BVY 20-025, Response to Request for Information 10 CFR 20.2002 Request for Alternate Waste Disposal at Us Ecology, Idaho (EPID L-2020-D20-0000)

Response to Request for Information 10 CFR 20.2002 Request for Alternate Waste Disposal at Us Ecology, Idaho (EPID L-2020-D20-0000)

ML20290A492
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	09/21/2020
From:	Daniels C NorthStar Nuclear Decommissioning Company
To:	Document Control Desk, NRC/EDO, Office of Nuclear Reactor Regulation
References
BVY 20-025, EPID L-2020-D20-0000
Download: ML20290A492 (15)

Text

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Northstar Nuclear Decommissioning Co., LLC Vennont Yankee Nuclear Power Station 320 Governor Hunt Rd.

North Star Vernon, VT 05354 802-451-5354 Corey R. Daniels ISFSI Manager BVY 20-025 September 21, 2020 ATTN: Document Control Desk, Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Response to Request for Information Re: 10 CFR 20.2002 Request for Alternate Waste Disposal at US Ecology, Idaho (EPID No. L-2020-D20-0000)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, NorthStar Nuclear Decommissioning, Co. LLC to USNRC, "10 CFR 20.2002 Request for Alternate Disposal at US Ecology Idaho,"

BVY 20-007, dated May 20, 2020 (ML20157A123)

2. Letter, US Ecology, Inc to USN RC, "Request for Exemptions under 10 CFR 30.11 for Alternate Disposal of Wastes from Vermont Yankee Nuclear Plant under 10 CFR 20.2002," dated May 4, 2020 (ML20174A590)

3. E-Mail to C. R. Daniels/ Northstar Nuclear Decommissioning, Co. LLC.

from Jack Parrott/USN RC, "Request for information related to 10 CFR 20.2002 alternate waste disposal request for Vermont Yankee Nuclear Power Station (EPID No. L-2020-D20-0000)," NVY 20-009, dated August 21, 2020 (ML20237F432)

Dear Sir or Madam:

By letter dated May 20, 2020 (Reference 1), NorthStar Nuclear Decommissioning Co., LLC requested NRC approval of alternate waste disposal at the US Ecology,.lnc (USEI) Resource Conservation and Recovery Act (RCRA), Subtitle C hazardous waste disposal facility located near Grand View, Idaho. The request involved approximately 2,000,000 gallons of low-activity radioactive wastewater containing byproduct material from activities associated with the decommissioning process at Vermont Yankee Nuclear Power Station (VY). VY has collaborated with USEI on this request. Since the USEI facility is not an NRC-licensed disposal facility, USEI submitted under separate letter (Reference 2) a request for an exemption pursuant to 10 CFR 30.11 to allow for the disposal of the byproduct material at the USEI facility.

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BVY 20-025 / Page 1 of 2 As part of the Staff's evaluation of our request, it was determined additional information was necessary to complete the subject review. On August 21, 2020, the NRC submitted to VY a request for additional information (Reference 3).

One new regulatory commitment and one revised regulatory commitment are contained within Should you have any questions concerning this letter, or require additional information, please contact Mr. Thomas B. Silko at (802) 451-5354, Ext 2506.

Sincerely, CRD/tbs Attachments:

1. Response to Request for Additional Information Related to 10 CFR 20.2002 Alternate Waste Disposal Request.

2. Revised USEI Site-Specific Dose Assessment Workbook - Data Input Worksheet

3. Revised USEI Site-Specific Dose Assessment Workbook - Summary of Project Alternate Disposal Dose Results.

cc: Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Senior Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-5A 10 Washington, DC 20555 Ms. June Tierney, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601

BVY 20-025 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Response to Request for Additional Information Related to 10 CFR 20.2002 Alternate Waste Disposal Request

BVY 20-025 / Attachment 1 / Page 1 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO 10 CFR 20.2002 ALTERNATE WASTE DISPOSAL REQUEST FOR VERMONT YANKEE NUCLEAR POWER STATION

Background

L----~µetter-d.ated-f\~r--2(},-,~@iRefererlCe: t)""Nl:rrttrStar uc ear ecommissioning Co., LLC requested NRC authorization for alternate disposal of certain low-activity waste containing byproduct material from Vermont Yankee Nuclear Power Station (VY) at the US Ecology, Inc (USEI) Resource Conservation and Recovery Act (RCRA), Subtitle C hazardous waste disposal facility located near Grand View, Idaho. VY collaborated with USEI on this request. Concurrent with VY's request, USEI submitted a request for exemption to 10 CFR 30.11 to allow for disposal of byproduct material at the USEI facility (Reference 2). The authority of 10 CFR 20.2002 and the exemptions requested from 10 CFR 30.11 licensing requirements for byproduct material would allow VY to transfer these wastes to the USEI facility for disposal.

The NRC staff has reviewed the subject requests and determined that additional information from NorthStar Nuclear Decommissioning Company, LLC is necessary in order to complete its review.

Request for Additional Information

1. Comment:

The version of the Site-Specific Dose Assessment Methodology (SSDA) used for the calculation of the doses appears to differ from the version reviewed by the NRC in 2018.

Basis:

US Ecology, Inc. (USEI) previously requested NRC's review of Version 3 of their SSDA methodology (Agencywide Documents Access and Management System [ADAMS]

Accession No. ML17230A221 ). During this review, USEI submitted an updated revision, Version 3a, of the SSDA spreadsheet and Technical Basis Document to the NRC. This revision corrected an error in the spreadsheet and contained other changes to certain assumed parameter values. One parameter value that was changed that affects the projected dose from the disposal of the waste included in the Vermont Yankee request is the waste contact time for the treatment workers. In Version 3a of the SSDA, the tanker survey time was incorporated into the treatment' worker task, and 10 minutes of exposure time was added to the treatment worker task resulting in a total waste contact time of 55 minutes or 0.92 hr. However, in the calculations submitted for the current 20.2002 disposal request, a waste contact time of 45 minutes (0. 75 hr) was assumed.

The NRC based its conclusion that the use of Version 3 was an appropriate method to evaluate future proposed disposals at USEI and that the SSDA methodology can be used to satisfy the criteria in 10 CFR 20.2002( d) on its review of the final Version 3a of the SSDA (ADAMS Accession No. ML18164A070). Any differences between the calculations in the spreadsheet reviewed previously by the NRC and the calculations used in the current submittal would need to be reviewed by the NRC. However, it is not clear what, if any, additional differences (aside from the treatment worker waste contact time) exist between the version of the calculations reviewed by the NRC and the calculations used for the disposal of water from Vermont Yankee.

BVY 20-025 / Attachment 1 / Page 2 of 7 Path Forward:

• Provide a justification that the exposure time of 0. 75 hr used for the treatment worker task is appropriate or provide an updated calculation of the treatment worker dose including a contact time of 0.92 hr.

• Provide a list of any other changes to the calculations between the fina.Llte.r:s<<;;)A-~-------,

spreadsheet and methodology reviewed by the NRC (ADAMS Accession Nos. ML18085A238 and ML18124A017) and the version used to calculate the doses for the VY request.

Response

An error occurred which resulted in the SSDA utilized in our submittal using an exposure time for the treatment workers of .75 hrs vs. the correct duration of .92 hrs. This response utilizes revision 3b version of the SSDA. Revision 3b corrects the treatment worker exposure time as well as other minor updates as discussed below.

Since the approval of Version 3 (Revision 3) of the USEI SSDA, US Ecology has made several updates to the SSDA in accordance with Section 4.3 of the Technical Basis Document (as provided in ML17230A221 ). Two incremental 'Minor' updates have been made to Revision 3 of the SSDA as documented in the Technical Basis Document, Revision History, as provided below Rev.# Date By Record of Revisions 3a 1/29/18 J. Weismann 1. Assigned 'Tanker Truck Drivers' task to account for tankers being used for Front-End Dray and/or Back-End Dray activities. The activity is the same so there was no need to create a new worker task for FED/BED drive time at USEI.

2. Renamed 'Gondola Railcar Surveyors' to 'Railcar Surveyors' since rail tankers could also be included in this activity.

3. Incorporated Tanker Survey Time into 'Treatment Worker' task.

Added 10 minutes exposure time for all water shipments (now 0.92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> vs original 0.75 hrs). This correction was made in SSDA cells C23 and C42 on the 'Dose Summary' tab.

4. Corrected omission of number of iterations for 'Bulk/IMC Surveyors' for certain scenarios of Bulk and Containerized loads. All scenarios now appropriately calculated.

3b 6/4/19 J. Weismann 1. 'Mayfield Processing Facility (MPF)' name changed to 'Mayfield (1) Verification Facility (MVF)'.

8/20/20 2. Corrected "Gallons per Cubic Foot" conversion factor from "7.35" to (2) correct value of "7.48." Previous value was a typographical error. Corrections were made in cells G14 and G16 on the 'Dose Summary' tab.

3. Updated 5-year average landfill volume in 'RESRAD' tab. Value of 223,029 tons now used (average for years 2015-2019).

4. Parameter adjustments to Inadvertent Intruder Scenarios to reflect more realistic operating values versus conservative assumptions in previous versions of the SSDA. Details are outlined in response

1. 2 below.

New SSDA results have been calculated using Version 3b (Revision 3b ). The results of the revised USEI SSDA - Data Input Worksheet may be found in Attachment 2. The results of the

BVY 20-025 / Attachment 1 / Page 3 of 7 revised USEI SSDA - Summary of Project Alternate Disposal Dose Results may be found in . These attachments replace the corresponding Attachments 2 and 3 provided in Reference 1.

2. Comment:

The potential dose for an individual who excavates or drills into the waste reported in this 20.2002 request exceeds the "few millirem" dose criteria.

Basis:

The doses reported in this 20.2002 request for the "Construction Scenario" and "Well Driller Scenario" are 7.67 mrem/yr and 7.2 mrem/yr, respectively, which is slightly above the "few millirem" dose criteria the NRC uses for evaluating 20.2002 disposal requests. In the 20.2002 request, it is stated that these inadvertent intruder doses are not intended to be applied to the "less than a few millirem" criteria. A basis was not provided for why these scenarios were not considered to be plausible scenarios. The reported doses do appear to be calculated using conservative assumptions and a more realistically calculated dose might be expected to be lower. For example, the dose calculation for the "Construction Scenario" did not appear to take credit for the mixing of the waste with clean material located above the waste. Similarly, the dose calculation for the "Well Driller" scenario did not appear to take credit for the mixing of the waste with clean material located above the waste or with clean material located between the waste and the resource the well driller is attempting to reach (e.g., the groundwater table).

Path Forward:

• Provide a justification for why the "Construction Scenario" is not plausible for the USEI site or provide a dose estimate demonstrating that the dose from this scenario is within a "few millirem".

• Provide a justification for why the "Well Driller Scenario" is not plausible for the USEI site or provide a dose estimate demonstrating that the dose from this scenario is within a "few millirem".

Response

The Inadvertent Intruder scenarios included in the SSDA (Rev 3 as well as earlier versions) were programmed with very conservative parameter values. The most conservative parameter value being the "Dilution Factor Due to particular Disposal Practices (fd)" which was initially set to "1.0." A dilution factor of "1.0" represents zero vertical dilution (or mixing) of the disposed waste being evaluated in this alternate disposal request. This is not representative of actual disposal practices at USEI. The total volume of waste from VY to USEI would be 9,903 yd 3 (2,000,000 gallons). The average annual wastes received at USEI from all sources during the calendar years 2017-2019 was -150,000 yd 3/yr. Accounting for the other volumes of waste received at USEI, the actual fd is calculated as 0.07. This value represents the 'as-found' dilution expected in the landfill prior to any inadvertent intruder scenario evaluation. This is consistent with the USEI SSDA Technical Basis Document which defines fd: "fd values in individual USEI ADRs [alternate Disposal Requests] are based on project-specific waste volumes compared to average annual volume accepted at USEI. Disposal practices also accounts for dilution of the radiological inventory at USEI with other non-radiological wastes that are normally accepted." Additionally, the 0.07 calculated value was programmed in for all Inadvertent Intruder Scenarios in Revision 3b of the SSDA.

BVY 20-025 / Attachment 1 / Page 4 of 7 The following Inadvertent Intruder scenario parameter adjustments were incorporated in Revision 3b of the SSDA:

i. Intruder Construction Scenario - The cover depth of the closed Cell 16 at USEI is set to 6 meters. This is deeper than a typical excavation performed to construct a residential basement or other structural foundation. However, interaction with the

~-----------v.,aste-1f8Yl~s-sttililhlaa1sS1:s;cmilrTE1e:Kdr,,1Jbotutwit an a JUS men o t e Dilution Factor" (fd). f d was adjusted from "1" to a more realistic value based on actual disposal practices at USEI. Factor adjusted to 0.07 which was calculated as annual volume of VY waste (9,903 yd 3 ) divided by average annual USEI disposal volume from 2017-2019 (150,000 yd 3 ). .

ii. Intruder-Drilling Scenario - (a) Dilution Factor (fd) of 0.07 applied (see explanation in Intruder Construction Scenario above); (b) Cover depth of Cell 16 adjusted to 6 meters.

iii. Intruder - Driller Occupancy Scenario - (a) Dilution Factor (fd) of 0.07 applied (see explanation in Intruder Construction Scenario above); (b) Cover depth of Cell 16 adjusted to 6 meters.

Vermont Yankee has recalculated the Inadvertent Intruder Dose Estimates associated with this alternate disposal request, with the above corrections as incorporated into Revision 3b of the SSDA. As captured in the Revised USEI Site-Specific Dose Assessment Workbook - Summary of Project Disposal Dose Results (Attachment 3), the following Inadvertent Intruder Dose Estimates were calculated:

i. Construction Scenario = 1.07E+00 mrem ii. Well Driller Scenario = 5.04E-01 mrem iii. Driller Occupancy Scenario = 3.36E-02 mrem By utilizing these conservative, but more realistic assumptions, the more accurately calculated Inadvertent Intruder Scenario results remain within the "few millirem" dose criteria.

3. Comment:

Information is needed on the potential for disposal of waste under the previous 20.2002 request for Vermont Yankee and the current request in the same calendar year.

Basis:

The NRC previously approved the disposal of water from Vermont Yankee at the USEI facility under 20.2002. The timing of the final shipments of the water included in the previously approved 20.2002 from Vermont Yankee to USEI is unclear. When waste is disposed under multiple 20.2002 requests from the same licensee to the same disposal facility during the same calendar year, the "few millirem" criteria for that year would apply to the combined dose from all of that licensee's 20.2002 requests.

Path Forward:

• Provide the volume of waste, if any, from the previous 20.2002 request for Vermont Yankee that could be disposed in the same calendar year as the waste in the current 20.2002 request.

BVY 20-025 / Attachment 1 / Page 5 of 7

• If waste from the previous 20.2002 request is anticipated to be disposed in the same calendar year as the current request, provide an estimate of the expected combined annual dose from the previous Vermont Yankee 20.2002 request for disposal of water at USEI and the current one.

Response

All shipments from Vermont Yankee to the USEI facility under the previous 20.2002 alternate disposal request (200,000 gallons) have been completed. To resolve this comment, VY herby commits that any shipments made pursuant to this pending alternate disposal request (2,000,000 gallons) will be provided to USEI for processing on or after January 1, 2021.

4. Comment:

More information is needed on the transfer of contaminated water to and from the tanker trucks.

Basis:

The 20.2002 request states that after the water is received at the rail transfer facility, the railcar is surveyed and then the water is transferred into tanker trucks for the final drive to the USEI facility. At the USEI facility, the water is transferred into a steel pan for stabilization with clay. The 20.2002 request provides doses for the gondola surveyors who survey the railcar when it arrives at the rail transfer facility, the tanker truck drivers who drive the water to the USEI site, and the stabilization workers. It is not clear if there are any other individuals who could potentially receive a dose from the water included in this 20.2002 request. For example, it is not clear if there are any additional workers who could receive a dose during the transfer of water from the railcar to the tanker truck. It is also not clear if any cleanout and/or survey is needed for the railcars and tanker trucks, and, if so, if anyone could potentially receive a dose in this process.

Path Forward:

• Provide information on whether any additional workers, beyond those that were evaluated in this 20.2002 submittal, could potentially receive a dose from the water included in this 20.2002 request. If any additional workers could potentially receive a dose, provide a justification that their dose is bound by the dose of the workers previously evaluated or provide a calculation of the potential dose for the additional worker roles.

• If the railcars and/or tanker trucks are not cleaned out and surveyed after the transfer of water, provide information on the process that will be used to ensure that that there is no potential for individuals to be exposed to residual radioactivity in the railcars and tanker trucks.

Response

All workers assigned to receipt, survey, and transfer of water from rail tankers to rail trucks ai USE l's rail transfer facility have been accounted for in the SSDA analysis. The workers assigned to perform these tasks have their time allotted in the analysis that conservatively captures actual contact time with the proposed waste. These workers may perform other tasks while the subject VY tasks are in progress (e.g., transfer of water from rail to truck). The time

BVY 20-025 / Attachment 1 / Page 6 of 7 programmed into the SSDA for 'Railcar Surveyors" of 20 minutes encompasses a conservative estimate of time for these workers for each rail tanker that arrives at the USEI RTF.

Once a rail tanker has been appropriately emptied, it is sealed back up and a confirmation survey performed for DOT compliance prior to the return trip to VY. The tanker survey is in accordance with 'Return

• e-asscllUH=m"'e!Ed1-1feeF-r- - - - - -

this task since the source term has been removed from the tank.

Final cleanout and disposition of the rail tanker following completion of transfer operations occurs once the rail tanks have been returned to VY, and are performed by, or under the direction of VY personnel. Thus, any dose associated with this evolution is independent of USEI personnel.

Clarification Question:

C1. Clarification is needed on the volume of waste used in the calculation of the potential dose. The 20.2002 request consists of the disposal of "2,000,000 gallons (~267,000 ft3 )"

of water. However, the volume of waste included in the SSDA calculation worksheet is 272,109 ft3. Please clarify the intended volume of waste in this 20.2002 request.

Response

An incorrect conversion factor for "gallons per cubic foot" was erroneously included in the SSDA submitted with our 20.2002 Alternate Disposal Request (Reference 1), which resulted in a different volume. The original value (272,109 ft3 ) used a conversion factor (CF) of 7.35 gal/ft3 instead of the correct CF of 7.48. Once the correct CF was used, the actual volume of water correctly reflected 267,380 ft3 (= 2,000,000 gallons). This correction is also documented in the Response to Request for Additional information item 1 above as one of the revisions incorporated into Revision 3b of the SSDA. The correct volume is reflected on the Data Input Worksheet on Attachment 2 (cell E10).

In addition to the volume correction discussed above, the incorrect CF value was also replaced in the calculations for total repetitions for 'Tanker Truck Drivers - Drive Time' (Cell G14 of Summary of Project Alternate Disposal Dose Results -Attachment 3), where 7.35 gal/ft3 was also used incorrectly. This change however, did not result in a change in the total number of repetitions.

For sake of clarification, the conversion factor of 7.35 originated from the number of "ft3 per 55-gal drum" (i.e., 7.35 ft3 = 55 gal/ 7.48 gal/ft3). This was the source of the incorrect CF used in the volume calculation on the 'Data Input Sheet' tab.

Commitments This response to request for additional information results in a revision to the third commitment provided in VY's original submittal in the following fashion (revision in parenthesis)

VY commits to perform a representative sample prior to each shipment of water and confirm that the radionuclide concentrations result in doses that are equal to or less than the doses delineated within the Summary of Project Alternative Disposal Dose Results in Attachment 3 of this submittal (Revision 3b). This confirmation can be performed by verifying that the radionuclide concentrations are equal to or less than the concentrations assumed in this

BVY 20-025 / Attachment 1 / Page 7 of 7 analysis (i.e., the concentrations identified in the Data Input Worksheet of Attachment 2) or, the confirmation can be performed by inputting the sample radionuclide concentrations into the SSDA, used in this submittal, and verifying that the dose consequences are equal to or less than the doses delineated within the Summary of Project Alternative Disposal Dose Results.

This response to request for additional information also results in one new commitment to those provided in W's original submittal:

W commits that any shipments made pursuant to this pending alternate disposal request (2,000,000 gallons) will be provided to USEI for processing on or after January 1, 2021.

References

1. Letter, Northstar Nuclear Decommissioning, Co. LLC to USN RC, "10 CFR 20.2002 Request for Alternate Disposal at US Ecology Idaho," BW 20-007, dated May 20, 2020 (ML20157A123)

2. Letter, US Ecology, Inc to USNRC, "Request for Exemptions under 10 CFR 30.11 for Alternate Disposal of Wastes from Vermont Yankee Nuclear Plant under 10 CFR 20.2002,"

dated May 4, 2020 (ML20174A590)

BVY 20-025 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Input Worksheet Revised USEI Site-Specific Dose Assessment Workb ook - Data

BVY 20-025 I Attachment 2 I Page 1 of 2 USEI Site-Specific Dose Assessment Workbook Rev._-"3b"--- Data: _ _ _8/ = 20._

{20

= 20;...,__ _

Data Input Worksheet c..-er: Northstar Project: Ve rmont Yankee Torus and Infiltration Wate r- 2M al Rall

,..,._ I- W-$4N-lnfonnellcN, wortsheet Uscc lnsmadlons and Notes:

Is the SSDA being used for the MVF?

Maximum annual dose assumed for assessment lmrem/vrl :

- No 5 1. EnterdatalntDYell-shldedcellsmfL}'.. Allothercellsinthe 3 workbook are automated and/or protected.

Volume of waste icubicfeet (ft )1: 267,380

2. Answer all questions In Section I* W-Stream Information Volume of waste (cubic yards (yd 3 )]:

first. Entervalues In yellow cells or select answer from drop-clown Volume of waste lcubic meters (m 3)] : 7""" lists provided. Notes ore also provided In keycelis toasslstthe Does waste orimarilY consist of Soil Debris a Mix of Soll/Debris or Water? Water user.

WIii shipments be made by rail truck or a combination of both? Rail 3. Enterconcentratlons (In pCl/1) f or all nuclldes In your If Both how manv miles of front-end drav are reauired? IN/A If direct shin-di 0 I 0 characterized waste stream into Section H- W- Profile Nudlde Is waste containerized or will it be shinn.d as bulk? Bulk Evaluation.

If 'Ccntalnerized' is It bel n* shicced in an intermodal, 8-25 bax or drum? NIA if 'Bulk' 4. The Maximum Acoeptable Ccnoentratlon for each nudlde is N/A determined byeltherthe USEI Waste Acoeptance Criteria (WAC) or If shinn,,,d direct via truck or tanker how manv m iles from oroiectsite to USEI? 0 I 0 a general exemption value, lhpplicable. L.oglcintheSSDA If shicced via truck or tanker will the driversleeo In the cab of his truck? N/A workbaok wll I automaticll ly choose the mostappropriate value Number of vears reouired to complete project? 2 for each nudlde.

Will waste reQuire RCRA treatment? Yes 5. USEI Is limited to a total of 3,000 pCl/gof source material Percentage of waste volume reQuirinR treatment? 100% summed overall parent& progeny nudides(Th +U).

Waste Density (lb/ft'): 62.5 6. USEI lslimltedtoatotalof 3,000 pCl/gof SNMsummedoverali fissile nuclldesandthelrlsotoplcmlxturenudldes, I.e., U-234, U-Waste Density (R!cm'l: 100 235, and U-238 forenriched uranium.

Waste Mass llbsl:

Waste Mass (tons) : ,_

A-.n7

7. Cross-checksagalnstall USEI Dose and WAC limits are 1utomatlcallycalcul1ted In the Indicators bel<>N. The activity Waste Mass (Rl : 1.---10 concentration cross-checks onlY f PDIYto Individual shipments for Does the waste contain Source Material I Uranium orThoriuml1 !Yes/Nol Yes USEI WAC compliance purpose~

Does the waste conta in Soe dal Nudear Material? (Yes/Nol No Sedlon 11

• w- Pnlllle Nudlde fnllllllan

-lmum cu_,w_ A<aptallle RallotDUSB PNlflle Conalntratlan Conalntratlan 1 lnt".1,.1' Nudkle lnt".1,.1 Concelt1nllon Ac-227 3000 ~~

AR-108m 3000 AR*llOm 3000 OK 4.90 Am-241 3000 Am-243 3000 Au-195 3000 Ba-133 3000 0.678 Be-7 3000 C-14 ca-41 3000 ' .

3000 Cd-109 3000 OK Ce-139 3000 Ce-141 3000 um Source Material WAC Check' Ce-144 3000 Cf-252 3000 OK Cl-36 3000 Cm-242 3000 USEISNMWACChec:117 Cm-243 3000 Cm-244 3000 OK Cm-245 3000 Cm-246 3000 Cm-247 3000 Cc-57 3000 Cc-58 1.0 3000 0.000 Cc-60 500.0 3000 0.167 Cr-51 3000 Cs-134 3000 Cs-135 3000 Cs-137 75.0 3000 0.025 Eu-152 3000 Eu-154 3000 Eu -155 3000 Fe-55 50.0 3000 0.017 Fe-59 3000 Gd-152 3000 Gd-153 3000 Ge-68 3000 H-3 1300.0 3000 0.433 1-125 3000 1-129 3000 1-131 3000 lr-192 3000 K-40 3000 Mn-54 10.0 3000 0.003 Na-22 3000 Nb-93m 3000

BVY 20-025 I Attachment 2 / Page 2 of 2 Nb-94 3000 Nb-95 3000 Nl-59 3000 Ni-63 so.a 3000 0.017 No-237 3000 Pa-231 3000 Pb-210 3000

--Pm-147 3000 Pu-238 3000 6

Pu-239 3000 Pu-240 3000 Pu-241 3000 Pu-242 3000 Pu-244 3000 Ra-226 3000 Ra-228 3000 Ru-103 3000 Ru-106 3000 5-35 3000 5b-122 3000 5b-124 3000 5b-12S 3000 Sc-46 3000 5m-147 3000 5m-151 3000 5n-113 3000 5r-89 3000 5r-90 3000 Tc-99 5.0 3000 0.002 Te-123 3000 5

Th-228 3000 5

Th-229 3000 5

Th-230 3000 5

Th-232 272 TI-204 3000 U-233° 3000 5

U-234 212 6

U-235 3000 U-236' 3000 5

U-238 1.0 212 0.005 5

Natural Uranium (sum) 3000 5

Refined Uranium (suml 3000 5

Deoleted Uranium lsuml 3000 Zn-65 30.0 3000 0.010 Zr-95 3000 Total Concentration /pCVg) 2022.0 Total Source Material (pCVg) 14 Total Special Nuclear Material (pCi/g) 0 Total Activity ( µCi} 3.83E+o7 SOR: .... ~:

BVY 20-025 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Revised USEI Site-Specific Dose Assessment Workbook - Summary of Project Alternate Disposal Dose Results

BVY 20-025 / Attachment 3 / Page 1 of 1 Rev:..__3_b____

USEI Site-Specific Dose Assessment Workbook Date c.,:_ _8/_,_20_._{20=20_,__

Summary of Project Altemate Disposal Dose Results Customer: Northstar I Usedfor MVF?....,___N...,_ _~

Project: Vermont Yankee Torus and lnflltratlon Water- 2M gal by Rall I Number of Project Years: 2 I M ax Dose Allowed ( mre m/yr) : 5 I al USEI Worker Total Prolect Dose Total External Total Internal Total Project Minimum External Dose per Dose per Dose per "of Max Number of Waste Contact Exposure Rate Internal Dose Distance Total No.of Worker Worker Worker Annual MEI Function Workers Tlme lhrl lmR/hrl Rate lmrem/hrl 1ml Reoetltlons lmreml lmreml lmreml Dose Front- End Drav Truck Drivers 4 0.00 O.OOE+OO O.OOE+OO 0.6 0 O.OOE+OO O.OOE+OO 0.OOE+OO 0.0%

Long- Haul Direct Truck Drivers - Drive Time 8 0.00 O.OOE+OO O.OOE+OO 0.0 0 0 .OOE+OO O.OOE-+00 0.OOE+OO 0.0%

Lono-Houl Direct Truck Drivers - Sleep Time 8 0.00 0.OOE+OO 0.OOE+OO 0.0 0 0.OOE+OO 0.OOE+OO O.OOE+OO

. j..

9.BOE+OO 195.9%

Tanker Truck Drivers - Drive Time 8 0 .75 2.61E-01 O.OOE+OO 3.3 400 9.BOE+OO Tanker Truck Drivers - Sleea Time 8 0.00 2.61E-01 0.OOE-f(}() 3.3 0 0.OOE-f(}() 0.OOE+OO 2.47E+OO 49.4%

Ra ll car Surveyors 4 0 .33 4.47E-01 O.OOE+OO 1.0 67 2.47E+OO O.OOE+OO Bulk/IMC Truck Surveyors 8 0.08 3.60E-01 O.OOE+OO 1.0 0 O.OOE+OO O.OOE+OO 0 .OOE+OO 0.0%

Container Pad Ooerators 6 o.so O.OOE+OO 6.39E-OS 1.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

RTF Excavator Ooerator 2 0.75 2.63E-01 6.39E-05 2.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Gondola Railcar Cleanout 4 0 .16 8.96E-02 6.39E-05 0.3 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Rall Transfer Eauioment Ooerator 4 0.25 4.30E-02 O.OOE+OO 4.9 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Back-End Dray Truck Drivers 8 0.75 5.14E-01 O.OOE+OO 0.6 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Treatment Workers 6 0 .92 1.56E-01 6.39E-05 2.0 401 9.57E+OO 3.93E-03 9.57E+OO 191.5%

Treatment Plant Truck Driver 2 0.16 4.02E-02 6.39E-05 0.6 991 3.19E+OO 5.06E-03 3.20E+OO 63.9%

Container Pad Truck Driver 2 0 .16 O.OOE+OO O.OOE+OO 2.0 0 O.OOE+OO 0 .OOE+OO O.OOE+OO 0 .0%

Landfill Cell Operators 2 0 .25 1.73E-01 6.39E-05 1.0 418 9.0SE+OO 3.34E-03 9.06E+OO 181.1%

bl USEI Worker Total Dose per Project Year llf applicable)

Annual Annual Total Annual Minimum External External Dose Internal Dose Dose per "of Max Number of waste Contact Exposure Rate Internal Dose Distance Total No.of per Worker per Worker Worker Annual MEI 1

Function Workers Tlme lhrl lmR/hrl Rate lmrem/hrl 1ml Reoetltlons lmreml lmreml lmreml Dose Front- End Drav Truck Drivers 4 0.00 O.OOE+OO O.OOE+OO 0.6 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Long- Haul Direct Truck Drivers - Drive Time 8 0.00 O.OOE+OO 0 .00E+OO 0.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0 .0%

Lona-Haul Direct Truck Drivers - S/eeo Time 8 0.00 0.OOE-f(}() 0.OOE+OO o.o 0 0.OOE+OO 0.OOE+OO --~ --

98.0%

Tanker Truck Drivers - Drive Time 8 0.75 2.61E-01 O.OOE+OO 3.3 400 9.BOE+OO O.OOE+OO 4 .90E+OO Tanker Truck Drivers - S/eeo Time 8 0.00 2.61E-01 0.OOE+OO 3.3 0 0.OOE+OO 0.OOE+OO --, ---

Rail car Surveyors 4 0.33 4.47E-01 O.OOE+OO 1.0 67 2.47E+OO O.OOE+OO 1.23E+OO 24.7%

Bulk/IMC Truck Survevors 8 0.08 3.60E-01 O.OOE+OO 1.0 0 O.OOE+OO O.OOE+OO 0.00E+OO 0 .0%

Container Pad Operators 6 0 .50 O.OOE+OO 6.39E-05 1.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0 .0%

RTF Excavator Ooerator 2 0.75 2.63E-01 6.39E-05 2.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Gondola Rai l car Cleanout 4 0.16 8.96E-02 6.39E-05 0.3 0 O.OOE+OO 0 .OOE+OO O.OOE+OO 0 .0%

Rail Transfer Eauipment Operator 4 0.25 4.30E-02 O.OOE+OO 4 .9 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Back- End Drav Truck Drivers 8 0.75 5.14E-01 O.OOE+OO 0.6 0 O.OOE+OO O.OOE+OO O.OOE+OO 0.0%

Treatment Workers 6 0.92 1.56E-01 6.39E-05 2.0 401 9.57E+OO 3.93E-03 4 .79E+OO 95.7%

Treatment Plant Truck Driver 2 0.16 4.02E-02 6.39E-05 0.6 991 3 .19E+OO 5.06E-03 1.60E+OO 32.0%

Container Pad Truck Driver 2 0.16 O.OOE+OO O.OOE+OO 2.0 0 O.OOE+OO O.OOE+OO O.OOE+OO 0 .0%

Landfill Cell Operators 2 0.25 1.73E-01 6.39E-05 1.0 418 9.0SE+OO 3.34E-03 4.53E+OO 90.6%

c) USEI RESRAD Post-Closure Screening Dose _ _1 _._SOE= +OO _____ mrem/yr d) lnadvertant Intruder Doses (d) 1. Construction Scenario _ _ .;;;1;,.;: E.,;.

.0.,7..;; = - -:.-m.rem/yr

+OO (d) 2. Well Driller Sce nario _ _5._._0_ 4E _-_0_1_ _m re m/yr (d) 3. Dri lle r O ccupancy Scenario _E

_ .......3_._3 6 2 _ _cm re m/y r

_-_0 _

Notes

1. If the SSDA Is being used for the MPF, only the job functions at the USEI landfill are subject to the MEI dose limits.