June 25, 1985 4410-85-L-0138 In addition, enclosed for your information is a copy of GPU Nuclear's
. variance request to 10 CFR 61.55 which, based on discussions with the State of Washington,- GPU Nuclear expects to be approved. Upon receipt of the State of Washington's approval, a copy will be forwarded to your office.
Sincerely,
/ 64 F. R. Standerfe Vice President / Director, TMI-2 FRS/RDW/eml Attachments cc:.. Deputy Program Director - TMI Program Office, Dr. W. D. Travers l
l
ATTACHMENT (4410-85-L-0138)
INTRODUCTION GPU Nuclear letter 4410-83-L-0259 dated October 26, 1983, requested from the State of Washington a variance to 10 CFR 61.55 regarding the TMI-2 EPICOR II resin liners.
This letter proposed that the EPICOR II resin liners be categorized as Class "A" waste and, therefore, be buried in a dewatered condition. Accordingly, GPU Nuclear proposed increasing the upper Class "A" limit for Sr-90 from
.04 uCi/cc to 1.0 uCi/cc..
In order to implement this variance request from 10 CFR 61.55, GPU Nuclear is requesting exemption from the following regulatory requirements:
GPU Nuclear is requesting exemption from the portion of 20.311(b) which states, "dastes classified as Class A, Class B, or Class C in Section 61.55 of this chapter must be clearly identified as sucn in the manifest".
This section states, " Prepare all wastes so that the waste is classified according to Section 61.55 and meets the waste characteristics requirements in Section 61.56 of this chapter". GPU Nuclear is requesting exemption from this requirement for the EPICOR II liners, o
This section states, " Label each package of waste to identify whether it is Class A waste, Class B waste, or Class C waste in accordance with Section 61.55 of this chapter". GPU Nuclear is requesting exemption from this requirement for the EPICOR II liners, o
This section states, " Conduct a quality control program to assure compliance with Sections 61.55 and 61.56 of this chapter; the program must include management evaluation of audits". GPU Nuclear is requesting specific exemption from the requirement to comply with 10 CFR 61.55. The TMI-2 EPICOR II liners will comply with the requirements of 10 CFR 61.56.
Reason for Exemption The above regulations, from which exemption is requested, require the licensee to comply with the waste classification requirements of 10 CFR 61.55.
i ATTACFNENT (4410-85-L-0138)
Under 10 CFR 61.55, the TMI-2 EPICOR liners would be classified as Class "B" waste and, therefore, would require stabilization, via solidification, in accordance with 10 CFR 61.56. However, compliance with the Class "B" conditions of 10 CFR 61.55 would result in an increase of burial volume and ALARA concerns because:
o EPICOR II liners are used for miscellaneous processing and for polishing the effluent of our Submerged Demineralizer System (SDS). These liners are sodium limited rather than curie limited. As a result, the present curie loadings on these resins cannot be increased above their current 1 uCi/cc level because these resins become chemically depleted.
Therefore, stabilization via solidification of resins at this level would result in a 30 to 40 percent increase in volume due to solidification efficiency.
o The EPICOR 11 resin liners have no insitu solidification capability; the resins would have to be sluiced from the EPICOR liner into another container. The sluicing activity and volume increase from solidification would cause additional handling of the EPICOR liners. This additional handling would increase personnel exposure at both TMI and the burial site, and would increase the potential of a radioactive release accident.
Compliance with the current Class "A" conditions of 10 CFR 61.55 would also result in an increase of burial volume and ALARA concerns because:
o Due to the accident at TMI-2, there is a higher concentration of Sr-90 in the waste stream than normal.
Therefore, implementation of the 10 CFR 61.55 Class "A" limit for Sr-90, i.e., 0.04 uCi/ml, would result in approximately ten (10) times more waste as compared to the proposed Sr-90 limit of 1 uCi/cc.
Alternative Methods o
10 CFR 20.311(b) and 20.311(d)(1), (2)
In lieu of the waste classification requirements of 10 CFR 61.55, GPU Nuclear will classify the TMI-2 EPICOR II liners in accordance with GPU Nuclear letter 4410-83-L-0259 dated October 26, 1983. This classification will be annotated on the shipment manifest. GPU Nuclear will comply with all other requirements of these regulations.
GPU Nuclear has and will continue to conduct a quality cor.urol program for the TMI-2 EPICOR II liners. In lieu of assuring compliance with 10 CFR 61.55, our quality control program will assure the compliance of the subject liners with the criterion of the requested variance to 10 CFR 61.55.
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ATTACfNENT (4410-85-L-0138)
Safety Evaluation Justifying Change The NRC staff performed an evaluation in October of 1981, at the request of GPU Nuclear, to determine the Sr-90 concentration limit for an unstablized EPICOR liner that would be acceptable for burial at the Hanford site. The results of the NRC's evaluation show that a concentration limit of 24 uCi/cc of Sr-90 would be acceptable for the TMI-2 EPICOR II liners. GPU Nuclear's variance request to 10 CFR 61.55, which proposed an upper Class "A" limit of 1.0 uCi/cc for Sr-90, is very conservative in comparison to the results of the NRC's safety evaluation.
Therefore, an exemption to the waste classification requirements of 10 CFR 20.311(b), and 20.311(d)(1), (2), and (3) will not jeopardize the health and safety of the public.
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ENCLOSURE (4410-85-L-0138)
OPU Nucleer Corporation
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==, se Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
October 26, 1983 m-4410-83-L-0259 w.
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State of Washington D:partment of Social and Health Services At'en:
Mr. Lee Gronemyer Radiction Control Section Mail Stop LF-13 2*'%'/IT m -6 Olympia, WA 98504 n. u'",". r. o".-
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Three Mile Island Nuclear Station, Unit 2 (TMI-2)
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Operating License No. DPR-73
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m, Docket No. 50-320 d ' '**_;"," '
?y 10 CFR 61 Exemption gg['u'. -
,,j Ide t eo r e -P.r. ip Essed on recent conversations between you and members of my staff, EU*L N '"'
GPU Nuclear has been informed of the State of Washington's intentiot T.;',n";;w,,
a' to change the license of the Hanford Disposal Site to implement a+ ' e appropriate requirements contained in 10 CFR Part 61.
It was also UEU'.i."i learned that this license change is intended to become effective
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by the end of this year.
Although GPU Nuclear has not, as of yet, hed the opportunity to study this change, we understand that the n:w license will recuire shipments to the disposal site to be
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classified in accordance with the requirements in 10 CFR 61.55 and most the waste characteristics requirements of 10 CFR 61.
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The purpose of this letter is to request, from the State of 7 "-
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Wachington, a variance to this change so that EPICOR II resin liners oo. 3 M 2,
could be classified as Class "A" waste and, therefore, be buried in
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e d; watered condition as is the current case.
Under the current v'
license these EPICOR II resin liners comply with condition 27j in i
thet the specific activity of materials with half-lift greater than fiva (5) years is less than one (1) uCi/cc.
Under 10 CFR Part 61.55, however, these liners would be classified as Class "B" waste cnd require stability in accordance with 10 CFR Part 61.56.
Tcble 2, Column 1 of 10 CFR Part 61.55 lists the maximum concentration for Class "A" waste.
Isotopes of interest to the TMI-2 Recovery Program are Sr 90 and Cs 137.
The limits for these isotopes are 0.04 uCi/cc and 1 uCi/cc respectively.
For the rest of the nuclear industry, t.hese values are a relaxation of the current license condition 27j.
However, due to TMI's unusually high Sr 90 and Cs 137 ratio, these values are more restrictive.
Implementation of the more rostrictive Sr 90 criteria for unstabilized waste (Class "A") at TMI GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
ENCLOSURE (4410-85-L-0138)
'Mr. L2e Grontmyar 4410-83-L-0259 would result in the generation of approximately ten (10) times more waste than would be generated under the current limit.
Compliance with the proposed license Class "B" conditions would also result in an increase of burial volume and ALARA concerns.
EPICOR II 1
liners are used for miscellaneous processing and for polishing the effluent of our Submerged Demineralizer System (SDS) and they are i
sodium limited rather than curie limited.
As a result, the present curie limits cannot be increased above their current 1 uCi/cc level because these resins chemically deplete at this level.
Stabilization i
via solidification of resins at this level would result in a 30 to 40 percent increase in volume due to solidification efficiency.
Because the EPICOR II resin liners have no insitu solidification capability, the resins would have to be sluiced from the EPICOR liner into another container.
The sluicing activity and volume increase from 4
solidification would cause additional handling and, therefore, personnel exposure at both TMI and the burial site leading to ALARA concerns along with the possibility of a radioactive release.
1 The NRC staff performed an evaluation in October of 1981, at the request of GPU Nuclear, to determine the Sr 90 concentration limit for an unstabilized EPICOR liner that would be acceptable for burial
^
at the Hanford site.
The results of the NRC's evaluation show that a concentration limit of 24 uCi/cc of Sr 90 would be acceptable for waste to be considered Class "A" waste under the criteria used to develop the limits in 10 CFR Part 61.
A copy of the NRC's evaluation is enclosed for your information.
l The limits expressed in 10 CFR 61 are for the burial of Class "A" waste at a humid site and at normal burial depths, less than three (3) meters.
Provisions for exemptions from specific limits are provided for within 10 CFR Part 61 if the aerformance objectives can be met by consideration of options such as burial at an arid site and at a depth greater than five (5) meters.
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l Based on the NRC's analysis, GPU Nuclear is requesting a variance to
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allow a 1 uCi/cc limit on Sr 90 as the upper Class "A" limit for TMI EPICOR II waste.
All other Table 2, Column 1 limits would remain the same.
In addition, the liners would be requested to be buried at the bottom of the disposal trench.
It is our belief that this variance would be granted without any adverse effect on the health and safety of the public.
GPU Nuclear believes that this variance would be in compliance with the full intent of 10 CFR Part 61.
If you have any questions, please contact Mr. J. J. Byrne of my staff.
Sincerely,
/s/ J. J. Barton for B. K. Kanga Director, TMI-2 BKK/JJB/jep Enclosure CC:
Mr. L. H. Barrett, Deputy Program Director - TMI Program Office i
Dr. B. J. Snyder, Program Director - TMI Program Office m-.-
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ENCLOSURE
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UNITED STATES NUCLEAR REGULATORY COMMISSION 41-03c[y o
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k.,e...e October 22, 1 981 Docket No. 56320 Mr. John J. Barton Acting Director of TMI-2 Metropolitan Edison Company P. O. Box 480 Middletown, PA 17057
Dear Mr. Barton:
This is in response to Mr. Hovey's letter LL2-81-0214 of September 11, 1981, concerning the use of EPICOR-II ~for SDS affluent polishing, which included Metropolitan Edison's plans for EPICOR-II liner radioisotope loading and disposal.
In that letter, Met-Ed proposed to load the EPICOR-II liners to a maximum concentration of 1 ud/cc of isotopes with half lives greater than five years and dispose of the liners (with resins in a dewatered, but unsolidi-fled form) at the bottom of a disposal trench (approximately 10 meters deep).
Even though not specifically stated, we understand that Met-Ed is proposing to dispose of the EPICOR-II liners at an arid disposal facility.
Prior to final promulgation of Part 61, your proposal would be allowable under current NRC regulations. Subsequent to final promulgation of 10 CFR 61, the remaining waste covered by your proposal would require an exception to the l
Sr90 concentration limit (0.04 uc/cc) in Table 1 for Class A waste if the regulation is approved as proposed by the staff.
The NRC staff ha's performed an evaluation of the waste and disposal conditions i
proposed by Met-Ed. The evaluation indicates that the proposed conditions would be acceptable for the waste to be considered.a Class A unstabilized waste under 10 CFR 61, provided all other requirements of the proposed 10 CFR 61 for Class A wastes were met (e.g., the waste is segregated from Class B and C stabilized wastes and disposed of in a separate trench).
1 Since the existing commercial disposal sites are regulated by the individual States, acceptability of the waste form and disposal conditions would rest with them. However, it is our position that we would recommend acceptance of your proposal.
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r ENCLOSURE (4410-85-L-0138)
Mr. John J. Barton,
It is requested that you continue your careful analytical program to determine the content of these.1sotopes in the various waste containers to ensure conformance withthedis)osalcriteriadiscussedabove.
Sincerely, "k
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Bernard J. Snyder rogramDi$ector TMI Program Office Office of Nuclear Reactor Reaulation cc: See Service Distribution List e
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ENCLOSURE
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(4410-85-L-0138) r.
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' Acceptability for Disposal of Unstabilized TMI-2 Devatored Resin
- Wastes Havina Sr Concentrations Greater than 0.04 uc/cc l
Purpose:
The purpose of this evaluation is to determine the acceptabigty of disposing of unstabilised TMI-2 dewatered resin vastes concentrations greater than 0.04 uc/cc..the upper limit for ha p Srconcentrations for Class A wastes specified in the proposed 10 CFR Sr
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61.
References:
1.
Proposed rule,10 CFR 61 Licensing Requirements for Land Disposal of Radioactive Waste, Federal Register, Vol. 46, No. 142, July 24, 1981, pp. 38081 - 38105.
2.
Draf t Ehvironmental Impact Statement on 10 CFR 61 " Licensing Require-ments for Land Disposal of Radioactive Wasce," NUREG-0782, Appendix G.
3.
INVERSI code run, June 12, 1981.
Results:
Disposal of THI-2 dewatered resin wastes having Sr concentrations less than 24 ve/cc would be acceptable for disposal in an unstabilized condition at depths greater than 5 meters at an arid disposal site.
If other isotopes listed in Table 1 of the proposed 10 CFR 61 are also present, these isotopes would also need to be accounted for using the concentration ratio factor identified in Table 1.
i Evaluation:
The proposed rule for low-level waste management, 10 CFR 61, includes a weste classification system (Reference 1). The upper cogentration limit for the disposal of unstabilized wastes (Class A) for Sr is given as 0.04 uc/cc.
This limit was determined by evaluating the effects of intruder pathways at a reference disposal facility.
The j
intruder pathways included construction and agricultural cases. The l
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ENCLOSURE
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(4410-85-L-0138) 2 W'
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l draft environmental impact statement for 10 CFR 61 (Reference 2) provides a detailed description of these pathways.
The allowable concentrations for the intruder pathway evaluations in the waste caissification system are based on a performance objective that the intruder receives an annual dose to the whole body of less than 500 area.
The wucce classification system in Reference 1 requires that vastes buried at normal depths (includes di g sal at less than 3 asters) at either humid or arid sites having Sr concentrations greater than 0.04 uc/cc be stabilised. However,10 CFR 61 does provide for exemptions if j
the specific disposal conditions provide assurance that the performance l
In evaluating certain options which could provide objectives are mat.
the assurance that the performance objectives are mat, several y alternatives could be considered for unstabilized wastes with Sr concentrations greater than 0.04 uc/cc. These alternatives include:
burial at depths greater than 5 maters (that is, with att intruder bar' l, burial at an arid site, or a combination of these.
s the proposed waste would be unstabilized, the wastes would be
- Bec, Class A wastes would disposed of in a trench containing Class A wastes.
The basic be segregated from the stabilized Class B and C wastes.
assumptions in the Class A waste scenarios for normal depths and deeper depths (greater than 5 maters) are as follows:
1.
The reference disposal site is located in a humid Southeastern l
site.
1 2.
Inadvertent intrusion is made after institutional control is lost following an active control period of 100 years.
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At the time of intrusion the wastes have degraded to the extent I
3.
that they are unrecognizable as waste and undistinguishable
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from soil.
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4.
The weste degradation takes place at a rate independent of site location. That is,- the degradation is the same for an arid and a humid site.
1 less 5.
Agricultural activities occur only in vastes located than 3 asters below grade.
This is based on the construction of
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a residence with a basement excavated to 3 meters. The soils i
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ENCLOSURE
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(4410-85-L-0138) 3
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l removed for the building are graded about the residence and
. foods are grown in the excavated soils.
6.
Construction events noras11y taka place at depths less than 3 meters.
7.
When deep disposal is assumed, it is judged less likely that significant construction will taka place at these depths
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(high rise building construction, for example).
For wastes thus disposed, it is assuand that only 10 percent of the vastes are contacted and become available for dispersion into the air and subsequent inhalation by humans.
Further, potential direct l
gamma exposures from working on homogeneously contaminated ground aret assumed to be reduced by a factor equal to one mater of soil shielding (1/1200).
With these basic assumptions the allowable Sr" concentrations for the stated options were computed using the INVERSI code which uns also used to determine the limiting radionuclide coacentrations for the 10 CFR 61 waste classification system (Reference 3). The results are provided in Table 1.
Table 1 I
Allowable Sr Concentrations for Unstablized Wastes Allowable Concentration, Allowable Concentration, Construction Scenario, Agricultural Scenario, Option uc/cc uc/cc Unstabilized waste, ragular disposal 2.0 0.04 (normal depths) l Unstabilized waste, i
burial at depths l
greater than 5 asters 24 NA l
Agricultural activities are not assumed to take place for wastes
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disposed at depths greater than 5 meters.
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ENCLOSURE
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(4410-85-L-0138)
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.4 since the disposal effects for an arid and a huid site are assumed to be However, the the same, the allowable concentrations would be the game.
abovef evaluation has considered only the isotope Sr and has not g4 evpjusted g effects of other limiting long-lived isotopes such as C These Tc or I which might be present in a vaste of this nature.
isotopes. ave high migration potentials at humid sites but are generally h
not specifically measured at power plants due.to low concentrations and Allowing disposal of higher activity unstabilised analytic complexity.
l westes at humid disposal sites could result in increased groundwater migration of such limiting long-lived mobile isotopes as well as increased post operational maiutenance costs.
Since it is possible that TMI-2 westes might also contain some of these longer-lived isotopes in concentrations near their Class A limits, it is judged to be prudent to dispose of such higher activity unstabilized westes at an arid site where l
it can be assumed that migration is not a significant pathway.
Thisevaluation,therefore,conegdesthatdisposalofunstabilizedTMI-2 l
dewatered resin vastes having Sr concentrations up to 24 uc/cc would be acceptable provided the wastes were buried at depths greater than 5 meters at an arid disposal site.
Other isotopes listed in Table 1 of i
j Reference 1, of. course, would need to be accounted for using the 1
concentration ratio factor identified in Table b./
AW Date /4-81 Evaluation performed by
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