ML20214T855
| ML20214T855 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/25/1986 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | Farrar D COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8609300424 | |
| Download: ML20214T855 (5) | |
Text
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SEP 2 51986
' h m==I564733 DISTRIBUTION:
% d 50-3 4 Docket Nos. 50-373/374 EJordan NRC PDR BGrimes local PDR ACRS (10)
Mr. Dennis L. Farrar BWD-3 r/f Director of Nuclear Licensing EAdensam Comonwealth Edison Company ABournia Post Office Fox 767 EHylton Chicago, Illinois 60690
.RBernero Attorney, OGC
Dear Mr. Farrar:
JPartlow
SUBJECT:
Request for additional information on the petition for disposal of lower level radioactive contaminated sludge by land application under 10 CFR 20.302(a) for la Salle County Station, Units 1 and 2 By letter dated April 22, 1986, Comonwealth Edison submitted its Petition #2 for disposal of low level radioactive contaminated sludge by land application under 10 CFR 20.302(a) for la Salle County Station, Units 1 and 2.
As with the original Petition, the staff has completed its review and finds that insuf-ficient information is contained in Petition #2 in order for the staff to complete its evaluation under 10 CFR 20.302(a). Enclosed is the additional infomation requested by the staff in order to be able to complete its review in a timely manner. You should revise your submittal by addressing these items listed.
If there are any questions concerning this information, please contact A. Bournia, Project Manager at (301) 492-8698.
Sincerely 9
Elinor G. Adensam, Director BWR Project Directorate No. 3 Division of BWR Licensing
Enclosure:
As stated cc: see next page 8609300424 860925 DR ADOCK 05000373 p
PDR BWD DBL LA,: B,W
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. DBL ABournia/vag Elly13on EA am 09/25/86 09/2ff86 09 86
Mr. Dennis L. Farrar La Salle County Nuclear Power Station Commonwealth Edison Company Units 1 & 2 cc:
Philip P. Steptoe, Esquire John W. McCaffrey Suite 4200 Chief Public Utilities Division One First National Plaza 160 North La Salle Street, Room 900 Chicago, Illinois 60603 Chicago, Illinois 60601 Assistant Attorney General 188 West Randolph Street Suite 2315 Chicago; Illinois 60601 Resident Inspector /LaSalle, NPS U.S. Nuclear Regulatory Commission Rural Route No. 1 P. O. Box 224 Marseilles, Illinois 61341 Chairman la Salle County Board of Supervisors La Salle County Courthouse Ottawa, Illinois 61350 Attorney General 500 South 2nd Street Springfield, Illinois 62701 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Gary N. Wright, Manager Nuclear Facility Safety Illinois Department of Nuclear Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Rossevelt Road Glen Ellyn, Illinois 60137 29
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UNITED STATES 1
NUCLEAR REGULATORY COMMISSION n
,,i wAsHmorow.o. c.zooss REQUEST FOR ADDITIONAL INFORMATION (RAI)
ON THE LA SALLE 1 AND 2 PETITION FOR DISPOSAL OF LOW LEVEL PADI0 ACTIVELY CONTAMINATED SLUDGE BY LAND APPLICATION UNDER 10 CFR 20.302fal COMMONWEALTH EDISON CO.
00CXET NOS. 50-373 AND 50-374 The subject petition (Petition #2), submitted by Commonwealth Edison (CECO or licensee) on April 22, 1986, contains insufficient information for the NRC staff to complete its evaluation under 10 CFR 20.302(a). Specifically, it omits useful information contained in an earlier petition, it overlooks questions raised in the staff's previous RAI dated September 17, 1985, and it contains conceptual errors in procedures proposed for the disposal. The licensee should revise the submission and provide a complete, extensive analysis and evaluation 'of the proposed sludge disposal, addressing these problems and providing the staff with suffic-ient overview information and detail so that an Environmental Impact Appraisal can be prepared.
The first two pages of the licensee's Petition #2 provide useful information as to CECO's perspective for this disposal. The NRC staff agrees that land appli-cation of this very low level radioactive sludge potentially may be shown to have insignificant radiological impact, and that it would place a lesser demand on the limited disposal / burial site space.
Furthermore, the objective of limiting the annual dose from this sludge to any exposed individual to below 1 mrem /yr may be i
acceptable, if adequate demonstration is provided that all pathways are considered and that positive constraints on access to the landspread are provided. This would help to assure that the parameters used in the considerations are valid.
A number of specific issues with the petition are discussed below; 1.
The licensee's Petition #2 fails to provide sufficient information as to how they plan to assure that the annual dose to any exposed individual will be kept below 1 mrem /yr. The map provided as Appendix A should be augmented by a second legible map covering the entire site area with detailed descriptions relative to fencing and restricted or nonrestricted access areas. Additional information should be provided as to what controls, if any, will be placed on the fishermen using the lake.
2.
The following statement was made in the staff's RAI for the original petition: "In addition, analyse the other major pathways of exposure (e.g.,
drinking water from nearby wells, inhalation of resuspended particulates, and ingestion of food), or briefly state that these pathways are non-existent or negligible and provide a brief basis for this statement." Petition #2 makes no mention of these items; instead it relies entirely on considerations of direct gamma radiation.
... Migration of radioisotopes from the landspread to the cooling lake with its associated fish pathway, and eventual deposition in the rher should be I
addressed. Similarly, questions of other food ingestion, water ingestion, and -
inhalation pathways should be discussed.
3.
Appendix C of Petition #2 shows widely varying analyses for different batches of sludge for 1983. Similar information for more recent years should also be provided, particularly for late 1985 and 1986.
In view of the observed wide variability.from one batch to another, questions arise as to the variability within a batch. What are the bases for concluding that samples from 3 different areas in a 305 ft3 batch of dry sludge are sufficient to define the contamination level? This question is particularly pertinent because most of the values in Appendix C are near the proposed administrative limit.
4.
A significant error and misconception contained in Step 6, Page 4 of Petition #2, should be corrected. In NRC regulations there is no "de minimis" level below which samples can "be considered non-radioactive". The LLD of La Salle Technical Specification (TS) Table 4.11.1-1 referred to in Petition #2 is limited to releases from the monitored liquid release paths specified in TS Table 3.3.7.10-1.
This LLD was determined by assuming certain dilutions that occur in these monitored paths and is not a "de minimis" value.
La Salle TS 3.11.1.2 limits the dose to an individual from radioactive materials in liquid effluents released from each reactor unit from the site.
The TS limits the dose during any calendar year to less than or equal to 3 I
mrem to the total body and to less than or equal to 10 mrem to any organ. All of the analysis values in Appendix C of Petition #2 for the unmonitored digester sludge " stream" are less than the LLD of 5x10-7 Ci/ml and, accordino l
to the licensee's rationale, could "be considered non-radioactive". Yet it can be shown that this would violate TS 3.11.1.2.
Hence, cumulative dose calculations should be made for all batches of sludge, no matter how low the level of radioactive contamination, to demonstrate that the licensee is within the Appendix I dose limits of TS 3.11.1.2.
5.
Note should also be taken of two other misconceptions that do not appear in the licensee's Petition #2, but have appeared in submissions of similar petitions, as follows:
a) The MPCs of 10 CFR 20 are not "de minimis" values. They are associated with regular, monitored release pathways and are based on certain assumed dilutions identified with such pathways. Monitored waste streams measuring below the MPCs are not considered "non-radioactive". However, they are permitted to be discharged by the TS of the operating license on the basis of being of "no regulatory concern".
For la Salle 1 & 2, the MPCs are not applicable to release pathways which are not specified in TS Table 3.3.7.10-1.
,,, b) The exempt concentrations of 10 CFR 30 are not "de minimis" values.
They are quantities of radioisotopes that can be possessed without a license, but they apply to areas such as hospital and industrial tracers. They are not applicable to releases of power reactor-produced radioisotopes.
6.
Appendix I of Petition #2 should be expanded in order to explain in more detail what the IEPA reaulations and applications entail. Some of this type of information, contained in the first petition but omitted from Petition
- 2, would be useful. Further, a statement and verification should be included which indicates that there are no hazardous chemical constituents in the sludge proposed for disposal by land application. Similarly, statements should be made relative to potential biological hazards accompanying the sewage treatment.
7.
In Petition #2 the licensee applied for approval of the disposal under 10 CFR 20.302(a) which states:
"Any licensee or applicant for a license may apply to the Commission for approval tf proposed procedures to dispose of licensed material in a manner not otherwise authorized in the regulations in this chapter. Each application should include a description.of the licensed material and any other radioactive material involved, including the cuantities and. kinds of such material and the levels of radioactivity involved, and the proposed. manner and conditions of disposal.
The application should also include an analysis and evaluation of pertinent information as to the nature of the environment,-
including topographical, geological, meteorological, and
' hydrological characteristics; usage of ground and surface waters in the general area; the nature and location of other potentially affected facilities; and procedures to be observed to minimize the risk of unexpected or hazardous exposures."
Petition #2 deals primarily with the first half of this section.
It describes the material and conditions of disposal, but focuses hardly at all i
on the second half, regarding analysis and evaluation of "--- the environment, I
including topographical, geological, meteorological, and hydrological characteristics -- ". Equal emphasis should be placed on each of these two areas in the revised petition.
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