ML17341A246

Affidavit Addressing Aslb 810528 Memorandum & Order Re Filing of Detailed Info on Low Level Solid Waste Resulting from Repairs.Prof Qualifications & Certificate of Svc Encl

ML17341A246
Person / Time
Site:	Turkey Point
Issue date:	06/12/1981
From:	Angela Gould FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17341A245	List: ML17341A244 ML17341A246
References
ISSUANCES-SP, NUDOCS 8106190188
Download: ML17341A246 (36)

Text

UNITED STATES OF AMERICA NUCLEAR HEGULAK)RY COMMISSION BEFORE 'IHE MOMIC SAFEZY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250-SP

) 50-251-SP FLORIDA POWER 6 LIGHT COMPANY )

) (Proposed Amendments to Facility (Turkey Point Nuclear Generating ) Operating License to Permit Steam Units Nos. 3 and 4) ) Generator Repairs)

Q AFFIDAVIT OF ALAN J. GOULD My name is Alan J. Gould. My business address is 9250 West Flagler Street, Miami, Florida 33152. I am employed by Florida Power 6 Light Company (FPL) as a Power Resources Radwaste and Radiochemistry, Specialist. A statement of my educational and professional qualifications is attached to this affidavit and made a part hereof.

The purpose of this affidavit is to address the Licensing Board's Memorandum and Order of May 28, 1981, which directed the parties to file "detailed information concerning the handling, storage, transportation or other disposition to be made of low level solid waste that may be produced at

.the Turkey Point facility as a result of the proposed steam generator repairs."

As a result of my employment with FPL, I am familiar with FPL's plans for disposal of solid low-level waste generated during the repairs.

The Board's Memorandum and Order dated May 28, 1981, references paragraphs 4 and 7 of the Affidavit of Douglas King dated', May 13, 1981,

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concerning low level solid waste in "loosely stacked, sealed drums in roped off areas." The drums observed by Mr. King during his April l9, 1981, visit to the Turkey Point Plant were the approximately 1,312 55-gallon steel drums currently located within the protected area of the Turkey Point site. These drums are located as follows:

a) 792 in an open area east of Unit 3 outside of the Radiation

.Controlled Area (RCA).

b) . 108 east of Unit 4 just outside the BCA fence.

c) 156 just east of Unit 4 within the RCA.

d) 256 to the south of Unit 4 also within the KA.

Approximately 1,162 of the drums contain about 5,810 cu-ft of dirt1/ with an I

estimated average specific radioactivity concentration of about 71.4 pci/g or a total activity of about 21 mCi. All of the drums currently located outside the RCA contain such dirt. Additionally, another approximately 100 drums (all located within the BCA) contain concrete rubble with an estimated specific activity of about 100 pci/g or an additional 2.5 mCi. The remaining 50 drums (all located within the RCA) contain compacted dry trash or decontamination solids and have a total estimated activity of about 270 mCi. It should'e emphasized that these 1,312 drums have no relationship to the repairs and are not attributable to the repairs. Indeed, it is expected that some of the drums will be shipped off site prior to the conclusion of the repairs.

Nevertheless, as demonstrated herein, even if all of these drums are 1/Each drum has a capacity of about 7.5 cu-ft, but due to weight limitations, is only filled with approximately 5 cu-ft of dirt.

l included, in the evaluation of the solid low-level waste which will be handled during the repairs, this poses no radiation hazard of consequence. In fact, the concentration of radioactivity in about 1,262 of these drums is so low that transportation of'he drums would be exempt from the Department of Transportation's (DOZ) and NBC's regulations which govern shipments of radioactive materials.

In view of the recent restrictions on low-level radioactive waste (LLW) imposed by the burial sites upon nuclear waste generators, it is expected .that FPL will generate more low-level waste during the repair period than will be allocated to FPL at the Barnwell waste disposal site. As a result, the following have already been initiated:

1) A volume allocation policy regarding priority of shipments has been instituted by FPL in order to assure that all materials with higher specific radioactivity are removed from the Turkey Point site, and that whatever materials which must be retained will contain relatively low concentrations of radioactivity.

2) In addition to FPL's estimated regular monthly allocation, FPL may obtain additional bur'ial allocation from the first come, first serve pool at Barnwell. From past experience, it is expected that an additional allocation from this source of between 700 cu-ft to more than 1,000 cu-ft will be available to FPL each month.

3) FPL is seeking a permit for shipment of LLW to an alternate waste disposal facility.

FPL's policy for "priority of shipnents" works as follows: From monthly allocation of burial space at Barnwell, FPL initially schedules

'PL's shipments of low-level wastes which contain relatively high concentrations of radioactivity (e.g., resin, filters, decontamination sludges, etc.) . FPL's regular monthly allocation is sufficient to ship .to Barnwell all of this type of waste generated during the repairs. The remaining burial allocation is then used for the low-level waste with low concentrations of. radioactivity.

The volume of low-level waste that I estimate will be produced by the steam generator repairs is provided in Table 1. The solid low-level waste generated by the repairs will be handled in accordance with approved plant procedures in the same manner as low-level waste which is; generated from routine plant operating and maintenance practices. Such provisions include the compaction of dry radioactive compressible trash (i.e., rags, paper and clothing) using a highly efficient waste compactor in order to reduce the volume of this type of waste. Low-level waste which contains a high concentration of radioactivity is kept inside the Turkey Point Radwaste Building during the brief period it is on site (e.g., 2 3 months) pending preparations for shipment and transportation. All solid low-level waste-located on site will be monitored by portable monitors and swipe tests in accordance with approved plant operating procedures. Shipments offsite will be conducted in accordance with approved plant procedures and applicable DOZ and NBC regulations.

To address fully the Board's Order, I have provided in Table 2 an .

estimate of the total 2/

volume of low level waste which vill be produced at Turkey Point 3 6 4 during a two-year period which encompasses the repair.

Table 3 provides a comparison between FPL's projected burial space allocation and the low level waste expected to be generated at Turkey Point 3 a 4 during the same two-year period.

As shown in Table 3, the difference between the volume of low level waste with low concentrations of radioactivity which will. be generated at Turkey Point 3 & 4 during the repairs (55,253 cu-ft) and the Turkey Point 3.G 4 Portion of Remaining Allocation (19,498 cu-ft) is the volume of low level waste generated during the repairs which'Turkey Point may not be able to expeditiously ship to a burial site (35,755 cu-ft) . The estimated average concentration of radioactivity in this material is low, approximately 0.00064 Ci/cu-ft. The total activity contained in this amount of. waste therefore would be approximately 22.9 Ci.

Although FPL expects this volume to be significantly reduced by shipping LLW to an alternate burial facility and/or by obtaining additional burial allocation at the Barnwell site, due to current Turkey Point facility space limitations, much of this type of waste which will be generated during the repairs may have to be temporarily retained on site i'n outside areas.

In the event this low concentration LLW must be retained on site, it would be packaged as follows:

Z/Excluding Steam Generator Lower Assemblies (SGZAs), which will be stored in the Steam Generator Storage Compound.

1) Compressible trash is compacted into wooden boxes known as LSA boxes which meet the criteria of a strong, tight package under 49 CFR Part 173. These boxes are lined with steel plates and plastic liners.

When the boxes are filled, the lids are nailed in place. A steel lid cover is then nailed over the previous lid. The entire box is cross banded with five steel straps. A plastic cover is then placed over the entire box, and the box is rebanded with another five steel straps.

'2) Non-compressible solid waste with low concentrations of radioactivity would normally be packaged in steel drums meeting DOZ specifications for Type A packaging in accordance with 49 CFR Parts 173 and 178. Drum lids are clamped into place and held securely by a.

bolting ring.

As previously discussed, solid LLW which contains relatively high concentrations of radioactivity is kept in the Turkey Point Radwaste Building until shipnent. This facility has been designed to withstand the forces of hurricanes and tornados, and consequently this waste does not contribute to the potential for a radioactive release'uring one of these events. In order to minimize the potential for any release of radioactivity from LLW with relatively low concentrations of radioactivity produced during the repairs, the following precautions will be taken:

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1) Only LLW containers with low concentrations of radioactivity may be retained in outside locations.

2) Outside retention areas for waste produced during. the repairs will be within the Turkey Point 3 S 4 RCA at elevation 17.5 ft MLW.

3) LSA boxes weigh approximately 4,000 lbs. each when filled. LSA boxes which must be retained outside because they cannot be expeditiously shipped will be tied or banded together in blocks of four providing a subassembly weighing approximately 16,000 lbs. They will be stacked no more than two high. Additionally, tie downs will be used for groups of these subassem-blies. Plastic covers and/or tarps will be used to protect these containers from incl~nt weather.

4) Drums containing LLW which must be retained,'utside be-cause they cannot be expeditiously shipped, will be palletized and tied or banded together in groups of four. They will be stacked no more than two high.

When stacked, the top and bottom subassemblies will be tied or banded together, providing an assembly weighing approximately 4,000 lbs. Additionally, tie downs will be provided for those assemblies which will be grouped together.

5) In the event that FPL receives a warning of an approaching hurricane or imminent tornado, additional measures would be taken as necessary to further secure these waste containers in accordance with the Turkey

Point 3 a 4 Plant Procedure governing natural emergencies.

Additionally, the radioactivity contained in about 1,262 of the 1,312 drums which have been discussed previously is extremely low, approximately 23.5 mCi total. Seven hundred ninety two (792) of these drums are currently located at an elevation of approximately 5 ft KS within the protected area.

The remaining number are located at an elevation of 17.5 ft MLW. To minimize the potential release of this material due to a hurricane or tornado, all of the drums not currently at elevation 17.5 ft MLW will be moved to that elevation. They will be placed on a foundation of compacted crushed rock, palletized, banded together and additionally secured as discussed above.

Consequently, all of-the 1,312 drums which cannot be expeditiously shipped will'be located at elevation 17.5 ft MLW and will be appropriately secured.

Based on the following, I have concluded that. the impact of a hurricane or tornado on the LLW which might be retained at Turkey Point during the steam generator repairs poses no radiological hazard of significance:

1) The total estimated burial volume of LLW with low concentrations of radioactivity that might have to be retained outside on site during the repairs (including the 1,312 drums) is approximately 45,600 cu-ft. This represents a total estimated quantity of radioactivity of about 23.2 Ci. H?L expects that the actual volume which will have to be retained will be significantly less than this estimate because of additional Barnwell burial allocation or disposal at an alternate site.

2) The volume of waste retained would not reach a maximum until the end of the repair of the second unit.

3) Due to the protective measures which are being taken to stabilize the waste containers against impacts from

. a hurricane or tornado, it is extremely unlikely, even, if'uch an event would occur, that a large number of the packages would be breached..

4) Due to the integrity afforded by the packaging, it is unlikely that all of the radioactivity would be released from a breached container. In this regard, it is appropriate to refer to analyses which have been previously performed by the NBC of breaches of waste containers during waste handling or transportation accidents, in which the release factors for'he breach

-3 -6 of a container range from 10 to 10 of the amount of activity in the containers. 3/

5) In the event of a breach of a container and'he release of the waste therein, most of the radioactivity contained in the waste would be bound by the waste itself and would not be released as particulates. Studies- have been conducted which Final Programatic Environmental Impact Statement related to decontami-nation and disposal of radioactive wastes resulting from- March 28, 1979 acci-dent, Three Mile Island Nuclear Station, Unit 2 (NUR1X 0683), March 1981; and Environmental Survey of Transportation of radioactive material to and from nuclear power plants U.S. Atomic Energy Commission, December 1972.

4~ Brodsky in the Health Physics Society Journal (Volume 39, No. 6, Pages 992-1,000, December 1980) .

indicate that, empirical data exists to confirm "real world" values for resuspension in air of the

-6 radioactivity to be in the range of 10 to.

1 1 10 m . A resuspension factor of 10 m would be conservative. Consequently, the most significant impact for any waste which is released from a breached container would be that the waste might be physically displaced and redeposited in unrestricted areas. However, it is very unlikely that a significant quantity of waste material would be displaced to unrestricted areas. Even if this occurred, most of the activity associated with this type of release would have a high probability of being recovered.

6) No credit has been taken for the normal radioactive decay process.

Even if an extremely conservative assumption is made that 10 percent of the 23.2 Ci of radioactivity were released into the environment from this LLW due to the impact of a hurricane or tornado, the potential consequences (environmental radiation dose) which would result would be less than those which have been previously estimated for various postulated accidents because the postulated quantity of radioactivity released would be less than the quantity assumed to be released during the SGIA drop accident, less than the quantity assumed to be released to the groundwater from the RKAs, and less than the quantity assumed to be released from the SGIAs to the hurricane flood

surge. These references indicate that such releases would be within 10 CFR Part 20 limits, even though these limits "are applicable .to normal reactor operation, rather than accident conditions. 6/

FURTHER AFFIANT SAYEZH NOT.

Date STARK, OF FLORIDA .)

) SS.

'CQJNTY OF DADE )

SWORN to and subscribed before me this l~ day of June, 1981.

t Notary ic My Commission Expires:

i'ctary PuNc ~tate of Roric rrt Large

~lly Commission Expires October 30, 1083 Bonded thru Maynard Sonding Agency See Final Environmental Statement for the Turkey Point Steam Generator Repairs, g 4.4; Letter from Robert E. Uhrig to Steven A. Varga, dated February 17, 1981, item 3; Affidavit of .F. G. Plugger, H.H. Jabali and P.K. Wan on Contention 4B, pp. 15-16; Memorandum and Order of May 28, 1981, p.

35; Affidavit of Frederick G. Flugger and H. H. Jabali on Contention 4A, pp.

10-11, 16.

&Memorandum and Order of May 28, 1981, p. 36.

Cl TABLE 1 SOLID WMKE FRCN THE REPAIRS (PER UNIT)

Quantit (cu-ft)

Steam Generator Lower Assemblies 10,500 Channel Head Decontamination 1,260

• Concrete 1,620 Reactor Coolant Cutting and Weld Preparation

• Rags, Paper and Clothing 13,050

• Sand, Miscellaneous Concrete, Tools 3,000

. and Scaffolding Waste Ion Exchange Resins and Filters . 765

.Spent Resin 133 Non-Compressible Filters in Liners 400

~Lagging 2,100 K7ZAL 32,835 cu-ft (930 cu-m)

• Waste with relatively low concentrations of radioactivity.

TABLE 2 Solid LLW Generated at Turkey Point 3 6 4 During a 24-month Period Enco ssin the Re air Pro ect (Cubic Feet)

Total Volume of LLW Volume of LIÃ Volume of LLW With Low Concentration Generated at Turkey "Priori Shi in " Of Radioactivit Point 8,395 55,253 63,648

0 TABLE 3 Comparison of LLW Generated at Turkey Point 3 & 4 During a 24-&anth Period Encompassing the Repair Project with FPL's Pro'ected Allocation of Burial ce (Cubic Feet)

Turkey Turkey Point Excess FPL FPL Point Volume of Which Total Volume 3 a 4 LLW with Turkey Burial of Portion Low Point Allocation Priority FPL of Concentration May Not at Shipment Allocation Remaining of Be Able Barnwel3' LLW Remainin Allocation Radioactivit ~to Shi 46,410 15,387 31,023 19,498 55,253 35,755 This only includes FPL's estimated regular monthly allocation.

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Name: A. J. Gould Position: Radwaste and Radiochemistry Specialist Education AA, Science Presently enrolled at Florida International University completing upper .class course work in Industrial Engineering Technology Summary: Florida Power 8 Light Company 9 Years General Office Staff Radwaste and Radiochemistry Specialist-1 Year Nuclear Water Chemistry Specialist -1 Year Nuclear Mater Chemistry Coordinator -2 Years Turkey Point Nuclear Plant Plant Coordinator - Nuclear Chemistry -4 Year Associate Plant Coordinator - Nuc. Ch.-4 Year Plant Test Engineer.; Nuclear Chem. -1 Year Plant Technician - Nuclear. Chemistry -.1 Year United States Navy., Nuclear Submarine Serv. -8 Years Leading Engineering Laboratory .Tech. -4 Years Engineering Laboratory Technician -3 Years Experience: Mr. Gould is employed as a specialist on the General Office Staff of the Power Resources Department. His current responsibilities include operations at FPL's Nuclear Power Stations, which involve monitoring and evaluation of primary system radi'ochemistry parameters and/or are associated with the handling, treatment or disposal of radioactive materials.

Mr. Gould started his employment with Florida Power 8 Light Company at the Turkey Point Plant in August of 1972 as a Technician with the Nuclear Chemistry Labora-tory. He participated in the initial start up of both of the Turkey Point units. Prior to his transfer to the General Office Staff, Mr. Gould held a position that included responsibility for supervising and coordinating the day-to-day activities of the Nuclear Chemistry Laboratory.

Mr. Gould joined the Power Resources General Office Staff as a member of the Power Resources Services Group in March, 1977. His,primary .responsibilities were in the area of Operations and other activities associated with Corrosion Protection of Primary and Secondar y Systems at FPL ' Nucl ear Power Stati ons.

Mr. Gould transferred to the Power Resources Nuclear Services Group in March, 1980.

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~. a..~outa Page T~o Prior to employment with Florida Power 5 Light Company, Mr. Gould served aboard a Nuclear Powered Submarine as an Engineering Laboratory Technician, Plant Operator, and Mechanic.

E Pro fessi onal Memberships: Member, American Nuclear Society Industry Groups: Utility Nuclear Waste Management Group - Low-Level ti Waste, Edi son El ectri c I ns tute AIF Sub-committee on Solidification of Low-Level Reactor Radwaste, Atomic Industrial Forum, Inc.

Chemical: Cleaning Sub-committee, Electric Power Research Institute (EPRI), Technical Advisory Committee to the Steam Generator Owner's Group k

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSON BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket Nos. 50-250-SP 50-251-SP IN THE MATTER OF )

FLORIDA POWER 6 LIGHT COMPANY ) (Proposed Amendments to (Turkey Point Nuclear Generating ) Facility Operating Units Nos. 3 and 4 ) License to Permit Steam Generator Repairs)

CERTIFICATE OF SERVICE 1

I HEREBY CERTIFY that a copy of of the foregoing Letter to.Atomic Safety and Licensing Board and Affidavit of Alan,J. Gould was served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below:

• Marshall E. Miller, Esq., Administrative Judge Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Emmeth A. Luebke, Administrative Judge Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Mark P. Oncavage 12200 S.W. 110th Avenue Miami, Florida 33176

• Harold F. Reis, Esq.

Steven P. Frantz, Esq.

Lowenstein, Newman, Reis a Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036

• Steven C. Goldberg, Esq.

.Office of the Executive, Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.'S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Burt Saunders, Esq.

Assi'stant, Dade County Attorney 1626 Dade County Courthouse Miami, Florida 33130

• Henry H. Harnage, Esq.

Peninsula Federal Building 10th Floor 200 S.E. First Street Miami, Florida 33131

• Neil Chonin, Esq.

1400 AmeriFirst Building One Southeast Third Avenue Miami, Florida 33131 STEEL HECTOR & DAVIS Co-counsel for Licensee 1400 Southeast First Nationa Bank Building Miami, F rida 33131 Telepho (305) 577-28 3 By Nor n A. Coll June 12, 1981

• Addi'tional Service By Hand or Courier on June 15, 1981

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