ML20212L147
| ML20212L147 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 02/28/1987 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20212L140 | List: |
| References | |
| NUDOCS 8703100257 | |
| Download: ML20212L147 (49) | |
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS d
SAFETY EVALUATION REPORT ,
RELATED TO THE ,
VOLUME RE00CTION DEMONSTRATION FACILITY BATTELLE COLUMBUS LABORATORIES WEST JEFFERSON, OHIO (Docket 70-8)
FEBRUARY 1987 87031gK077 370303 8
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TABLE OF CONTENTS P,a2' '
1 INTRODUCTION AND GENERAL DESCRIPTION OF THE FACILITY ............. 1 1.1 Background .................................................. 1 1.2 General Description of the Facility.......................... 2 1.3 Summary o f Principal Revi ew Matters. . . . . . . . . . . . . . . . . . . . . . . . . . 6 2 SITE CHARACTERISTICS ............................................. 7 2.1 Introduction ........................................... .... 7.
2.2 Site Location........................................... .... 7 2.3 Demography .................................................. 7
- 2. 4 Climate ................................................
2.5 Hydrology .............................................. .... 10
.... 10
- 2. 6 Geology and Seismology ...................................... ,
11 3
FACILITY DESIGN .................................................. 13 3.1 Introduction ................................................
- 3. 2 Design Criteria ....................................
13 13 ,
3.3 Ventilation ................................................. ... 14 3.4 Fire Protection ............................................. ...... 14 3.5 Physical Security ........................................... 15 -
- 3. 6 Material Handling ........................................... 15 3.7 Incinerator System ............................................ 15 4 FACILITY OPERATIONS .............................................. 23 4.1 Organization and Staf f Qualifications . . . . . . . . . . . . . . . . . . . . . . . 23 4.2 Training and Experience ..................................... 23 4.3 Compliance Experience ....................................... 24 4.4 Normal Operating Procedures ................................. 25 4.5 Material Control ............................................ 25 4.6 Emergency Plans ............................................. 26 4.7 Records ..................................................... 26 5 RADIATION PROTECTION ............................................. 27 5.1 Design Basis ................................................ 27 5.2 Radiological Safety Program.................................. 28 5.3 Occupational Radiation Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 5.4 Environmental Radiation Exposure ............................ 31 i
i 6 ACCIDENT ANALYSIS ................................................ 35 7 LICENSE CON 0!TIONS ............................................... 41 l
i 8 CONCLUSIONS ...................................................... 44 l
l 9 REFERENCES ....................................................... 45 i
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TABLE OF CONTENTS (Continued)
'Fiaures Page 1.1 Location of Proposed Incinerator at Batte11e's.............. 4 West Jefferson Nuclear Sciences Area 1.2 Schematic of Incinerator ...................................- 5 2.1 BCL West Jefferson Facility Location........................ 8-3.1 Incinerator System Arrangement ............................. 17 Table a Pa2' 2.1 Population Distribution Around BCL Site in 1980 ............ 9 5.1 Maximum Concentrations of Radionuclides at Ground Level from Normal VROF Operations ................................ 32
- 5. 2 Annual Dose to Maximum Individual Off-Site from l Normal Operations .......................................... 33
. 6.1 Dose at the Site Boundary from a Fire in the Waste Storage Building (Source Term: Reactor Material).................. 37
- 6. 2 Dose at the Site Boundary from a Fire in-the Waste Storage Buf1 ding (Source Term: Institutional Material)............ 38 6.3 Dose at the Site Boundary from an Explosion in the Incinerator and Ash Container (Source Term: Reactor Material) ......... 39 6.4 Dose at the Site Boundary from an Explosion in the Incinerator and Ash Container (Source Term: Institutional Material) ... 40 i
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..-- o-1 INTRODUCTION AND GENERAL DESCRIPTION OF THE FACILITY 1.1 : Background By letter dated August 15, 1983, -Battelle Columbus Laboratories (BCL or licensee)-
appiled:for amendment to NRC Materials License No. SNM-7 for their West Jefferson and Columbus, Ohio, locations. The request was for authorization to operate an incinerator for treatment of radioactive low-level w.aste (LLW) to demonstrate the safety and technical effectiveness of incineration as a method of LLW man-agement. Specifically, the amendment would authorize: receipt and possession of up to 50 curies of byproduct material in the form of LLW from nuclear util-7 ities and industrial and institutional organizations (including BCL wastes),
storage of the material in a new building, and LLW processing, product packaging and shipment under the byproduct material authorization of the license. The appitcation was subsequently amended by letters dated September 28, 1984, January 4, 1985, January 3, 1986, and March 10, 1986.
The application was reviewed under the provisions of 10 CFR Parts 20, 30 and 70.
In accordance with 10 CFR Part 51, the environmental aspects of the application have been reviewed separately and are addressed in the NR: staff's Environmental Assessment (issued June 24, 1986).
This report documents the staff's review and evaluation of the safety of opera-tion of the Volume Reduction Demonstration Facility (VRCF). Our technical review of radiological safety matters under the Commission's regulations with respect to amendment of Materials License No. SNM-7 was based on BCL's application and amendments thereto. The application is available for public inspection under 4
NRC Docket No. 70-8 at the NRC's Public Document Room at 1717 H Street NW, Washington, D.C.
We have reviewed the proposed design and operation of the VROF to determine whether NRC's safety requirements have been met. Many of the safety programs i to be used in the operation of the VROF are in use at the West Jefferson site 1
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and have been previously reviewed by the staff for licensed activities.
Therefore, these programs in use at BCL were not reviewed again in this report.
References to these programs are specifically noted where they are made throughout this evaluation. If an amendment to Materials License No. SNM-7 is granted, the facility must be opefated in accordance with the terms and conditions of the_ license, the amendment, NRC's regulations, the Atomic Energy Act of 1954 as amended, and will be subject to the NRC's inspection and enforcement program.
1.2 General Description of the Facility The VRDF would be located at the West Jefferson site in a new 60' x 125' building constructed specifically for the purpose. It would be located adjacent to the south edge of the existing parking lot which is immediately east of the fenced area of BCL's Nuclear Sciences Area. The building would be comprised of a low bay area for waste storage and a high bay area for waste processing, as shown in Figure 1.1. The facility would be constructed on a 6" thick, rein-forced concrete slab with insulated, corrugated steel walls and a built-up roof over steel decking.
All LLW would be shipped to the VROF by highway. The trucks containing waste materials would be received at the unloading and loading dock where unloading would take place. Containers of waste would be moved by forklift or drum cart to storage areas which also serve as staging areas for accumulation for effic- '
ient processing of batches by generator in the incinerator. A total of about 500 drums of waste could be stored.
Containers of waste for processing would be transferred by forklift or drum cart to the ground floor of the incinerator building, raised to the top floor by freight elevator, and off-loaded by drum cart or dolly. Waste would be man-ually charged into the incinerator feed chamber.
The incinerator, developed by Kraftanlagen AG (West Germany) and represented by ATCOR Engineered Services, Inc., in the United States, is described fully in a topical report. Figure 1.2 is a schematic drawing of the incinerator. It is capable of reducing combustible LLW (such as rags, paper, plastics, rubber and 2
1 wood),' scintillation liquids, biological material, and contaminated oil into an
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ash that would be packaged for disposal.
The Kraftanlagen controlled-air incinerator is a two-stage combustion -incinera-l~ tor. The primary combustion chamber would operate at a maximum temperature of l
about 1450rF to ignite the waste. The combustion air to the primary chamber would be restricted, resulting in pyrolysis. The gaseous combustion products would pass to the secondary chamber, which would be maintained very air-rich at a temperature of about 1650rF, for the purpose of completing the oxidation of the gaseous combustion products. The char that is formed in the primary chamber is also passed through to the secondary chamber where combustion is completed.
_The gaseous combustion products are moved by induced draft fans through a process gas cleanup syst_em.
Process gas exits the secondary combustion chamber at about 1650rF, leaving about 70 percent of its ash loading behind in the ash cooling chamber, and en-
- ters the hot gas filter. The hot gas filter removes about 97 percent of the particulate in the gas stream. The process gas is then mixed with ambient air that reduces the composite gas temperature to less than 500rF before it enters a series of mesh filters. The mesh filters, which are bag filters, remove more i than 70 percent of the particulate presented to them. Final filtration is achieved through High Efficiency Particulate Air (HEPA) filters that are 99.95 percent efficient. The cleanup efficiency of this series of filters is 99.9995 percent.
Ash from the incineration process would be accumulated at three locations: the incinerator ash cooling chamber, the hot gas filter ash cooling chamber, and the mesh filter ash discharge lock. Empty drums would be brought from the empty drum storage area to those locations, which would be on the ground floor of the incinerator building. The drums would be attached to a lock, the hopper dis-charge valves operated, and the drums filled to about 90 percent of capacity.
l The drums would then be sealed, surveyed, weighed, and removed to the caged drum ash storage area in the waste storage building.
Construction of the FsDF building and procurement of the incinerator has not been initiated at this time.
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r l1.3 Summary of principal Review Matters The staff's review and evaluation of the information submitted by the licensee considered the-following principal review matters:
Evaluation of the VROF design as compared with the general requirements of 10 CFR Parts 20 and 30 and general engineering principles'.
Evaluation of the Kraftanlagen incinerator design and operating experience for its applicability to process the types of LLW requested in the application.
Evaluation of the licensee's proposed conduct of operations and pr'ogram for radiation protection at the VROF. Since the VRDF would be at the West Jefferson site and operated by the same personnel, many programs and pro-cedures already instituted at BCL under provisions of License No. SNM-7 would be incorporated into the operation of the VROF and have been pre-viously accepted. The additional review that was performed in this eval-uation was limited to the adequacy of personnel, programs and procedures for the new activities sought to be authorized. Those programs, procedures and items previously reviewed by the staff include: the health physics pregram, the security program, the emergency plan, the decommissioning plan, the BCL organization, the technical and financial qualifications of BCL, the training and experience of their personnel, and the quality assurance program.
Evaluation of the licensee's assessment on the potential for accidents during operation of the VROF and their possible radiological consequences.
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1 2i SITE CHARACTERISTICS 2.1 Introduction' ,
Th'e staff review and evaluation of-site characteristics were provided in the-safety' evaluation of the BCL West-Jeffe'rson site prepared in lonnection with
, renewal of.. License No. SNM-7 on April- 29,01983. The safety evaluation is available for public inspection,at the NRC's Public Docur,ent Room at 1717 H
' Street, NW, Washington, D.C. The staff's evaluation of new information togeth,er with-some general descriptive information-is discussed in this section.
2.2 Site Location ,
The West Jefferson site is located at 39* '58'N, 83* 15'W approximately 13 stat-ute miles west of the.BCL King Avenue Facility (Figure 2.1). The West Jefferson Site consists of a.1,000 acre tract which accommodates the Engineering Area in-the southeastern portion, the Experimental Ecology Area in the east central portion and the Nuclear Sciences Area in the northern portion. The northern boundary of the site lies approximately one mile south of Interstate Highway 70 and extends from the Georgesville-Plain City Road eastward to the Big Darby Creek. The eastern boundary of the site roughly parallels the valley of the Big Darby Creek southward to the Conrail tracks which constitute the southern boundary. The Georgesville-Plain City Road defines the western boundary of the site. The proposed incinerator facilities are to be located in the Nuclear Sciences Area as previously shown in Figure 1.1.
2.3 Demography The area immediately adjacent to the West Jefferson site has a low population density. Table 2.1 shows the population distribution, by direction and distance, within 80 km (50 mi) of the site. Residences nearest the Nuclear Sciences Area are two houses that are located about 750 m (2500 ft) to the northwest and south-west, respectively. A Girl Scout camp, Camp Ken Jockety, is located on a bluff on the east side of Big Darby Creek at a distance of 450 m (1500 ft). On the 7
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Figure 2.1 GCL West Jefferson r :flity location 9
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Table 2.1 Population distribution around the BCL site in 1980 Distance (km) I j Sector 0-1.6 1.6-3.2 3.2-4.8 4.8-6.4 6.4-8 i
8-16 16-32 32-48 48-64 64-80
! N 8 6 30 80 3,241
! NNE 105 2,538 3,692 19,232 38,558 4 6 30 80 105 1,304 i NE 5,358 20,947 7,461 11,290 2 6 30 80 105 3,310
- ENE 4,405 7,734 6,631 16,466 2 6 30 80 205 18,499 E 109,046 11,809 8,419 11,956 2 6 30 80 105 18,040
! ESE 342,003 42,808 10,255 53,990 2 6 30 80 105 34,158 1 SE 170,123 23,960 39,354 15.115 O 495 30 80 105 7,240 45,405
] SSE 0 9,298 7,591 6,259-105 30 80 105 16,028 9,860
- S 0 3,496 6,115 8,886 6 30 80 105 610 4,574
] SSW 2 6 3,107 4,707 11,739 200 300 105 635 4,807 3,543
{ SW 4 6 2,000 4,667 7,343 j WSW
,1,800 105 1,846 5,798 2,390 6,345 16,152 2 6 150 300 105 j
- W 2 402 7,318 7,095 19,774 184,704 6 30 80 105 728 4
WNW 2 2,074 71,132 28,610 65,312 6 30 80 10$
l NW 4 561 2,547 14,966 5,636 9,794 6 30 80 105 NNW 423 1,754 3,344 17,568 9.754
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711 2,282 3.318 3,429 6,086
- Annular totals 40 684 2,740 3,440 1,680 107,739 719,892 232,639 205,794 C3,404 Grand total 4
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east side of Big Darby Creek, and 1.2 km (4000-ft) to the southeast,_is the Lake
'Darby Estates residential subdivision. A total of 3000 people reside in Darby Estates. A second subdivision, West Point, east of the Lake Darby Estates and Hubbard Road, is considered a part of Darby Estates, and the residents are included in the 3000 person total previously stated.
During the last 25 years, two major highways, I-70 and I-270, have been completed near the West Jefferson site. The area areund the junction of these highways, which is about.16:km (10 mi) east of the Nuclear Sciences Area, has proven to ,
be popular for industrial growth. It is estimated that the industrial population has shown an increase equivalent to that of the general population in this area, i.e., two and one-half times the population within 16 km (10 mi) in 1965. Most of the growth has taken place near the outer , limits of Columbus; however, larger employers, e.g., General Motors and White-Westinghouse, have actually reduced their numbers of employees.
2.4 Climate There have been-no significant deviations in weather patterns since climate conditions were described in the previous environmental assessment prepared in February 1981. (See the NRC staff's Environmental Assessment of the VROF for additional information.)
2.5 Hyorology There are two aquifers, or sources of water, in the site area. The shallow aquifer is dense clay till. The deep, or principal, aquifer is the limestone bedrock underlying the till.
The present wells at the Battelle facility lie below the surface of the bedrock.
The nortn well is 130 feet deep, the centrally located well in the Life Sciences Area is 162 feet deep, and the south well is 118 feet deep. Bedrock was encoun-tered at approximately 103 feet below the surface in drilling these wells. A man-made hydrologic feature of the site is the artificial lake covering an area of about 25 acres that was formed by damming Silver Ditch south of, and down 10
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' gradient from, the Nuclear Sciences Area. The normal surface elevation of the lake is'888 feet MSL.
The source of ground water in the site area is local precipitation. Recharge to the shallow aquifer takes place relatively uniformly over the area. Contours of the water table, which are aoout 40 feet below the surface, are a subdued replica of the surface topography. Ground water moves downslope at right angles to the contours and follows a path similar to surface runoff. At the Nuclear Sciences. Area surface runoff moves downslope.into the lake, thence through the, controlled dam on the. site into Big Darby Creek. All ground water'in the site area, and that entering on the site, is already near its place of discharge.
Flood hydrology calculation for the lake indicated a capacity'of releasing water that was about three times the inflow rate measured during the January 1959 floods. It can be concluded that the lake has not adversely affected the hydro-logy of the area. The ground floor level of the VROF is about 910 ft. on the USGS mean sea level datum. The BCL West Jefferson site has been reviewed with respect to flooding. The safety of the VROF from flooding by Big Darby Creek was demonstrated by comparison with the probable-maximum flood (PMF), computed by the Corps of Engineers as 294,000 cfs for the downstream Big Darby Creek Dam with a drainage area of 441 m1 2
. The capacity of the creek adjacent to the laboratory, determined from conservative parameters, is about 329,000 cfs at an elevation of 900 ft MSL. Thus, the channel capacity adjacent to the VRDF at an elevation 10 ft below grade is greater than the PMF for a drainage area of 441 m18, 2.6 Geology and Seismology The local and regional geological and seismological features of the central Ohio West Jefferson site have been previously described and evaluated by the staff in the 1981 environmental assessment and the 1979 report on the te Effects of Natural Phenomena, NUREG-0893.
Briefly, the entire area is featured by glacial till, with the ungiaciated basement formations of limestone, dolomite and shale beginning at about 80 to 100 feet deep. These formations are several hundred feet thick.
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.There have-been no recorded earthquakes within 50 miles of the area of interest, "although in-1937 a strong quake was experienced at Anna, Ohio, a little over 50 miles:to the northwest of the West Jefferson site. The Columbus-West Jeffer-son areas are, however, considered to be in an aseismic region.
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,_ , , The;VROF has:been designed to be a free-standing, separate facility;to be located L outs.ide the security fence of BCL's Nuclear Sciences Area. ,The building design L
includes areas for_ incoming' waste receiving, storage, transfer to processing,.
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- incineration,' ash ' storage, shipping and ancillary operations. Tall ' services and . _
utilities would be-provided from sources in' the Nuclear Sciences Area.
Descriptions of the. facility design are contained in'BCL'sc " Report on Safety Related Information' for the Battelle Volume Reduction Demonstration Facility, and'the Kraftanlagen topical report on incineration of radioactive wastes apply--
ing the Juelich Incineration Process. Additional discussion of the VROF design is found in the staff's Environmental Assessment of the VROF,1especially -
Section 3.0.
3.2 Design Criteria BCL has stated in _their application that they have chosen design criteria for VROF design, construction and operation necessary to assure that-the health and safety of the public and plant operators will not be subjected to undue risk curing and after operation of the facility. These criteria cover: waste accep-tance; structures, systems and components and include temperature, ground motion, high winds, flooding and snow loading; safety protection systems and includes confinement barriers, ventilation and controls and instrumentation; radiation protection; fire protection; and decommissioning.
In addition, BCL has described design bases and features in the application and in the existing license which are described in subsequent sections of this report.
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.3.3 Ventilation-i- ,
'3.3.1 Butiding Ventilation
D In accordance with BCL's design bases for butiding ventilation, all areas of the VRDF in which waste contaminated with radioactive materials is handled would, be_provided with ventilation which is exhausted through high efficiency particu-
. late air (HEPA) filters to the atmosphere. The waste storage butiding would not be provided with HEPA filtration, however. No recirculation would be pro ,
vided for either building. ~tiuch of the building ventilation air would be pro--
vided by the incinerator process ventilation system; the remainder would be
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provided by separate blowers. The' process and control area ventilation would
'be discharged via a 132 foot-high stack which would be situated alongside the process building.
3.3.2 Process Ventilation -
The incinerator process, or off gas, ventilation system is'an integral part of the incinerator operation it'self and is described in Section 3.8.
3.4 Fire Protection In accordance with BCL's design bases for fire protection, the VROF buildings would be provided with detection and suppression equipment which includes:
Fire Detection System - Heat or smoke detectors (as appropriate for the area) which alarm locally and in the incinerator control room.
Fixed Fire Suppression System - Temperature actuated, automatic water sprink-1er heads in the incinerator room, charging room and ash packaging room in accordance with NFPA 82, Section 2-3.6.3, and in the waste storage building.
- . Portable Fire Extinguishers - NFPA specified, personnel-operated, portable fire extinguishers located throughout the VROF.
Water Hydrants and Stations - Yard hydrants with equipment stored in enclo-sures and hose stations within the VROF building.
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3.5; Physical Security
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The Nuclear Sciences Area of BCL's. West Jefferson site.is under NRC Category III safeguards control of special nuclear material as specif.ied in 10 CFR Part 73.
BCL's Security Plan to comply with the regulation includes provisions for a physical security program. This-program includes features for restricting entry to the area, surveillance of the fenced area, and others which involve the presence of; security guards. However, BCL has proposed locating the VRDF about 80 feet outside the. fenced area and about 120 feet from the security guard house. The.re fore , .
while the VRDF would not be specifically included in the Security Plan by virtue of the facility being within the fenced security area, the VRDF would be under
' general observation from the continuously occupied guard house. In addition, a fence will be erected around the VRDF for radiation protection purposes, although nene is required by NRC regulations for physical security purposes since no special nuclear material would be authorized in the VRDF.
3.6 Material Handling In Section 3.3 of the VRDF Safety Related Information Report, BCL has-described the design and arrangement of the material handling features of the facility.
.The basic concept is to use portable equipment such as forklift trucks, drum carts and motorized lift dollies to move containers of waste and product'through-out the storage and processing areas. In addition, a freight elevator would be used to raise incoming waste to the top floor where the incinerator is fed.
The portable equipment provides great flexibility for accommodating variations in the demonstration program, although some sacrifice in efficiency and radia-tion exposure to workers may result. Battelle has stated that other drum transfer equipment may be acquired later if necessary to improve operator efficiency and reduce exposure.
-3.7 Incinerator System In Section 3 of the VRDF Safety Related Information report, BCL has described
, the design and arrangement of the proposed incinerator system. In addition, Kraftanlagen has prepared a topical report on incineration of radioactive wastes applying the Juelich Incineration Process and a brief description of the systen 15
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ts included 15 Section 3.2.3 of the staff's Environmental Assessment of the VROF.' The design of the unit destined for Battelle's site is identical with the German design, although it has not yet been determined whether fabrication will be done in Germany or the United States.
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3.' 7 .1 General Arrangement
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The incinerator system would be housed in its own 3-story building located' outside the security-fenced Nuclear Sciences Area at BCL's West Jefferson site.
A contiguous one-story building would house the associated receiving, storage and shipping activities. The system is comprised of waste feeding equipment, the incinerator itself, ash discharge equipment, off gas cleaning equipment, and air flow components. Electricity, natural gas for combustion, and water would be provided from facilities in the Nuclear Services Area. . Figure 3.1 shows how the incinerator system would be arranged within the building.
3.7.2 Incinerator Feed The waste loading chamber atop the incinerator is divided into a drummed waste compartment and a bulk weste compartment by a pneumatic slide gate. Drums of waste are upended into a loading port and waste removed into the chamber. Bulk waste is loaded through the bulk waste compartment and then into the chamber.
Air locks are provided to maintain integrity and glove ports are provided for manual operations if necessary. A waste feed lock lies between the chamber and the incinerator itself. Only one slide gate of the feed lock can be opened at
! a time so that feed preparation can be conducted separately from the incinerator atmosphere. Feed is introduced to the incinerator when indicated by level sen-sors. Bulk liquids such as contaminated oil are introduced by direct injection into the upper part of the pyrolysis chamber at a controlled rate.
3.7.3 Incinerator l
The incinerator is a steel jacketed, airtight square column. It is flanged at the top to the waste feed lock and at the bottom to the ash discharge hopper.
The incinerator, which has a multi-layer refractory lining and insulation, is l
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divided vertically into a pyrolysis chamber and a combustion chamber by the pyrolysis grates. The innermost refractory layer is designed for wear resis-tance to minimize residual contamination and to aid in decontamination. Pyrolysis air is admitted through channels in the side wall of the incinerator and combus-tion air is admitted through holes in the pyrolysis grates for cooling the grates and for maintaining the lower combustion chamber temperature at about 1650*F.
Depending on the type of waste material, it can take 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to pass through.
the pyrolysis chamber; 1-1/2 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is typical for most wastes as temperature increases from about 200 F to 1500 F. In any case both chambers are maintained-at subatmospheric pressure by induced draft ventilation. Actuating shafts for grates and valves penetrate the walls of the incinerator systen and are not provided with leak-tight seals. The operators'and actuators are enclosed on the exterior of. the system to provide confinement. An airtight, steel flue gas discharge duct, which is also refractory-lined and insulated and connects the combustion chamber to the hot gas filter, serves as an afterburning chamber and provides an additional 1.5 seconds of holdup under , combustion conditions.
Natural gas-fired burners are provided in the both incinerator chambers to pre-heat, initiate incineration and maintain temperature. Combustion air is provided by blowers located in the incinerator building.
3.7.4 Off-Gas Treatment The Kraftanlagen design for off gas treatment differs from most designs in that it is essentially dry. The system consists of a hot gas filter, a mixing (cool-ing) chamber, a mesh or bag filter and final HEPA filters with prefilters. The system is designed not only to efficiently remove ash and particulatos from the flue gas but to cool the off gas from about 1650 F down to 480 F at the final HEPA filters.
The hot gas filter is an airtight steel jacketed box with a multi-layer refrac-tory lining. It has a hinged, steel, insulated cover that provides access to the filters for maintenance. The filter medium is a disposable ceramic fiber fleece. Spent filter elements are discharged into the ash hopper. The top of the hot gas filter is enclosed in a service room that has controlled, filtered ventilation to prevent contamination release during the hot gas filter change 18
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'y' operation. An ~ ash ~ discharge hopper is- flanged to the bottom of th'e hot gas y
' filter: inlet-plenum.
The filtered flue ~ gas exits the hot-gas filter through a refractory lined duct.
/ The flow is: split to divert up to 20 percent of the hot gas back to-the pyroly-
. sis unit by.way of a' quench cooler in which the gas is. contacted with a water (spray for cooling. The remainder of the air is sent to the-final cleanup _ system ~ ,.
'and. stack discharge.
A duct is.available to' allow the flue gas to bypass the hot gas filter in emer-
-gencies such as rapid plugging of the filter elements. This duct is 2 feet in
-diameter and is refractory insulated. The bypass is normally sealed by a spe-
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cially designed cone valve. In an emergency the incinerator is shut down and' the bypass duct valve is opened manually. This allows flue gas to enter the downstream components of the incinerator system where other filters are present to remove particulates.
The off gas. is cooled further in a mixing chamber which is a cylindrical steel housing fitted inside with baffles and swirl vanes ~ welded to the interior of the housing. It is flanged to the refractory lined steel ducting from the hot gas filter and the insulated steel ducting leading to the mesh filter. A cooling
. air injection connection is located in the mixing chamber refractory lined inlet plenum. Cooling air is supplied by the draft action of the induced draft fans.
Off gas.from the mixing chamber is directed to the mesh filters which are airtight steel housings with arrays of mesh bags located inside. The mesh filter hous-ings are flanged to the split flue gas ducting from the mixing chamber and to
.the ducting leading to the final filters. The flue gas enters at the bottom j of the filter units, flows through the bags (outside to inside), and exits from the upper plenum. The mesh filter media will be either teflon or glass fiber l and have an efficiency of about 70 percent. When filter efficiency can no longer be maintained by impulse cleaning of the bags, the bags are changed during inciner-ator downtime. The top of the unit has an access cover similar to that of the i
hot gas filter. Used filter bags are dropped into the bottom of the units and removed through an ash discharge lock that is similar to that employed in the
{ incinerator and the hot gas filter. The ash discharge lock also retains the I 19 l
E ash that is dislodged from the~ mesh filter by impulse cleaning during normal
-operation.
- Off gas: from the mesh ' filters is. directed to the final filter units which are housed in' airtight steel boxes. They are two-stage units each with a bank of prefilter elements proceeding HEPA filter elements. The filter media is of German' manufacture and the composition _is considered proprietary. The filters are used in German incinerators at temperatures comparable to those expected at BCL. However, _if they prove unsatisfactory in trial runs, they could be replaced with glass fiber filters of United States manufacture. In any event,
- Battelle has stated that they will certify operational performance prior to startup of the incinerator using LLW. The final filters have a design efficiency of about 99.97- percent, and the NRC will require that they be tested to be 99.95 percent efficient. Filter elements are replaced by the bag-out method and can
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be loaded directly into the incinerator for recycling without pretreatment such as crushing or shredding.
Redundant induction fans maintain negative pressure a'nd air flow through the incinerator system. The fans. discharge into a 132-foot stack situated alongside the incinerator building.
.3.7.5 Ash Discharge and Handling Ash hoppers are located at the incinerator, the hot gas filter, and the mesh filter.
The incincrator ash discharge hopper is flanged to the bottom of the combustion chamber. It consists of two airtight steel boxes flanged together--the ash cooling chamber (top) and the ash discharge lock (bottom) with associated aux-iliary support equipment. A set of ash grates is located at the top of the ash cooling chamber. Solid combustion products and noncombustibles accumulate on the ash grates, and are dumped automatically. The ash is cooled by water flow-ing between the wails of the double jacketed ash chamber. It is emptied period-
.ically into the ash discharge lock which has pneumatic slide gate valves at top and cottom and is equipped with a container (drum) coupling device to transfer the accumulated ash to drums. The atmosphere in the region below the valve is 20
o purged through local vents to the exhaust system to remove radioactive, airborne particulates, and a negative pressure is reestablished before the drum seal is released. After the filled drum has been removed and covered, another drum is immediately coupled to the discharge leg.
In the case of the hot gas filter, the ash hopper is separated from the hot gas filter by air cooled, ceramic insulated ash grates. The ash falls on the grates by separation from the flowing gas as the gas velocity and direction are changed and by spontaneous spalling of ash cake from the filter surfaces. The ash dis-charge lock has pneumatic slide gates at its top and bottom. A container cou-pling device is flanged to the bottom slide gate. The discharge lock promotes cooling of the ash. When the necessary volume of ash has accumulated in the lock, it is discharged to a drum. The drum coupler and air exhaust system for contamination control are the same as for the incinerator ash discharge described above. A drum of ash is filled about once a day. The ash discharge lock is provided with glove ports, service windows, lighting installations, and ventil-ation. During operations, the windows and glove ports are protected by an insulated steel slide shield.
An ash discharge lock is flanged to the bottom of each mesh filter. The ash discharge lock is equipped at the top with an insulated steel pneumatic slide gate for isolation from the mesh filter. At the bottom of the lock is another pneumatic steel slide gate which is flanged to a container coupling device for contamination-free discharge of ash to a waste container; the container coupling device and exhaust air controls are similar to the incinerator and hot gas filter ash discharge systems.
- Due to the concentrating of radioactivitI/ in ash by incineration, radiation dose rates from drums of ash are expected to be significantly higher than from drums on incoming LLW. The facility design includes a separate, caged area in the storage buildit:g for ash ktorage with provisions for adding shielding, if necessary, so thatflevels of.tradiation can be maintained as low as reasonably achievabi'e.
r 21 I
'3.7.6 : Operational Controls The. incinerator' system is designed with instrumentation and controls for remote
= operation and monitoring and for automatic shutdown in the event of a malfunc--
tion or off-standard condition that could damage equipment or present a potential hazard _to workers or.the public. Process parameters such as pressures, temper-aturesi liquid levels and flows, fan operation, and radiation are continously
-monitored and controlled. Selected parameters are continuously recorded. Proper operation of the incinerator is accomplished by control sequencing and inter .
locks as well as some operator actions. 'Aut'omatic shutdown of the incinerator system occurs from loss _ of power, loss of HEPA filters, loss of induced draft fans, loss of combustion air fans, loss of water level in the compensating.ves-sel, high-flue gas temperature downstream of the mixing chamber, high pressure drop across the hot gas fil_ter, and high radiation levels'in the exhaust stack
- inlet. The sequencing and timing of shutcown events is controlled automatically in ways that are dependent on the initiating shutdown function *.' Manual activa--
tion of the automatic sh'utdown function is available to operators in the event-of suspected or_ devel.oping problems.
.Because several control and shutdown functions are dependent on operator actions, the staff will, require that the incinerator control room be continuously manned during' periods when the incinerator is operating.
A standby diesel generator is provided for building ventilation fans and bat-teries are used to provide power for critical instrumentation and controls to permit automatic shutdown in the event of loss of power.
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4 ' FACILITY OPERATIONS 4.1 Organization and Staff Qualifications The opera' tion-of the VRDF would be an integral part of Battelle Columbus
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Laboratories' operations. As such, all personnel required for VRDF activities would be furnished by BCL with no significant reorganization of the top management and operating staff. New positions, including a Manager of the Incinerator Demonstration Prograr.i and Manager of the Incineration Facility and Research Operations,:would be added in the Nuclear Systems Section of the Nuclear Technology and Physical Sciences Department. Another important position, that of Operations ,
Manager, would report to the Incineration Facility Manager. Battelle will re-quire the Operations Manager to be degreed in scierice or engineering or 10 years experience, and a minimum of 5 years industrial or research experience, 2-years experience in handling radioactive materials and 2 years supervisory experience.
A Manager of Research Operations Analysis, a Transportation Logistics Supervisor and at least six Facility Operators woula also be added to the staff.
There are no special personnel qualifications for managing operation of the VRDF other than those already in place for operations at BCL. The NRC staff has previously reviewed BCL's organizational structure and staff qualifications and found them satisfactory to provide a staff and support capable.of operating the Laboratories. Based on the above information and the licensee's experience, the staff concludes that Batte11e's organization is adequate to conduct VRDF operations in accordance with regulatory requirements _and license conditions.
4.2 Training and Exoerience Pursuant to 10 CFR Part 30.33(a)(3), the licensee must be qualified by reason of j training and experience to safely handle the byproduct material requested in the application for license amendment to operate the VRSF. The licensee has been found technically qualified under the requirements of 10 CFR Part 70.23(a)(2) engage in activities currently and previously authorized which are related to uranium and plutonium fuel fabrication. The licensee also has been found
, technically qualified under the requirements of 10 CFR Part 30.33(a)(3) to l
23 i
i-i_ .
engage in activities currently authorized for hot cell work, radiography and biological research. However, the individuals selected to conduct the new VRDF operations will require special training, as stipulated in Part 1, Section 3.10 of-the license renewal application BCL-1031 and in Section 7.3 of Appendix G.
The former makes specific reference to LLW incinerator training documents, while the latter states that incinerator operators will be trained by experienced personnel who have operated similar equipment. BCL has advised the staff that they plan to have a Kraftanlagen/ATCOR technical representative onsite both during installation and testing of the incinerator prior to use with waste con-taining radioactive material and for an additional period from the time routine
-operations commence; thus, the technical representive will provide further training, advice and consultation on incinerator operations. The staff will require that this commitment for technical assistance be carried out.
Based on the licensee's already demonstrated proficiency to safely handle by-product material, the procedures and training requirements that are in place, and the assistance provided by the incinerator manufacturer, the staff concludes that the licensee's training and experience are adequate to operate the VROF in accordance with regulatory requirements and license conditions.
4.3 Compliance Experience The NRC conducts a program of periodic, usually unannounced, inspections of licensees' activities for compliance with NRC regulations and license conditions.
- In the case of fuel cycle licensees, such as BCL, inspections are made for both health and safety compliance as well as special nuclear material safeguards compliance. Since the time of the last overall safety evaluation and environ-mental assessment in 1981, 14 inspections were made that included the West Jefferson site with all but one of them for health and safety compliance pu--
poses. During that period, eight violations were noted. These were for minor procedural inadequacies including submittal of reports, and for dose rates and exposures greater than NRC limits. They were corrected promptly, and none resulted in the imposition of civil penalties. This record of compliance with NRC regulations and license conditions provides no reason for imposing unusual conditions of operation or denial of the application for license amencment.
24
BCL has been cooperative'with the NRC staff in complying with regulatory requirements ard requests for information.
4.4 Normal Ooerating Procedures In accordance with Part I, Section 2.1 and Appendix A of the license, BCL will be required to obtain review and approval'by their Radiological Safety Committee
.and, through a Radioactive Materials Application, review and approval by their Radiological Safety Officer of VRDF activities, including operating procedures.
In Part I, Section 3.10, Training, BCL has referenced training documents for procedures for radiological safety, maintenance, and operation and. shutdown of the LLW incinerator facility. In addition, a system of special work permits will be used to perform non-standard operations,' especially maintenance. This system would be used where special, augmented radiation or contamination controls might be necessary for personnel protection.
4.5 Material Control The VRDF Storage Building is arranged to allow the accumulation of quantities of incoming LLW sufficient for efficient processing of a generator's batch in the incinerator. Each generator's waste would have to be controlled separately and, after volume reduction, either returned to the generator or shipped to a licensed disposal site as that generator's waste. Battelle has proposed to use a computerized inventory procedure to maintain material control over incoming LLW and ash. The principal purpose of the inventory management system would be to ensure that the longest held waste is processed first and the longest held ash is shipped first. The system would record package receipt date, stor-age location, generator name, package activity, and surface radiation level of incoming LLW and loading date, generator name, package activity, and surface radiation level of ash. The facility has capability to store incoming LLW up to about 6 months and ash up to about 2 months. The inventory management system does not have the ability to automatically characterize packaged waste, classify packages in accordance with 10 CFR Part 61 waste classification requirements, and prepare shipping manifests and other documents, so these activities would have to be conducted manually. This should not, however, present a problem due to the relatively small volume of shipments.
25
-The generators would describe the contents of waste packages on their manifests and Battelle would accept the descriptions at face value. Verification of gen-erators' data on.the types and quantities of radioactive materials in their waste will be made during the incineration processing cycle in accordance with Battelle's quality assurance operational procedures, relying primarily on analy-sis of ash. Although it is the generator's responsibility to prepare accurate manifests, BCL will have to obtain experience to determine that the manifests accurately and completely reflect incoming waste composition to assist with keeping releases of radionuclides within BCL's limits and in preparation of accurate manifests for outgoing shipments. The NRC will require that BCL sub-mit a semiannual report of their experience with correlating and managing their receipt, processing and release data.
4.6 Emergency Plans Condition 22 of the current license requires BCL to maintain an emerger.cy plan and emergency procedures for coping with emergencies. The plan deals with the emergency response organization, assessment actions, activation of emergency response, notification procedures, emergency equipment and facilities, training, maintaining preparedness and recovery from emergency. -The staff has reviewed-and accepted BCL's plan, and it is appropriate for the proposed activities.
4.7 Records Pursuant to 10 CFR Part 30.51, the licenses must keep records showing the receipt and transfer of byproduct material. These records would be maintained through
, the inventory management system described in Section 4.5 above. Based on this information, the staff concludes that the licensee's recordkeeping system will
- be adequate to meet regulatory requirements for this aspect of facility opera-
[ tions. The staff has previously determined that the licensee's recordkeeping is adequate in other required aspects.
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6- . -
'5 RADIATION PROTECTION Battelle has previously described their West Jefferson site radiation protection program in the Specification and Demonstration Sections of the-license, supple-mented by their Operating Guide and augmented by license conditions imposed by the NRC staff. Additional radiation protection levels, controls and other features specific to VRDF operations have been described in the application for license amendment, including a report on safety related information. The staff has reviewed and evaluated the information on radiation protection and it is discussed in this section.
5.1 Design Basis The radiation protection design of the VRDF for occupational radiation protec-tion purposes is based on the radioactivity levels in LLW generated by nuclear power utilities and industrial / institutional users of radioactive materials, with additional limitation on acceptance of waste for incineration (5 mrem /hr average container surface dose rate). The staff independently reviewed the estimated composition of LLW that might be received at the VRDF to verify
~
BCL's estimates. As a result of these levels of radiation, all operations prior to and including i.LW treatment incorporate no shielding in their design, while operations post treatment incorporate isolation from occupied areas and minimizing the handling of end product containers. Processing operations, in which LLW is not packaged in containers, are designed with enclosures and/or i
local exhaust ventilation to prevent the release of radioactive materials into working areas or the environment. The staff concludes that these radiological design bases for occupational radiation protection purposes are adequate, subject to concerns discussed in Section 5.3.
, The radiation protection design of the VRDF for public radiation protection purposes is also based upon the radioactivity levels in generated waste.
Since potential radiation exposure to the public is from airborne effluents from the VRDF, operations include in their design air cleaning wnich has HEPA filters installed to reduce concentrations of radioactive materials in air to levels as low as reasonably achievable below NRC limits in 10 CFR Part 20. To 27 1
[ limit public radiation exposure from gaseous radionuclides in effluents that are not efficient 1y' removed by the air cleaning systems (tritium, carbon-14 and iodine-125), BCL has proposed administrative-limits on the amount of iodine-125 accepted for volume reduction. The staff concludes that these radiological design bases for public radiation exposure purposes are adequate, subject to concerns.and further requirements discussed in Section 5.4 and the NRC's Environmenta1' Assessment of the VROF.
5.2 Radiological Safety program .
The radiological safety program for the VRDF is part of and the same as that in effect for all BCL activities. Administration of the program is' performed in the Nuclear Services Section and overviewed by the Radiological Safety .
Officer who reports to the Laboratories Director. The Health Physics Supervisor, who reports to the Manager of the Nuclear Services Section, directs the radiblogical safety functions including: development and implementation of techniques and procedures for radiological monitoring and surveillance, investigation and evaluation of routine and unusual events, consultation to other supervisors, approval of radia* ion work permits (RWP's),
training, and approval of experiment changes, equipment installation and operating procedures. The Health Physics Supervisor and the Radiological Safety 0fficer have the authority to suspend or terminate any activity if its continuation would threaten the health and safety of employees or the public.
All operations at the VRDF will be performed in accordance with written
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procedures approved by the Radiological Safety Committee and with standing radiological control procedures or RWP's which specify all necessary protection and monitoring requirements.
The occupational radiation monitoring program for laboratory operations including the VROF, is specified in Part I, Section 3.0 of the license, with additional informatien provided in Battelle's Operating Guide. In general, the program consists of regular health physics surveys for direct radiation, surface contamination and air contamination, and the use of personal dosimeters of the thermoluminescent and self-reading types. Health physics surveys would be 28
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performed by operators and technicians using portable survey instruments, and by smear and air filter samples analyzed in Battelle's counting laboratory.
The self-reading dosimeters worn by workers would allow them to keep track of their accumulated exposures, while the thermoluminescent dosimeters would be the official means of dose accounting required by 10 CFR Par't 20.
The effluent radiological monitoring program for plant operations, including the VRDF, is also specified in Part I, Sections 3.6 and 3.7 of the license, with additional information provided in Battelle's Operating Guide. In general f the program consists of continuous sampling and periodic analyses of the discharges from building and process exhaust ventilation systems. As discussed in the staff's Environmental Assessment, SCL proposed weekly analyses of the discharge samples in the VRDF, but NRC will require daily analyses when LLW containing tritum, carbon-14 or iodine-125 is being processed because of the inability of the air cleaning systems to capture these gaseous radionuclides and the imprecision of estimates in the unprocessed waste. The NRC will also require the installation and use of a real-time monitor to detect any inadvertent high-level particulate release of radionuclides from the incinerator. Monitoring of air and water in the environment will contir:ue according to the existing schedule, with the addition of sampling for tritium, carbon-14 and iodine-125 in air at each of the four perimeter air sampling stations. In addition, BCL intends to evaluate the radiation dose from iodine-125 based on desposition associated with vegetation.
Based on this information, the administrative control procedures established as part of the license and the additional NRC requirements, the staff concludes that BCL has an adequate health and safety program.
5.3 Occupational Radiation Exposure In operation of the VRSF, BCL will have to comply with the provisions of 10 CFR Part 20, Standards for Protection Against Radiation, which provide limits for radiation exposure to workers and an exhortation to maintain exposures as far below the limits as low as is reasonably achievable (ALARA). BCL also has committed to ALARA, including a system for investigation of radiation exposure levels that are fractions of the annual limits.
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'In their application,'Battelle showed by an analysis, which is supported by iexperience gained in operating a similar facility in West Germany, that the
- totalannualexposureduringnormal.operationoftheVRDFwouldbeabout
-3 person-rems. Batte11_e further explained that, because the West German experience isJfor.a research institute incinerator, dose rates at the VROF would be higher. Therefore, BCL used in their analysis maximum design dose
' rates as specified in Table 3.1 of their report on' safety-related information.' '
BCL also used a maximum 7200 hours0.0833 days <br />2 hours <br />0.0119 weeks <br />0.00274 months <br /> per year of operation in their analysis --
-an extraordinary 82 percent plant availability factor considering-the demonstration nature of the VROF and the need to shut down frequently between campaigns of processing generators' LLW.
Batte11e estimated that six workers would be required to operate the VRDF on this 7200 hour0.0833 days <br />2 hours <br />0.0119 weeks <br />0.00274 months <br /> per year schedule. The~ workers would also perform some of the maintenance, although BCL's Facility Engineering would be called upon for repairs that require the trades. -
-The staff questions BCL's estimate of total dose, its distribution among only
'six workers, the high utilization and low maintenance of the incinerator. If a more realistic utilization of 50 perce,nt.is assumed,-perhaps six workers along with .six supervisory employees and maintenance workers could operate the VRDF.
o If 82 percent utilization is retained as BCL's. assumption, additional operators .
i would be required, and the total dose would be higher than 3 person-rems. In either instance, maintenance and' supervision would give rise to higher exposure, with a total probably closer to 6 person-rems. This total is likely to be
- distributed unevenly among the dozen or so employees who would still be involved .
so that'the average annual dose would still be similar to BCL's estimate of
, 0.5 rem per year. The facility design places a limit of one rem per year to any one of the operating personnel.
I No estimate of exposures to airborne radionuclides was made by Battelle, but the .
VROF ventilation system would appear to provide adequate control to preclude i significant exposure during normal operations. RWP's which require additional controls would be used during off-normal operations and maintenance. These '
controls would provide further protection against intakes of airborne radionuclides. In addition workers would participate in the Laboratories' 1
30 i
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.bioassy program so that potential exposures can be monitored and evaluated.
Battelle has committed to provide additional. shielding, isolation and other controls if required to meet the facility design and personnel exposure limits specified in the application. Based on BCL's analysis of occupational radiation exposures and commitments for improvements if necessary and the staff's evaluation,.the staff concludes that the licensee will be able to ensure that all exposures are maintained within the limits at 10 CFR Part 20 and at levels that are ALARA.
5.4 Environmental Radiation Exposure Under the terms and conditions of NRC License, the licensee must limit radio-activity in effluents to unrestricted areas in accordance with 10 CFR Part 20.106.
The licensee must also comply with EPA's Clean Air Act standard, 40 CFR Part 61, which limits radiation exposure to individuals.
A detailed assessment of the expected concentrations of radioactivity in air at the West Jefferson site boundary and radiation doses to individuals, using conservative assumptions and calculations, is contained in the staff's Environmental Assessment of the VRDF. This assessment shows that the concentrations and doses will be well within the requirements of 10 CFR Part 20 and 40 CFR Part 61, and that the annual whole body dose to the nearest resident from normal operation of the VRDF would be about one mrem. Background radiation in the West Jefferson area is about 135 mrem per year. Summaries of the site boundary concentrations of radioactivity in air and doses to the public, resulting from incinerator operations, are shown in Tables 5.1 and 5.2. In the assessment of concentrations and doses resulting from incinerator operation, it was assumed that all tritium, carbon-14 and iodine-125 is released with no collection whatscever [ decontamination factor (DF) = 1],
cesium is released after a collection of 99.985 percent (DF=6,700), and other particulates after a collection of 99.9995 percent (DF=670,000).
An important feature of the environmental assessment is that releases of iodine-125, which would be the single most significant contributor to offsite radiation dose, would be limited by administrative control. Since this radionuclide would go through the incinerator with little or no diminution, 31
6 '
t
--Table 5.1 Maximum Concentrations of Radionuclides at Ground Level from Normal VRDF Operations Max. Ground Limiting Ground Level Nuclide Release Rate X/Q Level Conc.
pCi/sec. Concentration Conc. as Percent sec/ml. pCi/ml. pCi/ml. Limiting Conc.- -
Cr-51 1.6E-07 1.5E-11 2.4E-18 8. 0E-08 Mn-54 3.0E-09 3.5E-08 1.5E-11 5.3E-19 1.0E-09 5.3E-08 Co-58 3.5E-06 1.5E-11 5.3E-17
! 2.0E-09 2.7E-06 Co-60 6.0E-06 1.5E-11 9. 0 E Sr-90 3.0E-10 3.0E-05 2.3E-07 1.5E-11 3.5E-18 3.0E-11 Ir-95 5.7E-07 1.2E-05 1.5E-11 8.6E-18 1.0E-09 8.6E-07 Ru-106 4.4E-07 1.5E-11 6.6E-18 2.0E-10 3.3E-06 Sb-125 1.lE-08 1.5E-11 1.7E-19 9.0E-10 1.9E-08 Cs-134 7.6E-05 1.5E-11 1.1E-15 4.0E-10 2.8E-04 Cs-137 2.8E-04 1.5E-11 4.2E H-3 5.0E-10 8.4E-04 1.1E01 1.5E-11 1.7E-10 2.0E-07 C-14 6.3E-01 8.5E-02 1.5E-11 9.5E-12 1.0E-07 9.5E-03 I-125 6.7E-01 1.5E-11 1.0E-11 8. 0E-11 Am-241 1.3E-01 8.2E-10 1.5E-11 1.2E-20 2.0E-13 Tc-99 6.0E-06 5.7E-13 1.5E-11 8.6E-24 2.0E-09 4.3E-13 i
l 4
l l
0 32 l
l
\ . _ . - - -
f o- a Table 5.2. Annual Dose to Maximum Individual Off-Site
- from Normal Operations Pathway Dose Commitment (mres/ year)
Total Body ~ Thyroid Ground 0.14 0.14 Ingestion
,__ ._3egetation 0.34 2. 5 Heat 0.19 0.7 Milk 0.28 3.3 Inhalation 0.11 0.1 Total 1.1 6. 7 ,
Limits 10 CFR 20 500 N.A.
40 CFR 61 25 75 Location of nearest residence (not site boundary) - 2500 feet NW X/Q - 3.9E-06 Pathway sources - located at nearest residence i Growing season factor - 0.5.
i, 33
TT o . .
I this: essentially means that BCL'must limit .the quantity'of this' radionuclide
~
in the. incoming waste to be incinerated and to correlate incoming waste manifest data, ' system performance and releases and report the correlation in the semiannual reports. The NRC will require the administrative limit on
. releases of iodine-125 to be made a condition of the license.
Battelle has chosen to locate the VRDF outside the security fence of the
~
Nuclear Sciences Area to provide adequate room for the facility and for ease of access by trucks. Since BCL does not control public access on their site outside the security fence, the site must be considered an unrestricted area for radiation prctection purposes. BCL_ believes that the areas outside the VRDF will meet the criteria in 10 CFR Part 20.105(b) for radiation levels in unrestricted areas because of the low dose rates involved. The staff disagrees that this would be true in the vicinity of the shipping and receiving area and perhaps other areas as well. Consequently, the staff will require that a fence or other method of access control be provided to ensure that r.diation levels in unrestricted areas gould result in doses'to a hypothetical individual not in excess of two mrem per hour or 100 mrem per week.
Based on this information, the licensee's application, adherence to the administrative control procedures established as part of the license and-administrative limits on releases, the staff concludes that BCL will be able to ensure that concentrations of radioactivity in air and doses to individuals in unrestricted areas are maintained within the limits of 10 CFR Part 20 and
-40 CFR Part 61.
}
34 L
.6 ACCIDENT ANALYSES A detailed assessment of the radiation doses to nearest residents resulting from accidents occurring in the VRDF, using realistic assumptions and calculations, is contained in the staff's Environmental Assessment of the VRDF. The staff reviewed those accidents BCL evaluated in their application (power failure, ash container spill and abnormal forces) and performed independent evaluations which considered the following additional accidents and their potential consequences: incinerator explosion, storage area fire, transportation accident and loss of power. Accidents other than those were considered in Section 8 of the Environmental Assessment, but their impacts are bounded by the impacts of the reviewed accidents. The maximum radiation dose from the worst postulated accident is only a few millirems at the site boundary.
Although there are no standards for such accident doses, for a frame of reference they are far below the NRC limit for annual exposures of radiation workers.
Since the doses from an incinerator explosion and storage area fire were calculated to be about 100 times higher than from any other accident, it was these accidents that were selected for analysis in this safety evaluation.
Furthermore, more conservative assumptions were used. These included usir:g the nearest site boundary as the point for dose calculations, ground level release, short-term X/Q values for the site and, in the case of the incinerator explosion, release of two hours worth of feed plus a full drum of ash. The same calculational method GASPAR, which implements NRC Regulatory Guide 1.109, was used for the calculations. The results are shown in Tables 6.1 through 6.4. '
As can be seen, the highest whole body dose commitment calculated is about 40 mrem from inhalation and about 600 mrem per year from ground deposited cobalt-60. It should be pointed out that it would require an extraordinary and unlikely combination of events and physical conditions to cause the release of the magnitude assumed, and it certainly represents the upper limit of consequences of any accidents that could be postulated. It should also be pointed out that the dose from ground deposition is over a period of one year. Interdiction and decontamination could certainly be performed to 35
e e
~
minimize the potential ~ dose from such an accident. Regardless, the dose is below the level (one rem) at which EPA's Draft Protective Action Guidance would'suggest that some action tue considered.
The staff.also reviewed the history of accidents involving incineration of LLW.
The review revealed two fires at NRC fuel-cycle licensee facilities, one explosion at one of the same facilities and a recent explosion in a' facility in Sweden. The fires occurred in the off gas treatment sections of incinerators operated by the General Electric Company (GE) and-Nuclear Fuel Services, Inc. Both.were the result of carry-over of incompletely combusted waste and/or deficiency of water in the off gas treatment sections. Neither resulted in the release of radioactivity to the environment or exposure of employees. The explosion at GE occurred in the shredder section 'of the incinerator. It was the. result of ignition of dust from feed accompanied by air blockage. There was no-radiation exposure of employees or significant rekease to the environment. The explosion in Sweden (Studsvik Energiteknik Company), which occurred in February 1986, was reported to be the result of combustible gases in the furnace which created an over pressure in the ash con-tainer. No significant contamination was reported, and information available to the staff is preliminary; however, the Swedish authorities have categorized the incident as a minor explosion. While the possibility of an accident in BCL's incinerator cannot be precluded from some cause, the design and conditions of operation are not likely to result in the accidents of the types that occurred at other LLW incinerators.
On the basis of this information, no postulated accident at the VROF would result in a whole body dose greater than about 40 mrem and protective actions as recommended in EPA's Draft Protective Action Guidance would not be needed.
The staff concludes that the potential for accidents has been adequately analyzed, the consequences determined, and these consequences are limited.
- 36
-a
'9 Table 6.1 --1 Dose at the Site Boundary From a Fire in the -
Waste Storage Building Inhalation Source Ters: Reactor Material, 2000 ft3 9 1.5% release Activity Activity
- 00se Whole-Body Released X/Q Inhaled Factor Dome Nuc1ide mci sec/m3 aCi Rem /50yr-mci Rem /50yr-Cr-51 8.70E-01 2.50E-03 7.55E-07 2.64E-01 Mn-54 1.99E-07 1.92E+00 2.50E-03 1.67E-06 6.30E+00 1.05E Co-58 1.80E+01 2.50E-03 1. 56E-05 6.16E+00 9.62E-05 C0-60 2.37E+01 2.50E-03 2.06E-05 1.50E+02 3.08E-03 Sr-90 2.97E-02 2.50E-03 2.58E-08 1.30E+03 Zr-95 3.35E-05 2.97E-01 2.50E-03 2.58E-07 -
1.85E+01 4.77E Ru-106 2.37E-01 2.50E-03 2.06E-07 4.40E+02 Sb-125 9.05E-05 5.70E-02 2.50E-03 4.94E-08 9.2SE+02 4.57E Cs-134 3.60E+00 2.50E-03 3.12E-06 4.80E+01-Cs-137 1.50E-04.
9.30E+00 2.50E-03 8.07E-06 3.20E+01 2.58E-04 H-3** 5.20E+01 2.50E-03 4.51E-05 6.17E-01 i
O C-14** 2.78E-05 1.90E+00 2.50E-03 1.65E-06 2.31E-02 3.81E-08 Total 3.80E-03
- Breathing Rate: 3.47E-04 m3/sec
. _ . = _ _ . .
nj
.o.
Table 6.2 '
Dose at the Site Boundary From a Fire in the Waste Sto~ rage Building Inhalation Source Term: Institutional Material, 2000 ft3 @ 1.S% release Activity Activity" Dose Whole-Body -
Released X/Q Inhaled Factor Nuclide Dose mci sec/m3 mci Rem /50yr mci Rem /50yr C0-60 8.70E+00 2.50E-03 7.55E-06 Sr-90 1.50E+02 1.13E-03 1.23E+00 2.50E-03 1.07E-06 .1.30E+03 Cs-137 3.90E+00 1.39E-03 2.50E-03 3.38E-06 3.20E+01 1. 08E-04 Tc-99 2.88E-06 2.50E-03 2.50E-12 An-241 8.33E+00 2.08E 4.20E-03 2.50E-03 3.64E-09 4.62E+05 H-3** 5.20E+03
'1.68E-03 2.50E-03 4.51E-03 6.17E-01 2.78E-03 C-14** 3.00E+02 2.50E-03 2.60E-04
- I-125** 2.31E-02 6.01E-06 3.20E+02 2.50E-03 2.78E-04 9.2SE+01 2.57E-02 Total 3.28E-02 u,
- Breathing Rate: 3.47E-04 m3/sec 2
Table 6.3 ,
Dose at the Site Boundary From an Explosion in the Incinerator and Ash Container Inhalation Source Term: Reactor Material, 100% release Activity Activity
- Dose Whole-Body Released X/Q Inhaled Factor Dose Nuclide aci sec/m3 mCf. Rem /50yr-mci Rem /50yr Cr-51 8.67E+00 2.50E-03 7.52E-06 2.64E-01 1.99E-06 Mn-54 1.91E+01 2.50E-03 1.66E-05 6.30E+00 1.04E-04 Co-58 1.79E+02 2.50E-03 1.55E-04 6.16E+00 C0-60 9.58E-04 j
2.36E+02 2.50E-03 2.05E-04 1.50E+02 3.08E-02 Sr-90 2.96E-01 2.50E-03 2.57E-07 1.30E+03 Z r-95 3.34E-04 2.96E+00 2.50E-03 2.57E-06 1.85E+01 4.75E-05 Ru-106 2.36E+00 2.50E-03 2.05E-06 4.40E+02 Sb-125 9.02E-04 i 5.68E-01 2.50E-03 4.93E-07 9.2SE+02 4.56E-04 Cs-134 3.59E+01 2.50E-03 3.11E-05 4.80E+01 1.49E-03 Cs-137 9.26E+01 2.50E-03 8.03E-05 3.20E+01 H-3** 2.57E-03 1.92E+00 2.50E-03 1.66E-06 6.17E-01 1.03E-06 oa C-14** 7.02E-02 2.50E-03 6.09E-08 2.31E-02 1.41E-09 Total. 3.76E-02
- Breathing Rate: 3.47E-04 m3/sec
^^100% release Ground Deposition 4
Activity Activity Dose Whole-80dy Released X/Q Deposited Factor Dose Nuclide mci sec/m3 pCi/m2 Rem-m2/pci yr Rem /yr Co-60 2.36E+02 2.50E-03 5.91E+06 1.04E-07 6.15E-01 i
6
.6 Table 6.4 '
Dose at the Site Boundary From an Explosion in the Incinerator and Ash Container Inhalation Source Ters: Institutional Material, '100% release Activity Activity
- Dose- .Whole-Body-Released X/Q Inhaled Factor ~
Nuclide Dose mci sec/m3 mci Rem /50yr mci Rem /50yr C0-60 8.67E+01 2.50E-03 7.52E-05 Sr-90 1.50E+02 1.13E-02 1.23E+01 2.50E-03 1.06E-05 1.30E+03 Cs-137 3.88E+01 1.38E-02' 2.50E-03 3.37E-05 3.20E+01 1.08E-03 Tc-99 2.87E-05 2.50E-03 2.49E-11 Am-241 8.33E400 2.07E-10 4.18E-02 2.50E-03 3.63E-08 4.62E405 H-3** 1.92E+03 .1.68E-02 2.50E-03 1.66E-03 6.17E-01 1.03E-03 C-14** 1.11E+01 2.50E-03 9.61E-06 I-125** 2.31E-02 2.22E-07 1.18E+01 2.50E-03 1.02E-05 9.25E+01 9.47E-04 Total 4.49E-02
- Breathing Rate: 3.47E-04 m3/sec g; **100% release Ground Deposition Activity Activity Dose Whole-Body Released .X/Q Deposited Factor Nuclide Dose mci sec/m3 pCi/m2 Rem-m2/pci yr. Rem /yr Co-60 8.67E+01 2.50E-03 2.17E+06 1.04E-07 2.25E-01 k
- r. _. <~ _
-LICENSE CONDITIONS In several sections of this safety evaluation and the Env'ironmental Assessment
~o f'the VROF, the staff has noted NRC requirements that will have_to be met by.
.Battelle in addition to NRC regulations,-the terms and conditions of.
the current license ' nd a the commitments made by BCL in their. application for
-license amendment. These requirements are translated'and summarized here as proposed license conditions.
- 1. Operation of the .VROF shall not commence without a valid permit or permths issued therefor by the State of Ohio Environmental-Protection Agency.
and other permits or authorizations required by federal statutes.
- 2. Operation of the VROF shall be conducted by the licensee in accordance with the conditions, statements and representations contained in the appli-cation for. license amendment dated August 15, 1983, and revisions dated September 28, 1984, January 4,1985, January 3,1986, and March 10, 1986, except as modified by conditions of this_ license. The licensee may make changes in the-VROF, its equipment and procedures. described in the application without license ~ amendment provided that any proposed change does not involve-(1) a modification to the provisions of Items 8, 9, or 10 of this license or Part I of the license application document; (ii) a significant increase in radiation exposure of employees; (iii) an unreviewed safety question; E
or (iv) a decrease in effectiveness of VROF effluent treatment systems.
An evaluation shall be required to validate a change to the VROF.not requiring amendment to the license. Such evaluation shall be reviewed and approved /
by the Health Physics Supervisor and the Radiological Safety Committee, and shall provide the basis for determining that the change will not involve a modification to the provisions of Items 8, 9, or 10 of this license ,.
! or Part I of the license application document, a significant increase in radiation exposure of employees, an unreviewed safety question, or a decrease in effectiveness of VROF effluent treatment systems. A change shall be deemed to involve an unreviewed safety question if an accident analysis
! for the change, (i) results in consequence values exceedi.ng the values of the accident analyses described in Section 6 of the licensee's Appendix G, '
i i
41
_cau,,.-.-,, ---\m+ aw-.m- - ~ --= = ~
y y; or th'e probability of occurrence for the types'of events there evaluated-Lis judged to increase; or (ii) reveals a possibility for an accident of. a
~different type-than previously evaluated. Records of. evaluations and approvals of changes shall be maintained by the licensee.
-3. The' licensee shall not retain low-level radioactive waste in physical..
inventory in the VRDF, either in the form of incoming waste or end-product, on behalf of customers, freight forwarders, carriers, brokers or the licensee, for a period of time in excess of one year from the time of receipt.
- 4. The licensee shall limit releases of iodine-125 in effluents from the VRDF to 0.010 curies / year. .The licensee shall maintain administrative can' trol procedures and records to achieve and demonstrate that such limits-have not been exceeded.
- 5. The licensee shall use appropriate methods for the continuous collection of gaseous ~ hydrogen-3, carbon-14 and iodine-125 samples in VRDF airborne effluents and shall analyze such samples on a daily basis when industrial and institutional waste containing these radionuclides is being processed, and on.a weekly basis when other waste, including waste from nuclear utilities, is being processed. If only nuclear reactor waste is being processed, no sampling or analysis for I-125 is required.
~
i j
- 6. . (The licensee shall install and operate a real-time continuous monitor for carticulate radionuclides in the V'ROF incinerator off gas discharge stack
,t whenever the incinerator is operating. The monitor shall annunciate in the control room and shall alarm if concentrations of expected mixtures of r
c part*culate radionuclides should exceed 24 MPC-hours, or equivalent, using
~
Appendix B, Table II values of 10 ,CFR Part 20: 'The control room shall be
, _ conkinuouslymannedduringperiods4henthe'fricieerator[isoperating.
~ 7.
r ') ,,,
The dicensee shall prepare and submit to.'tne 4RC Regional Administrator semiannually a report that provides an evaluation of VROF operations performance, including the licensee's experience with correlating and
'I managing the receipt, processing, shipment and release of radioactive
} ,
42
/
e ~ -
t
-? #. .
- j ,, . t Yh 4 .),.
material as'the result of-VRDF operitions. The;f'irst report shall
~
+i be submitte'd 6 .monthNaf s
ter, initial operation (and at 6 ma' n th intervais --T-
,- s rc thereafter. ,
.' 8. -The. licensee shall haVe available onsite a technical representative from y
the incinerator vendor for the first six months of VROF' incinerator- .,
operation to assist with operations, training and trouble-shooting.
2
- 9. The licensee shall in' stall a fence or other means of acces's centrol around the'VRDF or po,rtions thereof for radiation protection of f _ C __ _
individuals in unresfricted areas. _s
- 10. The licensee shall test installed HEPA' filters used in the VRDF after -
initial: installation,~at intervals not to exceed six months, and after , 1 filter change.' Testing shall comply with ANSI N101.1, " Efficiency Testing ,
l'?
of Air-Cleaning Systens Containing Devices for Removal of Particles," 4[)F usinga"coldDbP"te'skwithacceptancebasedonanefficiencySf- "' '
t 99.95 percent or better.
t l%
- 11. The licensee shall monitor the elivironment surrounding the VRDF for radionuclides processed therein, including nydrogen-3, carbon-14,
- - and iodine-125 fn ' air, water, soil and vegetation.
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8 CONCLUSIONS N- ,,
7A Mw Based'on evaluations of.the. application for license amendment andl supporting documents, and independent assessments, as set forth in this report, and subject
?'
to fulfillment of proposed conditions stated herein, the ' staff concludes that:
- 1. The application'. for ' amendment to NRC Materials License No. SNM-7 dated August 15,.1983, and revised by submittals dated September 28, 1984, January 4,1985, January 3,1986, and March 10, 1986, meets the standards, and requirements'of the Atomic Energy Act of 1954, as amended (the Act)
.gy and the Commission's ~ regulations set forth in 10 CFR Chapter I and is for i Ja purpose authorized by the Act; and
~
c y
% 2. The VRDF will be operated in conformity with the amended application, the P
provisions of the Act and the rules of the Commission; and Y 3. The licensee's proposed equipment and facilities are adequate to protect health and minimize danger to life and property; and
- 4. The licensee is qualified by reason of training and experience to conduct the activities authorized by the amendment in accordance with regulations of the Commission set forth in 10 CFR Chapter I in such a manner as to y( protect health and minimize danger to life and property; and (T 5. There is; reasonable assurance (a) that the activities authorized by the amendment can be conducted without endangering the health and safety of the public, and (b) that such activities will continue to be conducted in ccgipliance with the regulations of the Commission set forth in 10 CFR
, ,hipterI;and C
- 6. Tbeissuanceoftheamendmentwillnotbeinimicaltothecommondefense and security or to the health and safety of the public.
l 44
~
W N-l' l n
77 --
J: c:
-9.0 ~ REFERENCES
- 1. . Battelle _ letter, H. A. Toy, to L. C. Rouse, NRC, August 15, 1983, subject: request for amendment _to Materials License No. SNM-7 to authorize the incineration.of low-level radioactive waste as a demonstration program at West Jefferson Nuclear Sciences Area.
- 2. Battelle letter,_H. A. Toy, to L. C. Rouse, NRC, September 28, 1984, subject: submits BCL-1081, Rev. 1; safety related information, .
BCL-1081, Appendix G, Rev. 1; and the environmental assessment BCL-1081, Appendix H. , Rev.1.
- 3. Battelle letter, H. A.- Toy, to L. C. Rouse, NRC, January 4,1985, subject: submits safety related information, BCL-1081, Appendix G, Rev. 2.
- 4. Battelle letter, H.~A. Toy, to L. C. Rouse, NRC, January 3, 1986, subject: submits safety related information, BCL-1081, Appendix G, Rev. 3.
- 5. Battelle letter, H. A. Toy, to L. C. Rouse, NRC, March 10, 1986, subject: submits replacement pages 3-22 and 3-22a to BCL-1081, Appendix G, Rev. 3.
- 6. Environmental Assessment of Battelle Columbus Laboratories Volume Reduction Demonstration Facility, West Jefferson, Ohio, Docket No. 70-8, U. S. NRC, June 1986.
- 7. Incineration of Radioactive Wastes Applying the "Juelich Incineration Process," Manfred Wilke and Klaus Fatho, Heidelberg, April 1981.
45
9 - -
- 8. Safety Evaluation Report by the Division of Fuel Cycle and Material Safety Related to'the License Renewal of the Battelle Columbus.
Laboratories, Columbus, Ohio, Docket No. 70-8, License No.:SNM-7, U.S. NRC, March 1983.
- 9. Environmental Impact Assessment, Battelle Memorial Institute Laboratory, Columbus, Ohio, Report No. SAI 81-307-WA, prepared for U.S. Nuclear Regulatory Commission, February 2,1981.
- 10. NUREG-0893, The Effects of Natural Phenomena on the Battelle Memorial Institute Bui' ding JN-18 Facilities at West Jefferson, Ohio, March 1982.
- 11. Report on Safety Related Information for the-Battelle Volume Reduction Demonstration Facility, Battelle Columbus Laboratories and ATCOR Engineered Systems, Inc., April 15, 1983, et seq., (Appendix G to Renewal Application BCL-1081).
- 46