ML21039A719

Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Waste

ML21039A719
Person / Time
Site:	Westinghouse
Issue date:	02/08/2021
From:	Malek E Westinghouse
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LTR-RAC-21-18
Download: ML21039A719 (3)

Text

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Westinghouse Electric Company LLC Columbia Fuel Site 5801 Bluff Road Hopkins, South Carolina 29061-9121 USA Director, Office of Nuclear Material Safety and Direct tel: 803-647-2046 Safeguards U. S. Nuclear Regulatory Commission e-mail: malekem@westinghouse.com Document Control Desk 11555 Rockville Pike Your ref:

Rockville, Maryland 20852-2738 Our ref: LTR-RAC-21-18 February 8, 2021

SUBJECT:

Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Waste (Docket No. 70-1151, Material License SNM-1107)

REFERENCE:

1) NRC letter to Westinghouse, 12/9/2020, Westinghouse Electric Company, LLC-Amendment 25 to Material License SNM-1107, Exemption for Alternate Disposal of Specific Waste (Enterprise Project Identifier L-2020-LLL-0009) (ML20302A084)

2) Westinghouse letter to NRC, LTR-RAC-20-45, 5/8/2020, Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Waste (ML20129J934)

Westinghouse Electric Company, LLC (Westinghouse) requested NRC approval for alternate disposal of specified low-activity radioactive materials from the Columbia Fuel Fabrication Facility (CFFF), License No. SNM-1107, for certain waste containing byproduct material and special nuclear material (SNM) (Reference 2). That request was approved by the NRC on December 9, 2020 via NRC letter to Westinghouse (Reference 1).

In section 3.2 of Enclosure 1 to Reference 2, Westinghouse estimated there was 50,400 ft3 of Calcium Fluoride (CaF2) sludge previously dredged from the Calcium Fluoride Lagoons stored in a segregated area of the CaF2 storage pad. However, after moving the segregated pile of CaF2 it was discovered that the actual volume of material was less than the 50,400 ft3 assumed. Due to this discrepancy, Westinghouse cannot generate the waste aggregation characterized for disposal as described in Reference 2.

Following the submittal of Reference 2, lagoon dredging on site has continued and a second pile (Operations Pile) of CaF2 has been stored on the CaF2 storage pad separate from the previously segregated pile (Approved Pile). Material dredged from the lagoon has excess water removed via press. Two to three samples are taken per day of the material following water removal and are tested for moisture and Uranium content. Thirty-one radiological samples for Total Uranium were collected throughout the dredging operation from the material that makes up the Operations Pile and are representative of the contents of the pile. The sample results of the Operations Pile are included in Enclosure 1 to this letter. Westinghouse performed a statistical analysis of the results and has concluded that the Uranium content of the Operations Pile is bound by the sample

© 2021 Westinghouse Electric Company LLC All Rights Reserved

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Our ref: LTR-RAC-21-18 February 8, 2021 results of the Approved Pile and, therefore, the analysis of the aggregated waste dose assessment characterized in Reference 2.

Westinghouse is therefore requesting approval to dispose of a portion of the Operations Pile such that, when combined with the CaF2 from the Approved Pile, a total of approximately 50,400 ft3 of CaF2 can be added to the waste material to meet the approved waste aggregation as characterized in section 4.0 of Enclosure 1 to Reference 2. The estimated volume of material required from the Operations pile is 25,900 ft3. This request incorporates by reference and is otherwise bound by the information provided to the NRC in support of Safety Condition S-11 of SNM-1107 as described in Reference 1. Westinghouse requests a decision to this alternate disposal request and exemption by March 15, 2021 to support the planned material transport schedule.

Please contact me at (803) 647-2046 should you have questions or need any additional information.

Elise Malek Elise Malek (Feb 8, 2021 14:50 EST)

Elise Malek Regulatory Affairs Manager Westinghouse Columbia Fuel Fabrication Facility Docket 70-1151 License SNM-1107 Enclosure 1: CaF2 PILE RADIOLOGICAL DATA SET (1 Page) cc:

Mr. Thomas Vukovinsky Mr. David Tiktinsky

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Our ref: LTR-RAC-21-18 February 8, 2021 Enclosure 1 CaF2 PILE RADIOLOGICAL DATA SET Sample results of the Operations Pile of CaF2 material generated following dredging operations in 2020.

Sample # ppmU pCi/g U 1 11.31 31.78 2 11.50 32.32 3 12.30 34.56 4 13.13 36.90 5 13.22 37.15 6 13.75 38.64 7 14.00 39.34 8 15.26 42.88 9 15.30 42.99 10 15.63 43.92 11 17.14 48.16 12 18.23 51.23 13 18.28 51.37 14 18.35 51.56 15 18.60 52.27 16 18.79 52.80 17 20.91 58.76 18 21.15 59.43 19 21.29 59.82 20 21.75 61.12 21 21.82 61.31 22 22.77 63.98 23 23.10 64.91 24 23.82 66.93 25 24.12 67.78 26 24.24 68.11 27 24.49 68.82 28 25.06 70.42 29 26.30 73.90 30 30.51 85.73 31 34.33 96.47 Standard Deviation 5.5 15.4 Mean 19.7 55.3