ML060870617

Memo L. Cunningham, NRR, to J. Hickman, NRR, Onsite Disposal of Slightly Contaminated Sludge at the D.C. Cook Nuclear Plant Units 1 and 2 (TAC Nos. M81885/81886)

ML060870617
Person / Time
Site:	Cook
Issue date:	12/16/1993
From:	Liza Cunningham Office of Nuclear Reactor Regulation
To:	John Hickman Office of Nuclear Reactor Regulation
References
FOIA/PA-2005-0293, IR-91-015, TAC M81885, TAC M81886
Download: ML060870617 (5)

Text

II DEC 16 1993 MEMORANDUM FOR: John B. Hickman, Project Manager 6r I

Project Directorate III-3 Division of Reactor Projects FROM: LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Safety and Safeguards

SUBJECT:

ONSITE DISPOSAL OF SLIGHTLY CONTAMINATED SLUDGE AT THE D.C. COOK NUCLEAR PLANT UNITS 1 AND 2 (TAC NOS. M81885/81886)

By letter dated October 9, 1991, Indiana Michigan Power Company (I&M) submitted a request pursuant to 10 CFR 20.302 for the onsite disposal of slightly contaminated sludge at D.C. Cook. We have completed our review of the request and find the licensee's procedures, including amendments, to be acceptable. This approval is granted provided that the enclosed SER is permanently incorporated as an appendix to the licensee's Offsite Dose Calculation Manual (ODCM). Any future modifications to these amendments shall be reported to the NRC. This completes our review of TAC Nos M81885/81886.

LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Safety and Safeguards

Enclosure:

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SAFETY EVALUATION D.C. COOK NUCLEAR PLANT UNITS I AND 2 DISPOSAL OF SLIGHTLY CONTAMINATED SLUDGE

1. INTRODUCTION By letters' dated October 9 and October 23, 1991, and September 29, 1992, Indiana Michigan Power Company (I&M) requested approval pursuant to Section 20.3J2 of Title 10 of the Code of Federal Regulations (CFR) for the onsite disposal of licensed material not previously considered in the D.C. Cook Final Environmental Statement (FES) dated August 1973.

Specifically, this request addresses a situation (1982) In which approximately 942 cubic meters of slightly contaminated sludge were removed from the turbine room sump absorption pond and pumped to the upper parking lot located within the exclusion area of the D.C. Cook plant. The contaminated sludge was spread over an area approximately 4.7 acres. The sludge contains a total radionuclide inventory of 8.36 millicuries (mCi) of Cesium-137, Cesium-136, Cesium-134, Cobalt-60 and Iodine-131.

In its submittal, the licensee addressed specific information requested in accordance with 10 CFR 20.302(a), provided a detailed description of the licensed material, thoroughly analyzed and evaluated information pertinent to the impacts on the environment of the proposed disposal of licensed material, and committed to follow specific procedures to minimize the risk of unexpected exposures.

2. DESCRIPTION OF WASTE

• rhe turbine room sump absorption pond is a collection place for water released from the plant's turbine room sump. The contamination was caused by a primary-to-secondary steam generator leak that entered the pond from the turbine building sump, a recognized release pathway.

Sludge, consisting mainly of leaves and roots mixed with sand, built up inthe pond. As a result, the licensee dredged the pond in 1982. The radioactive sludge removed by the dredging activities was pumped to 2,

(:ontainment area located within exclusion area. The total volume of 942 cubic meters of the radioactive sludge that was dredged from the bottom of the turbine room absorption pond was subsequently spread and made into a graveled road over the upper parking lot (see attachment 1) area cf approximately 4.7 acres.

I&M letter from E.E. Fitzpatrick to the NRC Document Control Desk, October 9, and 23, 1991, September 29, 1992, and NRC Inspection Reports 50-315/91015 (DRSS) and 50-316/91015 (DRSS).

I 2

The principal radionuclides identified in the dredged material are listed below.

TABLE 1 136 CS (13.2 d) 0.03 N.A 1'3Cs(2.1 y) 2.34 0.18 "7Cs (30.2 y) 5.59 4.57 60CO (5.6 y) 0.9 0.27 1311 (8.04 d) 0.03 N.A

.... . ...AB

.....

......

• N.A. not applicable due to decay

3. RADIOLOGICAL IMPACTS The licensee in 1982 evaluated the following potential exposure pathways to members of the general public from the radionuclides in the sludge:

(1) external exposure caused by groundshine from the disposal site, (2) internal exposure caused by inhalation of resuspended radionuclide, and (3) internal exposure from ingesting ground water. The staff has reviewed the licensee's calculational methods and assumptions and finds that they are consistent with NUREG-1101, "Onsite Disposal of Radioactive Waste," Volumes 1 and 2, November 1986 and February 1987, respectively. The staff finds the assessment methodology acceptable.

Table 2 lists the doses calculated by the licensee for the maximally exposed member of the public based on a total activity 8.89 mCi disposed in that year.

Table 2 Pathway Whole Body Dose Received by Maximally ExDosed Individual (mrem/vear)

Groundshine 0.94 Inhalation 0.94 Groundwater Ingestion 0.73 2.61__

Total 2.61

I On July 5, 1991, the lice see re-sampled the onsite disp sal area (attachment 2) to assure hat no significant impacts and adverse effects pad occurred. A counting procedure based on the environmental LLDSo -pC-ijkg-dry-we4ght-)-`Was used by the licensee; however, '!.~ 7was imt detected during the re-sampling2. The 1991 re-sampling process used by the licensee confirms that the environmental input of the 1982 disposal was very small. The staff finds the licensee's methodology acceptable.

Based on the above discussion by the licensee, the staff finds the licensee's procedures and amendments as documented in this SER acceptable. These amendments will be permanently incorporated as an appendix to the licensee's Offsite Dose Calculation Manual (ODCM), and that future modifications are reported to NRC in accordance with the applicable ODCM change protocol.

The licensee's proposal to dispose of the slightly contaminated sludge onsite in the manner described in the D. C. Cook submittals dated October 9 and 23, 1991, September 29, 1991 and September 29, 1993, is acceptable.

The guidelines used by the NRC staff for onsite disposal of licensed material and the staff's evaluation of how each guideline has been satisfied are given in Table 3.

2 I&M letter from E.E. Fitzpatrick to the NRC Document Control Desk, September 29, 1993

4 TABLE3 2

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1. The radioactive m terial 1. Due to the nature of the should be dispose of in a  ? disposed material, manner that it is unlikely recycling to the general that the material ould be V public is not considered recycled. likely. '

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2.. Doses to the total, 2. This guideline was any body organ of minimally addressed in Table 2.

exposed individuals Although the 3 mrem/yr is of the general public or a greater than staff's non-occupationally exposed guidelines, the staff worker) from the probable finds it acceptable due pathways of exposure to the to 9 yrs decay following disposed material should be an lys is and less than 1 mrem/year. Actlvlty was detected in i .

tthe 1991 survey. l-

3. Doses to the total body and 3. Because the material will any body organ of an be land-spread, the staff inadvertent intruder from the considers the maximally probable pathways of exposure exposed individual should be less than 5 scenario to also address mrem/year. the intruder scenario.

4. Doses to the total body and 4. Even if recycling were to any body organ of an occur after release from individual from assumed regulatory control, the recycling of the disposed dose to maximally exposed material at the time the memhbr nf thp ntilic is ,_

disposal site is released not expected to exceed I from regulatory control from mrem/year, based on all likely pathways of exposure scenarios exposure should be less than considered to this I mrem. analysis.

3 E.F. Branagan, Jr. and F.J. Congel, "Disposal of Contaminated Radioactive Wastes from Nuclear Power Plants," presented at the Health Physics Society's Mid-Year Symposium on Health Physics Considerations in Decontamination/Decommissioning, Knoxville, Tennessee, February 1986, (CONF-860203).