ML20211C823

Forwards Response to Questions Contained in Re Nasa License Reapplication for Plum Brook Reactors

ML20211C823
Person / Time
Site:	Plum Brook
Issue date:	09/18/1997
From:	Campbell D NATIONAL AERONAUTICS & SPACE ADMINISTRATION
To:	Mendonca M NRC
References
TAC-L79569, NUDOCS 9709260319
Download: ML20211C823 (10)

Text

• Natonal Aeronautes and Space Administration Lewjs Research Center Clevyland OH 44135 3'91

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• ',3 SEP 181997

%,% 0100 [j t; - /6j Huclear Regulatory Commission Non-Power Reactors and Decommissioning Directorate Division of Reactur Program Management Attn Mr. Marvin M. Mendonca, Acting Director Washington, DC 20555-0001

Subject:

Request for Additional Information (TAC No. 79569) ss.

State Mr. of Ohio, Donald cuyahogabeing J. Campbell, County,irst f duly swoen, says that Enclosed please find our response to the questions raised in your letter dated July 10, 1997, regarding NASA's license reapplication for the Plum Brook reactorr,.

If you have technical questions regarding this submittal, please contact the Plum Brook Reactor Engineer, Mr. Henry G.

Pfanner, at 419-621-3206. If I can be of assistance, please contact me directly at 216-433-2929.

And further affiant saith not.

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Donald J ampbe Directo Sworn tg bpfore me and subscribed in my presence this /5A day of .w*M4'[ A.D. 1997. 4

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2 Enclosures Ell T. NAFFAH, JR., Attorney MyN[n1Do"NsNom Section 147.03 R.C.

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• dhio Department of Health Attn Radiologf. cal Health Program Director )

P. O. Box 118 i Columbus, OH 43216 Ohio Environmental Pro?.ection Agency Division of Planning Environmental Assessment Section P. O. Box 1049 Columbus, OH 43216 Ohio Department of Industrial Relations _

Attn Chief, Boiler and Pressure Vessel Division ,

P. O. Box 825 Columbus, OH 43216 Ms. Celesta Lipp Bureau of Radiation Protection Ohio Department of Health P. O. Box 118 Columbus, OH 43216 l

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. RESPONSE TO REQUEST FOR ADDITIONAL INFOPMATION DATED 7/10/97  ;

NASA PLUM BROOK REACTORS l DOCKET NOS. 50-30 AND 50-185

1. Provide estimates of public radiological exposure and occupational radiological exposure, respectively, for proceeding with-decommissioning activities immediately, and at five, ten, and fifteen years from now.

Response

t The estimated radiological exposures from decommissioning the Plum Brook Reactors are shown below. These values are estimates based on data contained in the 1980 " Plum Brook Dismantling Environmental Report," which was previously submitted to the NRC. The original dose estimates have been adjusted to reflect radioactive decay. Supporting ,

calculations are provided as Enclosure 1.

Year 1997 2002 2007 2012 General Public Dose

• 3.1 1.9 1.4 1.1 occupational Dose

• 50.2 31.7, 22.6 18.8

' Doses shown are in Man *kom

2. Provide written verification from low level waste disposal facilities and associated organizations of the uncertainty of low level waste disposal availability that was expressed in l the NASA letter of December 20, 1996. Include assesseaents ,

of waste disposal availability for the same time periods as specified for assessment of radiological exposures (i.e., now and at five year intervals).

Response.:

NASA has investigated the availability of low level waste

, (LLW) disposal sites capable of receiving the waste expected to be generated by decommissioning the Plum Brook Reactors.

This investigation included discussions with personnel from the Department of Energy's National Low Level Waste Management Project, the executive director of the Midwest Compact, and personnel overseeing the operation of both the Barnwell, South Carolina, site and the Envirocare, Utah, site. Industry publications such as " Nuclear Waste News" were also consulted. As a result NASA was able to identify only two: commercial disposal sites which are currently in operation and capable of handling the waste expected to be generated during Plum Brook Reactor oecommissioning, and was  ;

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2 not able to identify any government sites. The Envirocare '

site in Utah appears to be available to accept only the Class A portion of the decommissioning waste; the Barnwell site in South Carolina appears to be currently available to accept both Class A and all of Plum Brook's higher classification

low level waste. Since a significant portion of the waste ,

generated by the decommissioning of the Plum Brook Reactors would be higher than Class A, NASA would need to utilize .

Barnwell as a disposal site.

NASA has concerns, however, about the reliable, long term availability of the Barnwell facility. Although currently i

open for use, it has on two separate occasions in the past i seven years refused to accept waste from generators located outside of South Carolina. '

NASA's concerns are reinforced by the information contained in the attached letter (Enclosure 2) from Mr. Virgil Autry,

Director of the South Carolina Department of Health and Environmental Control, Division of Radioactive Waste Management. Mr. Autry is the state regulator charged with overseeing the operation of the Barnwell Site. Mr. Autry states in his letter that... "the availability of access to the Barnwell facility is generally viewed from a year-to-year basis, and its continued availability could be curtailed by the S.C. General Assembly at any time."

Therefore, although the Barnwell waste disposal facility is available today, there is no guarantee that it will remain open for the duration of a large reactor decommissioning project, even if that activity were to begin immediately.

Further, there currently is no way to predict its

. availebility five, ten, or fifteen years into the future.

At the time of its December 20, 1996, response to the NRC, NASA believed that the opening of the Midwest Compact site, scheduled to occur in 2005, would provide the needed disposal ,

site access. Unfortunately, in June of this year, the Midwest Compact Jocided to halt further efforts to open a site. Mr. Greg Larson, Executive Director of the Midwest compact, has informed us that the Compact will now concen-trate on stabilizing access to the Barnwell and Envirocare 2 sites for generators in the Compact area. NASA will watch closely the progress of this new effort. NASA will also continue searching for other LLW site possibilities, includ-ing any belonging to the Department of Energy.

-3. Provide a discussion of the logistics and planning required to proceed with decommissioning activities immediately, and at five, ten, and-fifteen years from now. For example, I

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' updating decommissioning plans, scheduling work activities '

for expeditious completion of decommissioning, use of personnel that are familiar with the facility, and funding issues should be considered. i Response:  ;

The logistics and planning required to proceed with decommis- -

sioning activities immediately and at five, ten, and fifteen years from now are essentially the same. The first step in the planning process would be to update the 1984 Engineering Study, specifically in the areas of_ radiological inventory, ,

waste disposal site availability, and ectimated decommis-sioning cost and schedule. This updated information would be used by NASA management to determine the earliest date to start the decommissioning effort and to support the follow-on planning activities.

In advance of the proposed decommissioning date established by the updated engineering study, NASA would obtain the services of a contractor to prepare a Decommissioning Plan which would detail how decommissioning would be implemented.

The Decommissioning Plan would be submitted to the NRC along with a request for a decommissioning license.

Moreover, NASA would begin the process of securing funding to accomplish the decommissioning program. NASA management has already been alerted about the need to provide funding for the Plum Brook Reactor decommissioning project in advance of need. Definitive action on obtaining this funding is tied to establishing a proposed decommissioning date with input from the engineering study.

Upon completion of the Decommissioning Plan, NASA would begin the process of preparing. documents to obtain the services of a contractor to perform the decommissioning task. After receipt of a decommissjoning license from the NRC, NASA would select a decommissioning contractor and would begin the decommissioning effort.

Although it is desirable to utilize personnel who have extensive experience with the facility for the decommission-ing effort, it is not considered to be essential since most aspects of the facility are well documented. It is expected, however, that experienced personnel who continue to maintain the-facility in protected safe storage will also be available to assist with all phases of the decommissioning effort even if these occur five, ten, o" fifteen years in the future.

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4. ' Provide an estimate and discussion of the optimal time for '

decommissioning considering radiological dose estimates, waste disposal verifications and planning considerations above, and the regulations 10 CFR 50.82 (b) (4) which state  ;

that "(a]n alternative is acceptable if it provides for l completion of decommissioning without significant delay.

Consideration will be given to an alternative which provides ,

for delayed completion of decommissioning only when necessary  !

to protect the public health and safety." In your evalua-tion of the optimal time to decommission, specifically ,

evaluate how any proposed delay " protects the public health and safety."

Response

The optimal time for decommissioning will be after radio-logical decay has sufficiently reduced worker exposure levels a to well below the current mandated standard, after NASA has obtained assured access to a LLW site (or sites) capable of accepting its waste stream for the duration of the decommis-sioning activities, and after the required planning  :

activities are completed. .

While current radiological exposure levels appear to be sufficiently low to permit decommissioning to begin now, i meaningful decay and resulting reductions in worker exposure  :

levels are still occurring. These reductions and the benefit they provide to worker health and safety do not by themselves justify delaying decommissioning, but they are consistent with ALARA (As Low As Reasonably Achievable) and are a seri-ous consideration in providing the safest decommissioning

, scenario with the lowest negative impact on public health. .

At this time, NASA Lewis Research Center is working to obtain funding from NASA Headquarters to proceed with an update of the 1984 Engineering Study, which was identified as the first step in the planning process. As a part of the Engineering Study effort NASA will attempt to obtain a commitment from potential waste disposal sites as to when they will be able to accept the radioactive waste resulting from decommission-ing. NASA believes this commitment is necessary in order to responsibly carry out a decommissioning project which is i designed to protect the public health and safety. Specifi-cally, if NASA were to find itself without a suitable waste disposal site while-the Plum Brook Reactors were'in the

process of-being dismantled, public health and safety issues could arise since previously contained radioactive systems would now be partially disassembled and exposed, and the resultant radioactive waste would have to be stored on-site.

NASA believes that the planned update will help minimize the

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' risks which are perceived to exist in order to begin the decommissioning with an appropriate level of confidence.

5. Provide plans to submit annual updates on the above information.

Response

NASA proposes that updates to the above information be submitted as part of its regular annual report to the NRC.

. Enclosure 1

. Basis 'for Occupational and General Public Dose Calculations On March 17,1980, a letter was sent to the NRC requesting the issuance of a dismantling order for both NASA licenses. One of the enclosures with that letter was the

" Environmental Report, Plum Brook Dismantling, Febmary,1980".Section IV of that report, " Radiological Impact", detailed the expected dose levels as follows:

I Dose Category Dose (Man-Rems) Page Task Team 100.0 53 Staff & Support Personnel 17.0 53 Truck Drivers 18.0 53 General Public 8.2 58 Figure 1.1980 Estimated Dose Levels In the 1984 Engineering Study detailed surveying was performed end the quantities of specific radioisotopes present were recorded. Based on these values, the figures in the 1980 report for total Plum Brook Reactor Facility (PBRF) curie content, and the halflives of the various radionuclides, the following estimates of PBRF curie content present over time were made:

Year 1980 1997 2002 2007 _

2012 PBRF Total 211,712 78,760 49,763 35,404 29,482 Curie Content Percentage of 100 % 37.2 % 23.5 % 16.7 % 13.9 %

1980 value Figure 2. Estimated Curie Content of the Plum Brook Facility These figures are believed to be a fair representation of the overall decrease in the total PBRF curie content due to decay. Since dose rate is directly related to the amount of radioactivity present the decreasing percentages were applied to the estimated dose levels shown in Figure 1 (General Public - 8.2 man rems; Occupational - 135 man rems total) to generate the updated dose levels. The results are shown below in Figure 3:

l Year 1997 2002 2007 2012 Percentage 0.372 0.235 0.167 0.139 i General Public Dose 3.1 1.9 1.4 1.1 Occupational Dose 50.2 31.7 22.6 18.8 Figure 3. Updated Estimated Dose Levels l

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2 l P RO M D'I E P R O~I E CT P R O S P E R 2600 Bull Street  ;

I Columbia. SC 29201 1708 I

Q",,j5' $7 August 5,1997 HOARD:

Juha 11. Burnas churr a Mr. Robert Kozar, Chief i I

wmam v. iiau Jr.. nm Plum Brook Management Office l vweci=maa 6:00 Columbus Avenue ,

p, ia,,3,. Sandusky, Oli 44870 surewy Rkhard IL Jat4=mr. DDS Dear Mr. KoZar; This is in reference to Mr. Keith Peccook's letter of July 23,1997, regarding Brian K. Smuh availability of the Barnwell low-level radioactive waste disposal facility for long Rimincy L Orandy term access.

As you may know, the Barnwell facility was scheduled to close in January 1996.

Ilowever, the S.C. General Assembly decided to keep the facility open due to Nonh Carolina's failure to provide a site as required by the Southeast Compact Commission. The legislature also imposed a $235 tax to help fund educational commitments. Ilowever, there was no date established for closing the facility, nor to provide long term access and availability to waste generators throughout the country. Although a compact negotiating committee was also established by this law, there has been no action by this group to date.

Consequently, the availability of access to the Barnwell facility is generally viewed from a year-to-year basis, and its continued availability could be cunalled by the S.C. General Assembly at anytime.

Should you have any further questions, please do not hesitate to contact me at (803) 896-4244.

Very truly yours,

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Vir Aut , Direct Division of Radioactive i aste Management Bureau of Land & Waste Management KOZAR/sla SOUTH C AROLIN A DEP ARThtENT OF llE ALTil AND ENVIRONhlENT AL CONTROL

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