ML24095A343

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Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report
ML24095A343
Person / Time
Site: Triso-X
Issue date: 04/04/2024
From:
Triso-X
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML24095A341 List:
References
TX0-REG-LTR-0037
Download: ML24095A343 (1)


Text

TX0-REG-LTR-0037 Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report Page 1 of 6 Waste Management RAI 3 ER-WM-1 Provide a description of the types and estimated amounts of waste that will be generated during construction, operation, and decommissioning.

In Section 4.13, provide additional information on the estimated amount and types of municipal and debris waste that will be generated during construction, operation, and decommissioning.

Also provide information on the estimated amount and types of radioactive, mixed, hazardous, industrial, debris, and municipal waste that will be generated during decommissioning. Provide assurance that local capacity exists for the debris and municipal wastes (include specific locations). Provide an estimate of the number of annual shipments of the waste streams identified in table 2.1-2 of the TRISO-X Environmental Report and table ER-WM-2-1 of the TRISO-X response to RAI dated April 14, 2023. This information is needed by staff to make an environmental impact determination.

TRISO-X Response to RAI 3 ER-WM-1

a. Construction The estimated amount and type of municipal solid waste (MSW) and excavated soil waste generated during construction is provided in new Table 4.13-1. The number of shipments and destination of the MSW is also provided.
b. Operations The estimated amount and type of non-radioactive waste generated during operations including the estimated number of shipments per year is provided in Table 4.13-2 (formerly included as Table ER-WM-2-1 from the RAI response set dated April 14, 2023). The destination of the non-radioactive waste column has been updated in Table 4.13-2 and the estimated remaining capacity has been added where available. The shipments are provided in Footnote h) of Table 4.13-2.

The estimated number of shipments per year of radioactive wastes generated during operations is provided in Footnote b) of Table 2.1-2. Table 2.1-2 will be clarified to state this table is specific to radioactive waste generated during operations.

c. Decommissioning New Table 4.13-3 provides the estimated amount and type of radioactive waste generated during the estimated 2-year decommissioning process including the total estimated number of shipments. The waste from decommissioning will be shipped to Energy Solutions in Clive, Utah.

New Tables 4.13-1 and 4.13-3, and revised Table 4.13-2, will be added to Section 4.13 of the Environmental Report.

Environmental Report Changes Tables 2.1-2 and 4.13-2 will be revised as follows (changes in red). Additionally, new Tables 4.13-1 and 4.13-3 will be added to Section 4.13 of the Environmental Report.

TX0-REG-LTR-0037 Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report Page 2 of 6 Table 2.1-2 Estimated Type and Quantity of Radioactive Wastes - Operations Description Matrix Class as Generated Contents Mass (kg/yr)

Volume as shipped (ft3) 55-gallon drum equivalent as shipped Shipment Type Destination(b)

Waste Drums Solid A

Local and central system high efficiency particulate air (HEPA) filters, consumables, dry active waste (DAW) 919,138 26,182 3562 LSA(a)

EnergySolutions Clive, UT Waste Drums Liquid A

Unrecoverable water from crystallizer, silicone oil trough refill waste 34,551 984 134 LSA(a)

EnergySolutions Clive, UT Quality Control (QC) Lab Waste Mixed A

Unrecoverable uranium samples 12,350 352 48 LSA(a)

EnergySolutions Clive, UT a) Low Specific Activity b) There are approximately 39 shipments per year and each shipment consists of 96 55-gallon drums.

TX0-REG-LTR-0037 Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report Page 3 of 6 Table 4.13-1 Estimated Type and Quantity of Nonradioactive Wastes (Excavated Soils and Municipal Solid Wastes) - Construction Waste Stream Volume (ft3)

No. of Shipments Destination Remaining Capacity (Remaining Life)

Excavated Topsoil and Subsoil 15,126,561(a)(d) 9548 by truck(a)

Off-site ocations Municipal Solid Waste 1,825,067(b)(d) 48 by truck(ab)

Chestnut Ridge Class I Landfill 16,445,775 cubic yd.

(4.44E+08 ft3)

(47 years)(c)

Notes:

a) See Section 2.1.2.1.2. 560,243 cubic yards excavated topsoil and subsoil x 27 ft3 per yard = 15,126,561 ft3 /

1,584.26 ft3 per truck = 9,548 trucks b) See Section 2.1.2.1.2. 48 trucks/month x 1584.26 ft3 per truck x 12 months x 2 years = 1,825,067 ft3 c)

Reference:

Tennessee Department of Environment and Conservation: 2023 Annual Engineering Report Class I Disposal Facilities (https://www.tn.gov/content/dam/tn/environment/solid-waste/documents/solid-waste/remaining-life-surveys/sw-2023-landfill-remaining-life-survey.pdf).

d) The total volume of excavated soil is the total for the 6-month excavation period. The total volume of municipal solid waste is for the 2-year construction period.

TX0-REG-LTR-0037 Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report Page 4 of 6 Table 4.13-12 Estimated Type and Quantity of Nonradioactive Wastes (Hazardous, Industrial) - Operations Waste Stream Classification Monthly Effluent Mass (kgs)

Annual Effluent Mass (kgs)

Volume (gal.)

No. Drums(a)(h)

Destination Remaining Capacity (Remaining Life)

HTCF Tar(d)(e)

Liquid waste(b);

Hazardous 4024.5 48,294.2 10,933.5 404.9 Waste Control Specialists in Andrews, TX 6,086,241 ft3 (20 years)(j)(k)

Bags from IsoPress Area Solid waste; Industrial 367.5 4409.8 1226.4 24.8 Chestnut Ridge Waste Management Class I Sanitary Landfill in Anderson County, TN TBD 16,445,775 cubic yd.

(4.44E+08 ft3)

(47 years)(i)

Na2CO3, NaCl, and H2O from TRISO Scrubber Solid waste; Industrial 22,171.6 266,059.4 33,317 673.1 Chemical Waste Management Landfill in Emelle, AL See Note f)

Graphite Matrix Powder Dust (PS)(c)

Solid waste; Industrial 1989.4 23,873.3 2790.9 56.4 Chestnut Ridge Waste Management Landfill in Anderson County, TN TBD GFL Environmental Lakeway Class II Industrial Landfill in Morristown, TN 16,445,775 cubic yd.

(4.44E+08 ft3)

(47 years)(i) 970,950 cubic yd.

(2.62E+07 ft3) 8 yr, 9 months(g)

Graphite Matrix Powder Dust Production Solid waste; Industrial 446.4 5356.5 626.2 12.6 Chestnut Ridge Waste Management Class I Sanitary Landfill in Anderson County, TN TBD GFL Environmental Lakeway Class II Industrial Landfill in 16,445,775 cubic yd.

(4.44E+08 ft3)

(47 years)(i) 970,950 cubic yd.

(2.62E+07 ft3)

(8 yr, 9 months)(g)

TX0-REG-LTR-0037 Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report Page 5 of 6 Waste Stream Classification Monthly Effluent Mass (kgs)

Annual Effluent Mass (kgs)

Volume (gal.)

No. Drums(a)(h)

Destination Remaining Capacity (Remaining Life)

Morristown, TN Total 28,999.4 347,993.2 48,894 1171.8 Notes:

a) All drums are 55-gal.

b) Liquid waste is overpacked in 30-gal. drums within 55-gal. drums.

c) PS - Pebble Shaping.

d) HCTF - high-temperature carbonization furnace e) All tar waste to be mixed with adsorbent. Adsorbent values are for Petroset II, a product of FluidTech.

f)

The Chemical Waste Management, Emelle, Alabama facility is positioned on a 2,700-acre site (with 650 acres permitted for disposal operations).

g)

Reference:

Tennessee Department of Environment and Conservation: 2020 Class I and II Landfill Remaining Life Survey. The 2020 survey is the most recent survey for Class II Landfills. (https://www.tn.gov/content/dam/tn/environment/solid-waste/documents/solid-waste/remaining-life-surveys/sw_2020-landfill-remaining-life-survey.pdf) h) There are approximately 13 shipments per year and each shipment consists of 96 55-gallon drums.

i)

Reference:

Tennessee Department of Environment and Conservation: 2023 Annual Engineering Report Class I Disposal Facilities (https://www.tn.gov/content/dam/tn/environment/solid-waste/documents/solid-waste/remaining-life-surveys/sw-2023-landfill-remaining-life-survey.pdf).

j)

Licensed volume of 9,000,0000 ft3 with 2,913,759 ft3 either already disposed or reserved for Texas Compact generators results in 6,086,241 ft3 remaining. 20-year remaining life is assumed based on a second 10-year license renewal through 2044.

k)

Reference:

Texas Commission on Environmental Quality Capacity Report on Low-Level Radioactive Waste, Report to the 87th Texas Legislature SFR-104/20, November 2020 (https://www.tceq.texas.gov/downloads/permitting/radioactive-materials/publications/sfr-104-20.pdf/view).

TX0-REG-LTR-0037 Enclosure - RAI Part 3 Responses for the TRISO-X Environmental Report Page 6 of 6 Table 4.13-3 Estimated Type and Quantity of Radioactive Wastes - Decommissioning(a)

Waste Type(b)

Volume(c)

(ft3)

Number of Containers(d)

Contaminated Process Equipment and Debris 859,249 11,232 Used Filters 500 7

Dust from Scabbling/Scarification 2,365 31 Dry Active Waste (used PPE, clean-up materials, etc.)

43 1

Misc Equipment and Debris (office equipment and supplies, forklifts, golf carts, tools, etc.)

78,112 1,021 Mixed waste (contains both radioactive and hazardous components) 141 2

TOTALS 940,410 12,294(e)

Notes:

a) Source document of information in this table is TRISO-X Decommissioning Funding Plan (DFP), dated April 5, 2022, submitted to NRC to meet 10 CFR 70.25(a)(2) and 70.25(e).

The DFP was developed using the guidance provided in NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance.

b) Decommissioning waste is conservatively assumed to be Low Level Radioactive Waste (LLRW) in a solid form, with the exception of a small quantity of mixed waste noted in the last table entry.

c) Waste estimates were derived based on the assembled dimensional volume of the object.

Decommissioning will be conducted by disassembling the object, thus reducing the dimensional size. Decommissioning LLRW volumes conservatively include industrial, debris, and municipal waste.

d) Waste is containerized in 90 cubic foot B-25 burial boxes, and each burial box is conservatively assumed to contain 76.5 cubic feet of waste to account for void spaces inherent with packaging disassembled objects. Waste is assumed to be shipped to Energy Solutions in Clive, Utah.

e) Assuming 8 containers per shipment, a total of 1536 shipments are made.