ML20205C012
| ML20205C012 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/23/1985 |
| From: | Hufham J TENNESSEE VALLEY AUTHORITY |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20205B991 | List: |
| References | |
| 0167M, 167M, TAC-R00179, TAC-R00180, TAC-R179, TAC-R180, NUDOCS 8608120229 | |
| Download: ML20205C012 (4) | |
Text
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o SN 1578 Lookout Place
' December 23, 1985
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Mr. William J. Dircks
-Executive Director For Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Dircks:
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DISPOSAL OF EXEMPT TRASH IN ACCORDANCE HITH 10 CFR 20.302 Enclosed are three copies of an application requesting permission to dispose of up to 200 millicuries of extremely low-activity radioactive waste in a sanitary landfill each year.
This request is made in accordance with the provision of 10 CFR 20.302. Also, enclosed are three copies of: (1) EPRI NP-3299, " Segregation of Uncontaminated Dry Active Haste," (2) " Impacts of the Disposal of Exempt Trash in a Sanitary Landfill," and (3) " Regulations Governing Solid Haste Processing and Disposal in Tennessee," in support of this request.
He believe the information contained in this application, and the enclosed reports, provide sufficient information to allow your staff to evaluate this request for an exemption under 10 CFR 20.302.
The specific limitations that we propose for such an exemption are:
(1) an annual disposal limit of 200 millicuries, and (2) a specific activity limit of two.nanocuries per gram averaged over any truckload.
He appreciate your prompt attention to this request.
If you have any questions or if we can be of any assistance please get in touch with P. J.
Hammons of my staff at FTS 858-2736.
Very truly yours, TENNESSEE VALLEY AUTHORITY J. H. Hufham Manager of Licensing DLL H: ALM Enclosures (3)
.. g cc (Enclosures):
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H. L. Abercrombie, NUC PR, Sequoyah E. A. Belvin, LP SS 62E-C C. C. Mason, MR 6N 458-C M. E. Rivers, 201 SP8-K H. S. Sanger, Jr., Ell 833 C-K
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0167m B608120229 860805 PDR ADOCK 05000327 P
e ENCLOSURE TVA'S 10 CFR 20.302 REQUEST In accordance with 10 CFR 20.302, Tennessee Valley Authority (TVA) hereby requests approval to dispose of extremely low-activity radioactive waste in an
_ area not licensed for low-level waste disposal.
Specifically, to dispose of.
low-activity trash from our Sequoyah Nuclear Plant by burial in the Summit sanitary landfill located in Hamilton County near Chattanooga, Tennessee.
This waste consists of dry industrial trash such as wood, paper, plastic, metal, protective clothing, and other nonhazardous materials generated in the operation and maintenance of the Sequoyah facility.
The waste volume is not expected to exceed 27,000 cubic feet (uncompacted) per year.
The waste specific activity will not exceed two nanocuries per gram, which is considered nonradioactive under 49 CFR 173.403(y) of Department of Transportation
- regulations and 10 CFR 71.10(a) of NRC transportation regulations.
No more than 200 millicuries of activity will be disposed of in the sanitary landfill each year.
The determination of the specific activity of the exempt trash will be done using a National Nuclear Corporation Waste Curia Monitor (WCM-10). A description of the WCM-10 and its use is given in the enclosed copies of EPRI NP-3299, " Segregation of Uncontaminated Dry Active Waste." This report was prepared by National Nuclear Corporation as part of a study, under the sponsorship of the Electric Power Research Institute (EPRI), to characterize the dry-active waste stream from nuclear power plants. A continuation of this study, focusing on the impact of an alternate disposal method, will be reported in a forthcoming final EPRI project report. Meanwhile, the calculational methodology and results upon which the final report is based are given in the report prepared as part of the study by The Analytic Sciences Corporation (TASC) and discussed below.
Use of the WCM-10 will be in accordance with site-specific Sequoyah procedures controlling (1) the collection and handling of trash bags, (2) recordkeeping of bag activities and weights, specific activities, and cumulative annual activity (to ensure that the annual activity limit is not exceeded), (3) calibration of the WCM-10, and (4) quality assurance surveillance of bag handling practices.
These procedures and the records of any trash sent to the sanitary landfill will be available for NRC review during plant audits.
The waste will be disposed of in the same manner as other nonhazardous material in the Summit landfill.
This landfill is licensed by the State of Tennessee and is operated in accordance with State regulations (three copies enclosed).
Haste will be placed in sealed green plastic bags and loaded into g
a garbage dumpster located at the plant for the disposal of other nonradioactive trash from " clean" areas in the plant.
The dumpster will be picked up by a private contractor when filled and transported to the Summit landfill for disposal.
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t Also, enclosed are three copies of a report prepared by TASC entitled,
" Impacts of the Disposal of Exempt Trash in a Sanitary Landfill." Contained within the report is a description of the methodology used to assess radiological impacts, an environmental analysis, and a cost analysis.
The report concludes that, based on waste-specific inputs and site-specific parameters, "the disposal in the Summit landfill of up to 200 mci of exempt trash from TVA's Sequoyah Nuclear Plant is feasible, cost-beneficial, and
-presents no undue risk to the public." It also concludes that the " predicted lack of low-level waste disposal space makes it essential that only waste defined as radioactive material be disposed of in licensed low-level waste disposal facilities" and that " materials, such as the exempt trash described in this report, should be disposed of in other suitable facilities." This is in keeping with guidance found in NRC IE Information Notice 83-05, " Obtaining Approval for Disposing of Very-Low-Level Radioactive Waste - 10 CFR Section 20.302."
The material classified as exempt trash is useless waste from which reuseable
- tools a".d other items have been removed and recycled to the extent possible in the plant.
The exempt trash will be placed into opaque plastic bags before disposal to prevent visibility of contents.
The potential for recycle is minimized since the waste is covered with earth by the end of each day at the landfill.
The methodology used for calculating the environmental effects in the enclosed TASC report was the IMPACTS computer code developed for NRC for use in evaluating exemption requests such as this.
The only exception taken in using the IMPACTS code involved the transportation scenario.
In looking at the actual waste transportation situation at Sequoyah, it was determined that the IMPACTS code overestimated the radiation exposure to the driver for the following reasons.
1.
Only one driver is used.
IMPACTS assumes that two drivers are used on each trip.
2.
Only 3.9 metric tons of waste is carried in each trip rather than 4.5 metric tons as assumed by IMPACTS.
3.
The trip including container pickup and unloading takes two hours instead of three.
4.
The actual distance from the driver to the waste in the truck is farther than that assumed by IMPACTS.
These differences result in a calculated dose of 14.1 millirem per year to one driver rather than doses of 38.7 millirem per year to each of two drivers.
These radiation doses can be compared to a measured dose of 13.2 millirem to a,
g common carrier truck driver during one shipment of low-level trash from Sequoyah to the Richland, Washington, disposal facility.
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Under TVA's National Environmental Policy Act requirements, an environmental review was prepared by the TVA staff concerning the shipment of exempt waste to the Summit landfill.
This r.eview concluded that this action is categorically excluded' pursuant to TVA Instruction IX ENVIRONMENTAL REVIEW and that no environmental assessment or environmental impact statement is required.
Upon your approval, we will pursue any licensing required by the State of
. Tennessee for solid waste disposal. Contacts will also be made with the landfill operator and the waste transporter at that time.
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