ML20155F834
| ML20155F834 | |
| Person / Time | |
|---|---|
| Issue date: | 07/12/1988 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | James Smith SOUTH DAKOTA, STATE OF |
| Shared Package | |
| ML20153C000 | List: |
| References | |
| FOIA-88-409 NUDOCS 8810130398 | |
| Download: ML20155F834 (14) | |
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003783 SS 6/28 1
. JUI. .' t 1988 i I
Mr. John J. Smith, Secretary South Dakota Department of Water and Natural Resources 1 523 East Capitol Pierre, South Dakota 57501-3181
Dear Mr. Smith:
We have reviewed your reouest tc Chairran Zech regarding disposal of i approxima tely 270,000 tons of sewage ash at the Tennessee Valley Authority's (TVA's) uranium mill site near Edgemont, South Dakota. This is an NRC-licensed .
J
, mill in the process of being decommissioned. Your letter states that the sewage ash has been found to be non-hazardous waste and, therefore, that it I
could be used as fill material in the tailings disposal cell, if the ongoing i studies show that it has suitable chemical and physical characteristics.
A: NRC staff has previously informed your staff, such a request needs to be submitted to NRC by the licensee as an amendment or modification to its approved reclamation plan. The NRC does not regulate the disposal or use of any waste except that produced from NRC licensed activities. However, a ;
licensee must demonstrate that any material proposed for use as part of the i tailings disposal *, ell is clean, st 51e and fits acceptably into the overall I reclamation plan in such a way tnat would not impair the site's ability to l meet the requirements of 10 CFR Part 1 To date, the NRC has not received a rhdest for amendment er modific4 tion of l TVA's reclamation plan to allow use of the sewage ash in the tailings disposal cell at the Edgemont site. A decision to submit this request lies entirely with the licensee. The NRC staff will consider such a request if submitted by TVA.
Please contact Paul Lohsus at (301) or FTS 492-0553 if you have questions about this response.
Sincerely, g gup LThomosos, fr.
. Hugh L. Thempsen, Jr., Director OfR * + ' Nuclear Material Safety
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BYPRODUCT MATERIAL LICENSE NO. 22-08799-02 :
- f. UPDATED SAFETY ANALYSIS f '
SUPERSEDING 2 \ '
SAFETY ANALYSIS SUOMITTED WITii M NOMENT 4 :
e INTRODUCTION l 2
l 4 -
Northern States Power Company (NSP) currently has a CFR Title 10 Part 30 t j License for all byproduct radioactive material contained within the L
- Pathfinder Generating Plant. This updated Safety Analysis is submitted j 5 with an application te renewal c' the current license. The renewal ;
application will update the existing requirements to better represent '
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present conditions of tne operating plant. ;
- The Safety Analysis, associated with Amendment 4 to Byproduct Material [
j License No. 22-0879'.02, is hereby superseded by this document. Consistent t j with current regulatory guidance for license renewal, this document has ,
been made "free standing", without the need for reference to previously .
J submitted documents and information. Pertinent facility description and ;
! general information from the prior Safety Analysis is repeated in this 1
document. New information includes details of changes in the plant ;
status caused by the natural decay of radioactive material contained .
1 inside the facility since the submittal of the original Safety Analysis !
in 1972. The reduction in the amount of byproduct material contained by '
! . the facility reduces the potential for radiological hazards. ;
1 The Pathfinder Generating Plant has been converted from a nuclear -
i reactor facility to a fossil fueled generating plant. The nuclear ,
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portion of the plant has been dismantled in accordance with a dismantling ;
plan submitted to and approved by the AEC. The dismantling order was !
l issued on April 8,1971. l s ,
! The dismantling consisted of isolating the reactor building, fuel !
l storage pool and lower levels of the fuel handling building from the !
! remainder of the plant, the removal of all unused cont!.mmated piping !
j and equipment from the fossil plant, and the extensive decontamination l of accessable areas and equipment remaining in the fossil plant. !
i' lt is the objective of this document to describe the existing plant and
, support the conclusion that the presence and operation of this plant j j with the contained byproduct material inventory will not result in an l 1 unreasonable risk to the health and safety to the public. ,
j i j FACILITY DESCRIPTION l The Pathfinder Generating Plant is operational. The plant is manned 24 I hours per day. Access to the plant is administratively restricted to i plant personnel and authorized visitors, i I '
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The plant can utilize natural gas and m,noer six oil as fuel. The steam !
is supplied by three pack 39e boilers with a nameplate capacity of 235,000 .
l{
i lbs per hour each. The steam cycle consists of its generation in the
- boilers, passage through the turbine, condensation in the condenser and i pumped return to the boilers by way of two low pressure heaters, a i deaerator, feedpumps and a high pressure bester. ;
I Located within the Pathfinder Generating Plant is the Pathfinder Dismantled ,
) Facility. This facility consists of all the unused systems and e yipment l
- remaining as a result of Pathfinder's origin as a nuclear generating ,
j facility. As a result of the dismantling effort, the areas containing ;
, this equipment have been sealed off from the resinder of the plant. J These areas are the reactor building, the lower levels of the fuel }
handling buildir.g. the fuel transfer tube vault and the fuel storage [
pool. These areas function only as a repository of the radioactive j material they contain. ,
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- The byproduct material contained in the Pathfinder Generating Plant is !
' located within the following areas: the Pathfinder Dismantled Facility. l the Pathfinder Fossil System, and the Reactor Building Penetration Cage i Arce which only contains drumed radioactive waste. By far the greatest l portion of this material is located in the Dismantled Facility. The ;
j inventory in this area is presently estimated to be 16,500 Curies.
- The fossil system contains less than 0.041 Curies. This system consists of all the equipment in the fossil plant in contact with the steam i generated or condensate produced in the utilization of tne Pathfinder
, (- electrical power production system. The radioactive material in this !
system is the result of initial deposits accuinulated during the nuclear ;
operations period. Some of the equipment utilized in the nuclear plant .
j was later ennverted for use in the fossil plant, i The area in the turbine building basement, where the reactor system l
! penetrations into the reacto: containment were capped, is caged to l l isolate this area from the rest of the turbine building. This area will (
j be used to store solid radioactive wastes until sufficient quantities !
are accumulated to warrant offsite shipment for burial. l
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- All ef t19ent discharges from the Pathfinder Generating Plant are associated l j with the operation of the fossil plant. These eff'uents do not contain i l significant quantities of byproduct material (i.e., not above exempt I concentrations). The condenser off-gas and deaerator vent discharge l
directly into the buildings. Combustion gases and ventilation discharges i are passed into the atmosphere through separate stacks. All liquid I discharges including fossil system blowdown and cooling tower blowdown l
are discharged to settling ponds and not directly to the Big Sioux Riyer.
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SAFETY ANALYSIS The safety considerations associated with the operation of the Pathfinder 3
h Generating Plant are the possible exposure of personnel to significant rav.iation levels due to the presence of its radioactive material and the possible release of this material in harmful amounts from the contained a"eas. Each of these considerations for all three of the areas containing che radioactive material will be discussed separately.
[g s s !blg,33 } ga s g,g[,3a dj ga e t!y g,Ga tg[j a !,ga ly s is The pathfinder Dismantled Facility ,
The radioactivity contained in the Dismantled Facility consists of corrosion products plated on or activity induced in the piping or equipment components. In the lower levels of the fuel handling building approximately 0.211 curies of activity are contained in the equipment and piping. This activity consists mainly of Co-60.
Within the reactor building are stored the contaminated equipment and piping removed from the fuel handling building and turbine building as well as the equipment originally present in the building.
The activity contributed by the equipment and piping from the other ,
buildings is insignificant compared to the amount of activity '
originally present in the building. Nearly all of this activity is in the form of induced activity in the reactor internals and consists of mainly Co-60. Fe-55, and Ni-63. There are approximately 16500 Ci (1/1/79) in the Reactor Building.
( All the systems within the dismantled facility are drained and closed. Since virtually all the radioactivity is contained within these closed piping systems or forms an integral part of the components themselves, it would require complete deterioration of the piping and equipment and the outer facility containment barrier in order to release the activity. With only atmospheric corrosive action, it would take decades to deteriorate this piping and equipeent.
Because of the inherent nature of raoioactivity, by the time the piping and equipment were completely deteriorated the activity would have decayed to a small fraction of its original level. The probability of activity release is therefore unlikely.
With all potentially explosive or combustible materials removed from the areas before closures, the possibility of fires which could release the radioactivity to the environment is also unlikely.
Except for the personnel entrances provided for special inspection entries, all other possible entrances M re sealed by welding or concrete filling. Personnel entrances were made airtight, secured, and pidlocked. All entrances into the dismantled areas will be conducted according to pre-established ' Medures and the requirements of CFR Title 10 Part 20.
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I I A surveillance program is established to monitor the conditions of the isolated structure to check for water intrusion, measure radiation i j C levels on the exterior surfaces, and check for deterioration or !
faults in tM containment barrier. This provides reasonable assurances l
that the interity of the isolated structures will be maintained. '
t Accordingly, it can 5e concluded that a release of radioactive [
material from the dismantled facility is unlikely. [
The Reactor Building Penetration Cage Area 1 The reactor systems pioing penetratino through the reactor building l
]
containment into the turbine building basement was removed and the f penetrations were capped. Due to higher than acceptable radiation l l
levels about some of the caps, this area was caged and locked to ;
prevent general access, j i
l This area will also be used as a storage location for solid radio- l active waste until sufficiert quantities are accumulated to warrant l
.l offsite sh 9 ment. All this waste will be stored in Federal 00T specification containers. Shipment would be made in accordance !
J with 10 CFR 71. ;
l It can be concluded that a release of radioactive material from i L this area is unlikely. [
3 ge Pathfinder Fossil System l The Pathfinder Fossil System contains certain pieces of equipment !
I that were also used during reactor operations. Small amounts of i j
radioactive contaminants from this equipment have been distributed l 1 throughout much of the fossil system. l To reduce this inventory of radioactive material to as low as practical. NSP undertook an extensive decontamination effort priu !
to the initial startup of the converted fossil system, has on l l several occasions entered the accessable areas within the system i and removed all crud buildup found, and during the dismantling !
- effort removed unnecessary contaminated equipment from the system j l and attempted even further decontamination of the equipment remaining. ;
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{ These efforts along with natural radioactive decay have reduced the '
inventory cf radioactive material to less than 0.041 curies.
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! Radiochemical analysis has identified Co-60 as the only significant nuclide remaining in the system. Although minute releases of j activity from the system can occur as a result of liquid discharge, air particulates or contamination spread during special maintenance j operations, the probability of occurrence is very low because the i srall amounts of activity remaining in the system are contained in i stable oxide scale. Previous entrance reports show through N.
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O O recorded radiation and contamination levels that the activity distribution in the fossil system results in very small and stable
( localized deposits. Water sampling records since 1972 indicate that less than I microcurie / year has been released in ef fluents.
Radiation level surveys have shown that hot spots are stable and decaying as expected. Contamination surveys have not revealed significaat contamination spread. Continuous monitoring during startup and periodic monitoring of the off-gas discharge and plant areas since dismantling have found no detectable radioactive contaminants resulting from the discharge of the condenser off-gas, the discharge of the deaerator vent or the occurrence of unavoidable
$ team leaks into the ouildings.
Accordingly, it can be concluded that releases of radioactive material as a result of the operation of the Pathfinder Fossil System are very unlikely.
During the operation periodically blowdownoforthe fossil drain the plant systemit becomes (normallynecessary)to once/ year .
Also, normal operations result in a continuous loss of some water from within the system. This water contains exempt concentrations and normally an exempt quantity of radioactivity. Over six years of operating experience (since 1972) and 250 individual water 1 analysis have found:
o The (six year) average activity level of the water within the ,
system was near the minimum detectable level (MDL). That at j no time did the activity level exceed 57. of Part 20 MPC values
(. for the Zn-Co mixture.
l o That almost all of the levels were below one per cent of Part 20 MPC values. In 1978 no san:ples were found with activity i levels in excess of 3.8 x 10'8 uCi/ml. l o That there has been a gradual decreasc occurring in the activity l levels of the water within the system indicating a corresponding decrease in the release rate of the material from the inner surfaces of the system. 477. of the water samples checked in i 1969 were less than 1 x 10~7 uti/ml, 59% in 1970, and 747, in I 1971. But since 1972 the vast majority of samples have been at the MOL. This has made trend analysis difficult because i tne levels are too low to note a trend. i l
o That the activity is tightly entrapped within stable oxide scales in the system and the ultimate removal mechanism will be dacay. The last cleanout attempt of the mud drums, deaerator and hotwell resulted in less than tnree millicuries rco.ovoo. l l
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f O O o That a general decrease in crud accumulation is occurring--mud drum, deaerator and hotwell cleanouts in 1969 resulted in the removal of 32 mC) of activity; in 1970 22 mci of activity; cnd
(- in 19713 mci of activity.
Further, the operating characteristics of the plant are such that on an annual average for every !twe generated, approximately eleven :
gallons of water is lost frc . too fossil system and 260 gallons of cooling water is discharged from tne plant to the settling ponds; or the plant has a built-in dilution factor of about 20. However, the unit is only used for peaking capacity. It was used for less j than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> in 1977.
Accordingly it can be concluded tnat iow level liquid radioactive discharges from the Pathfinder fossil plant will occur; however, such discharges are not likely to exceed CFR Title 10 Part 30 exempt concentration levels and on an annual average are not likely to exceed one per cent of Part 20 MPC levels. The discharges are conveyed to settling ponds.
Surveillance has been performed to periodically check the radioactivity levels of the water contained witnin the system and the air activity levels 'about the plant. This program will be discontinued upon the ,
renewal of Byproduct Material License No. 22-08799-02 in 1979, due '
to the backgrcund or near background activity levels of the water
' and air samples over tha seven years since the program was initiated.
A;cordingly, it can be concluded that a release of radioactive j
(
material from the fossil system during maintenance activities is .
not likely.
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All areas external to the Pathfinder Dismantled Facility have been decontaminated to the extent practical in an attempt to achieve the limits specifiec in the AEC "Guidelines for Decontamination of Facilities l
! ard Equipment Prior to Release for Unrestricted Use or Termination of i License for Byproduct. Source, or Special Nuclear Material". For i
- reference this document may be found as Attachment A to NUREG-0436, i 1
The level of unrestricted area ree.ovable beta-gama contamination !
i specified in the Pathfinder Byproduct Material License is 1000 dpm/100 cm2 The level of direct radiation exposure permitted in unrestricted i areas is specified in the Pathfinder Oyproduct Material License. The i i Pathfinder radiation level limits are:
! l 4 mr/hr at I cm or when averaged over 10 square meters
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.'2 mr/hr at I cm !
with localized areas up to
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1 mr/hr at I cm Hot spots may exist above 1 mr/hr at I cm but these levels will not , !
extend into normal operating areas, shall be posted and access of non.
employees into areas containing hot spots shall be controlled. !
The Pathfinder Dismantled Facility The Pathfinder Dismantled Facility is isolated and sealed. Except [
for possible future internal inspections, no areas within the facility are open to normal personnel access. These areas are ;
restricted areas. All entrances into these areas will be corducted t in accordance with established precedures and CFR Title 10 Part 20 :
l regulations. Records of all entries shall be maintained.
Radioactive contamination levels on all the accessable exterior i surfaces of the dismantled facility are presently below 100 dpm/100 ;
2 cm smear area. !
Except for that pertion within the Reactor Building Penetration f Cage Area, all rallation levels on the exterior of the dismantled .
facility are below the Pathfinder radiation level limits.
A surveillance program is established which includes the surveying
(- of the external areas of the dismantled facility for radiation levels, water intrusion and pnysical deterioration. These surveys will be conducted every eighteen months (+ one month). In addition, t a survey of all af fected areas will be performad any time a conditien has occurred or is detected that may have or has jeopardized the integrity of the containment barrier of this area.
Accordingly, it can be concluded that the presence of the Pathfinder Dismantled Facility with its contained byproduct material is not likely to result in significant or unreasonable radiation exposures to plant personnel or the general public.
The Reactor t3uildino Penetration Cace Area The reactor systems piping pentrating through the reactor building containment into the turbine building basement was removed and the penetrations were capped. Decontamination efforts could not reduce the radiation levels about some of these caps to below the Pathfinder 1 radiation level limits. This area was therefore caged anc lor.ked to prevent general access.
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The highest radiation level reading at contact with these caps is f- 2.0 mR/hr. The radiation levels about the general walk areas 1
( within the caged area presently range from 0.1 mR/hr to 0.3 mR/hr.
The radiation levels at the cage perimeter are below the Pathfinder radiation level limits. ,
t
- This cage area is used as a sterage location for solid contaminated
! waste until sufficient quantities are accumulated to warrant offsite i 3 shipment. All of this waste is stored in Federal DOT specification -
1 containers and will be located so as not to cause radiation levels
- exterior to the area in excess of the Pathfinder radiation level 4 limits.
! This area in a restricted locked area. All entrances into the area f
. will be conducted in accordance with CFR Title 10 Part 20 regulations. !
! A surveillance program is established which includes the surveying i of the cage area for radiation levels. These surveys will be l cunducted every eighteen months (+ one month). In addition, a i survey of all af fected areas will be performed any time a ecndition j has occurred or is detected that may have or has jeopardized the l
- integrity of the containment barrier of this area. '
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! Accordingly, it can be concluded that the presence of the Reactor
'i Building Penetration Cage Area and its use as a radioactive material ,
storage area is not likely to result in significant or unreasonable !
radiation exposures to plant personnel or the general public, i i The Pathfinder Fossil System i
, J i The Pathfinder Fossil System contains less tnan 0.041 curies of l
! radioactive material. All of tnis material is the result of I deposits accumulated in those items of equipment that were also ,
j used during reactor operation. Essentially all of this activity is i entrapped within the oxide scales of the system and even though corrosive and errosive actions have resulted in t5e distribution of
} small amounts throughout much of the new fossil system, the major 2 portion of this material remains where originally deposited.
Except for maintenance activities, the fossil system is sealed.
q Access to its interior requires equipnent disassembly. Entrances
, into components of the Pathfinder Foss11 System where the radiological l hazard potential is unknown or where t significant radiological i hazard is known to exist will be in accordance with procedure and i records will be maintained. Signific0nt spccial maintenance of the Fossil System which could cause a radiological hacard (e.g., welding of mad drums) will be perfore.ed with odcquate radiological protection prescribed. All entrances will be conducted in a manner that
- complies with CFR Title 10 Part 20 reiulations.
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n Radioactive contamination levels on all accessible exterior surfaces of the fossil system are pmently below 100 dpm/100 cm2 stear i
area.
l l The radiation levels on the exterior surfaces of the fossil system I
generally fall below the Pathfinder radiation level limits; however,
, specific hot spots do occur on certain equiprcent and piping in I excess of tnesc level 3. Reasonabic efforts have been expended to l decontaminate this equipment and pipirg, but a point has been I reached where further decontamination ef forts will be economically i burdensome. Over six years of radiation level surveys have shown l that these spots are stable and decaying as expected, l
All of these hot spots except one are located in the lower levels
( of the turbine builoing on equipment converted from the former
- nuclear plant. Tne one exception is located on the undarside of l the boiler blowdown flash tan' x discharqe cooler in the boiler l buildim blowdown pit. All of these hot spots except six do not I creetc h radiation area in excess of 1 mR/hr at one foot. Tne six cxceptions arc Iwated in the turbine building caseiTectt on the l cordenser tctucil.
None of these tot spots crette a radiation area extending into the normal daily oprating areas. Over six years of general area surveys have shewn that the background radiation in these ueas does not exceed 0.1 tR/hr. Routine plant operation in thtse areas
- requires i maximum of four hours occupancy per operator per week l ( and rarely if at all are close approaches to any of the het spots required. All of these hot spots have been marked with warning signs which caution operating personnel to limit exposure.
l Personnel radiation exposure records maintained over tne tuc years prior to dismantling have demonstrated that actual exposures to plant pn sonnel due to the presence of these hot spots was nil.
- None of the operating crew received greater than 40 mR total recordable
! exposur e during the entire two. year period. Even this extresely low value is not truly indicative of actual present day exposures from the fossil system because during most of this period the Dismantled Facility aas accessible.
It should also be noted that all of these hot spots are located in I areas that, during normal operations are not occupied. Further.
I these areas are inspected briefly at least once every four haurs by l
operators making their routine plant rounds. The "accidental" undetected wandering of any person into thesa areas for the length I
of time required (approx. 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> / quarter) to obtain sigaificant exposure is unlikely.
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Q-A surveillarce program has been implemented and continued f rom the
- time of the conversion of the Pathfinder facility from nuclear to
(' fossil fuel operation until 1979. The program included frequent and extensive surveys of the external areas of the fossil system for both radiation and contamination levels.
The require-ents of 10 CFR 20.201 are to make or causc to be made such surveys as may be necessary to C0mply with the regulations of Part 20.
In order to comply with these regulations, considerations r.ust be mace to potential external and internal exposure, and the potential for release of raoicactive material to the environment.
The fossil system contains less than 0.041 curies distributed throughout the entire system. Air surveys and water samples over the past six years resulted in levels at or near minimum detectable activities. Which indicates that daring normal operation there will be no liquid effluents in excess of exempt concentrations and no airtorae levels above background.
Fossil plant surveys for radiation and contamination levels and previous exposure records show that external personnel exposure due to the radiation from the fossil system is ex'.remely low.
The calculated activity remaining in the fossil system and tne e previous survey results provide evidence sho ving that the potential l
g for personnel exposure and radioactive material release to the environment due to the normal operation of the Pathfinder Fossil Systen is .inimal. Therefore during normal operation, routine fossi",+ plant surseys for radiation, contamination, airborne and water radica;tivity levels are not required. The appropriate surveys will be r,ade, as necessary and in accordance with procecures, for entrances into corponents of the fossil system tihere the radiological hazard is unknown or where a significant radiological hazard is knNn to exist. These abnormal operations represent the only potential fer internal personnel exposure or release of significant effluents. Compliance with 20,201 will be achieved by surveys during these abnorraal operations.
Accordingly, it can be concluded tnat the presence and operation of the Pathfinder Fossil System with its contained t,yproduct :raterial is not likely to result in significant or anreasonable radiation exposure to plant personnel or the general public.
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El