ML19337B587

Forwards Addl Info Re Vehicle Cask Loading Requirements & Special Procedures & Precautions for Radwaste & Radioactive Matl.Provides Assurance That Process Control Program Waste Shipments Comply W/Burial Ground Requirements

ML19337B587
Person / Time
Site:	Farley
Issue date:	09/30/1980
From:	Clayton F ALABAMA POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML19337B588	List: ML19337B587 ML19337B590
References
NUDOCS 8010070341
Download: ML19337B587 (6)

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At ttma Power Company

• 600 N:rtn 18th Street Post Office Box 2641

• Birmingham. Alabama 35291 Telephone 205 250-1000 F. L CLAYTON, JR. m senior vice President Alabama Power the 50uthem elecinc System September 30, 1980 Docket No. 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulaiary Commission Washington, D. C. 20555 Attention: Mr. A. Schwencer Gentlemen:

JOSEPH M. FARLEY NUCLEAR PLAiiT DRAFT LICENSE NO. NPF-8 ITEM 2.C.(9)

As required by the draft license for Farley Nuclear Plant Unit 2, Alabama Power Company submits additional infomation which provides assurance that the process control program provides waste shipments that conform to applicable burial ground requirements.

If there are any questions, please contact us.

Yours very truly, h.'k?'a.3D~D-F. L*. Cl ay~ ton, Jr. ,

RLG:de Attachment cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr.W.L.H.L.Bradford Mr. Kintner w/(wattachment attachment) )

8*1oorosy

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D Attachment The aspects of the Farley Nuclear Plant (FNP) radwaste process control program and associated administrative control ensures compliance with the Barnwell, South Carolina burial ground requirements . The FNP program for complying with the burial ground requirements is described in FNP-0-RCP-56.

The criteria transmitted to Alabama Power Company by letter dated March 20, 1980 are described below:

Criteria 1.0 " GENERAL INFORMATION" Chem-Nuclear Systems, Inc. (CNSI) acceptance of material for disposal and CMSI published disposal rates are based upon compliance with Barnsell Site Disposal Criteria (" Site Criteria"). Deviations from the Sita Criteria shall not be permitted without prior approval by CNSI's Barnwell Site Manager. Any such deviation may result in refusal of shipments and/or a surcharge.

Compliance: Alabama Power Company complies with all the Barnwell Site Disposal Criteria before shipments are allowed to leave tr FNP Site.

Criteria 2.0 " VEHICLE / CASK LOADING REQUIREMENTS" This section lists several criteria for shipments of drums, boxes, crates, and casks. These criteria cover loading, bracing, shielding,

• etc. to insure proper shipments.

Compliance: APCo complies with all these applicable criteria and an inspection is performed before shipment is pennitted to leave the FNP Site to verify compliance.

l Criteria 3.0 " COMPLIANCE WITH CNSI/NRC CASK LICENSING REQUIREMENTS" All requirements set forth in the Nuclear Regulatory Commission (NRC)

Certificates of Compliance (lid torquing, sealing gaskets, weight l restrictions, etc.) shall be strictly adhered to. Failure to observe i any requirements shall result in the submission of non-compliance l reports to the appropriate reszl ttory agency. Shippers using a  !

cask not owned by CNSI shall ensure that CNSI is a " Registered User" of the licensed cask prior to shipment to the Barnwell Site. This applies to all shipments requiring licensed containers.

Compliance: APCo uses licensed containers for those shipments requiring licensed containers and complies with the requirements of the certificate for each container.

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Criteria 4.0 " PERMISSIBLE EXTERNAL SURFACE C0flTAt1IrlATION OF PACKAGE / VEHICLE" All shipmar.ts received at the Barnwell Site shall comply with contadnation control limits as prescribed in Section 173.397, Title 49, of the Code of Federal Regulations.

Compliance: APCo performs contamination and radiation surveys on each vehicle prior to releasing the shipment from the FNP site.

The limits prescribed in Section 173.397, Title 49, of the Code of Federal Regulations are met on each shipment.

Criteria 5.0 " PACKAGING 0F RADI0 ACTIVE BIOLOGICAL MATERIALS" These criteria cover the requirements for packaging of radioactive biological waste.

Compliance: APCo does not have any radioactive biological waste.

Criteria 6.0 " LIQUID RADI0 ACTIVE WASTE" Absolutely nothing in a liquid state shall be received at the Barnwell Site. Solidified water may be accepted provided it is solidified with one of the solidification media specified in the South Carolina

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Radioactive License rio. 097. There is not an acceptable solidifi-cation media for oil or organic solutions at this time.

Note: This criteria has been further defined by a letter dated October 30, 1979, from tir. Heyward Shealy, Chief Bureau of Radiological Health, State of South Carolina. This letter to the operating company of the Barnwell Site states that the amount of free standing liquid will be defined as less than 1% liquid by volume until December 31, 1980. Effective January 1, 1981, waste packages shall contain only trace quantities (not more than 0.5% or one gallon per container; whichever is less) of free standing liquids. Any liquids present in waste packages shall be noncorrosive to the container. Resins with a total specific activity of 1 1Ci/cc J

or greater, disposed of after June 30, 1981, must be stabilized by solidification. All other resins may be shipped in a dewatered form.

Compliance: Wastes generated at the FNP are currently being solidified by Chem Nuclear Systems, Inc. utilizing urea formaldehyde which is an acceptible media under the South Carolina Radioactive License No. 097. Alabama Power Company Process Control Program which ensures meeting this criteria is describe ' in FNP-0-RCP-474. Chem Nuclear has provided evidence to the NRC in their letter dated August 16, 1979 (Enclosure 1) that the current system i

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(being used at the FNP) meets the 1% freestanding liquid require-ment. Tests conducted at Barnwell utilizing the Process Control Program which incorporates secondary dewatering has verified that I this limit is achieved prior to shipment. Since this system has not yet been verified to meet the 1/2% or one gallon requirement, Alabama Power Company has elected to shift from mobile solidifi-cation of aqueous waste to mobile demineralization provided by Hittman Corporation. It is Alabama Power Company's intention to maintain administrative control on resin activity to ensure that the 1,uCi/cc limit is not exceeded and therefore plans to ship only dewatered resin after January 1,1981. Hittman Corporation has provided assurance to Alabama Power Company that insitu solidification capability is available if the limit is exceeded.

Currently Hittman Corporation is solidifying resins at other nuclear plants.

Criteria 7.0 "SPECIAL PROCEDURES" i

This criteria covers loading, storage, exchange of liners and handling of pallets for casks.

Compliance: Alabama Power Company complies with this criteria by performing the loading of FNP shipments utilizing Alabama Power Company personnel, w

Criteria 8.0 "SPECIAL PRECAUTIONS" l

This criteria outlines special precautions concerning airborne contamination and other unusual hazards. l Compliance: Alabama Power Company notifies the burial ground when the potential exists for airborne contamination based on contents

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of each container. Alabama Power Company provides a written state-ment on the Radioactive Shipment Record Form identifying unusual  !

hazards.

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Criteria 9.0 "RADI0 ACTIVE SHIPMENT RECORD (RSR) FORMS" This criteria outlines the information required for the RSR Forms.

Compliance: Alabama Power Company completes the RSR Forms for each

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shipment in accordance with this criteria, i

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r Criteria 10.0 "VOLUf1E ALLOCATION AND PRIOR NOTIFICATION PLANS" This criteria describes the Barnwell Site prior notification plan (PNP) for administrative control of burial volume allocation.

Compliance: Alabama Power Company follows these administrative j guidelines.

Criteria 11.0 " SHIPMENTS NOT AUTHORIZED BY Chem Nuclear Systems, Inc.

(CNSI) RADI0 ACTIVE MATERIAL LICENSES" This criteria describes method for obtaining amendments for the burial ground license to accept shipments of waste requiring an amendment.

Compliance: Alabama Power Company does not ship any material that is not authorized in the current burial ground license.

Criteria 12.0 "Oll" All radwaste packages shall be certified by the shipper to contain less than one percent (1%) of unintentional oil by volume. No oil shall be blended or mixed intentionally in any shipment. (See Paragraph 6.0) There is no acceptable solidification media for

+ oil or organic solutions.

Compliance: Alabama Power Company certifies on RSR Form that ship-ments contain less than 1% of unintentional oil by volume.

Criteria 13.0 " TRANSURANIC CONTENTS" This criteria requires c' rtification as to the quantity of transuranic l isotopes contained in each package which is to not exceed 10  !

nanocuries per gram.

Compliance: Alabama Power Company cerifies on the RSR Form each package as to its transuranic isotopic content.

Criteria 14.0 " VOLUME MEASUREMENT CRITERIA" This criteria outlines the administrative guidelines for determining burial volume.

Compliance: Alabama Power Company used this criteria in determining l burial volume.

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Criteria 15.0 " TRANSPORTATION" l

This criteria states that no collect shipments or rail shipments will I be accepted, l I

Compliance: Alabama Power Company does not ship waste by either i method. l Criteria 16.0 "RETRIEVABILITY OF DISPOSED MATERIAL" All materials disposed at the Barnwell Site are the property of the State of South Carolina, and no provision or authority exists for retrieval following disposal.

Compliance: Alabana Power Company accepts this criteria and has no plans for retrieval.

Criteria 17.0 " ADDITIONAL REGULATIONS AND REQUIREMENTS"

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This criteria references additional federal and state regulations applicable to the Barnwell Site.

Compliance: Alabama Power Company shipments comply with specifications

set forth in CFR, Title 49 and Title 10 and Chem Nuclear's South Carolina Radioactive Material License No. 097.

Criteria 18.0 " SHIPMENTS VIOLATING REGULATIONS OR CRITERIA" This criteria describes administrative controls for providing notifi-cation and correcting violations of regulations or criteria.

- Compliance: Alabama Power Company subscribes to these administrative controls on all shipments from FNP.

Criteria 19.0 "SPECIAL NUCLEAR MATERIAL" This criteria describes the handling of shipments containing special nuclear material.

Compliance: Alabama Power Company does not ship special nuclear material as low level radioactive waste.

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