ML20082E402
| ML20082E402 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/21/1983 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 8035JSD, LAP-83-455, NUDOCS 8311280187 | |
| Download: ML20082E402 (13) | |
Text
Carolina Power & Light Company SERIAL: LAP-83-455 P o. Box 1551. Raleigh, N. C. 27602 NOV 211983 L E.UTLEY Executive Mce President Power Supply and Engineering & Construction Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR DISPOSAL OF WASTE OIL PURSUANT TO 10CFR20.302(a)
Dear Mr. Denton:
Carolina Power & Light Company (CP&L) hereby makes application to the United States Nuclear Regulatory Commission pursuant to 10CFR20.302(a) for approval to dispose of waste lubricating oils which contain trace amounts of licensed radioactive material by on-site combustion at Brunswick Steam Electric Plant (BSEP).
To this end, CF&L proposes to:
1.
Adopt the 10CFR30.71, Schedule B exempt quantity limit for each individual radionuclide identified by gamma scan for a 55-gallon quantity of oil.
Where combination of radionuclides are present, the limit for the combined activity is derived as follows:
2.08E5 I U l
E1 Where:
Ci = Concentrations of the "i-th" radionuclide in pCi/ml Ei = 10CFR30.71, Appendix B, exempt quantity for the "i-th" radionuclide in pCi 2.08E5 = Number of milliliters in 55 gallons 8311280187 831121 PDR ADOCK 05000324 X
- j L
i i
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m Mr. Harold R. Denton 60 Where for example, Co is identified..the limiting concentration would be 4.8E-6 pCi/ml which is derived by dividing the 10CFR30.71, 5
Schedule B exempt quantity of 1 pCi for Co 60 by 2.08E which is the number of milliliters in 55 gallons.
2.
Perform a gamma-isotopic analysis on all waste oil scheduled for disposal f rom the site with an "a priori" lower limit of detection (LLD) of SE-7 p C1/al for Mn 54, Co 5 8, Co 6 0, Zn 6 5, Mo 9 9, Cs 134, Ca l 37, Ce l41, Ce l44, and Fe59 All other gamma-emitting
?
radionuclides identified will be reported and records maintained for the life of BSEP. The total quantity of oil disposed of will be reported in the BSEP Semiannual Environmental and Ef fluent Release Report and the associated radioactivity will be accounted for in the plant's total effluent.
3.
. Limit the total quantity of radioactivity which may be released from the site by com'bustion of waste oil to 50 0C1 per calendar year.
4.
Where treatment is necessary in order to reduce the contamination within the proposed limits, representative sampling of the oil for nuclear counting shall be accomplished by collecting a sample of the waste oil batch at the completion of the decontamination process, while in recirculation (Enclosure, Figure I) and prior to drumming.
Should resampling of waste oil become necessary, rapid recirculation will be established prior to sampling to ensure that samples are representative.
5.
Waste oil disposal shall consist of incineration in either an on-site auxiliary boiler or an on-site general purpose incinerator.
Carolina Power & Light Company has developed a process of which radioactively contaminated waste. oil can be mechanically and chemicelly decontaminated to levels which are f requently at or below limits of detection. The Company will use this process as necessary to comply with the above-stated proposal.
The enclosure to this transmittal letter describes the process, presents CP&L's results using it, and further presents pertinent safety analyses for incineration of waste oil on site.
In summary, the proposed disposal method for waste oil does not constitute a threat to the health and safety of the general public as described in the enclosed safety analysis. Over the life of the plant, the proposed method of disposal will save at least $1.7 million and preserve 25005 cubic feet of burial space at low level waste disposal sites.
1
)
. Mr. Harold R. Denton Carolina Power & Light Company has an urgent need to dispose of the
' existing and future oil inventories and therefore requests approval from the Commission within 30 days following this transmittal.
Yours very truly, d
E. E. Utley EEU/ccc (8035JSD)
. Enclosure ec:
Mr. Dayne H. Brown Radiation Prot,ction Branch
. Division of Facility Services Department of Human Resources Mr. W. P. Gammill (NRC)
Mr. M. Grotenhuis (NRC)
Mr. D. O. Myers (NRO-BSEP)
Mr. J. P. O'Reilly (NRC-RII)
37~
il l
p APPLICATION FOR DISPOSAL OF WASTE OIL PURSUANT TO 10CFR20.302(a)
ENCLOSURE
TABLE OF CONTENTS I.
-Introduction II.
Safety Analysis - on-site incineration III. Cost Analysis i
l I
b i
I.
Introduction
'The Brunswick Steam Electric Plant (BSEP) consists of two 790 MWe boiling water nuclear generating units. Major efforts have been initiated within Carolina Power & Light Company (CP&L), which owns and operates the plant, to reduce the total volume of radioactive wastes. Reduced availability of federally approved low level waste disposal space is a problem which is generic to the utility industry and many innovative waste reduction technologies have been developed to find solutions. One of the most difficult waste management problems faced by the nuclear industry is the disposal of waste lubricating oil which has become contaminated with various radionuclides.
Lubricating oil becomes radioactively contaminated at commercial nuclear generating stations usually through contact with primary coolant in pressurized water reactors or feedwater and steam in boiling water reactors. Waste oil also has a tendency to end up~in the radwaste treatment facilities of all nuclear stations and usually results in substantially reduced efficiency of much of the water processing equipment.
It can easily become mixed with low-activity sludges or spent demineralizer resins, further complicating disposal.
In 1980, CP&L solidified waste oil using a commercial process. Typically, 12 gallons of waste oil.were solidified with cement and other additives in a 55-gallon drum. The drums were then shipped to an approved low level waste disposal site for burial. As a result of the high overall cost which included manpower, contractors, transportation, and burial, CP&L sought alternative disposal methods which would reduce costs and the volumes of radioactive wastes requiring disposal in approved landfills.
At the same time, CP&L undertook a prot a to decontaminate waste oil to levels such that it could be disposed of by conventional means at greatly
. reduced costs. This program has shown that, although this level can be attained, multiple treatment methods are frequently necessary. These treatments are described below.
The process consists of mechanical and chemical separation of radioisotopes from oil. A centrifuge, polishing filters, and various chemical sequestering and chelating agents are used (see Figure I).
Contamination in waste BSEP oil usually consists of contaminated water, sludge, powdered and bead demineralizer resins, and very small quantities of radionuclides which are either chemically bound to the oil molecule or
_are infinitely soluble in the form of an emulsion. The balance of the activity.is contained in water and sludges which are easily separated from the oil in the apparatus described below.
It is much more difficult to remove emulsified or organically bound radionuclides.
BSEP uses an ALFA-LAVAL Model MAB 103B centrifuge equipped with effluent polishing filters and a filter bypass valve. The centrifuge features heaters capable of heating the oil to 180*F and multiple mode operation.
Typically, 250 gallons of contaminated oil, which constitutes a batch, are-added to a tank near the centrifuge. The centrifuge is then 1
started in the purification mode which establishes a liquid / liquid separation. Excess water and large particles are removed at this time.
This water waste stream can be processed by standard radwaste equipment.
When sufficient water is removed, the polishing filters are placed in operation to remove fine suspended material. These steps usuc11y remove 90 percent of the radioactive material and reduce the total activity to approximately 1 x 10-5 pCi/ml. This constitutes the mechanical cleanup phase and the oil is then ready for the second phase or chemical decontamination.
Approximately 10 gallons of water containing buffers and sequestering agents is added to the oil tank. The centrifuge is placed in the clarification mode which simply heats and mixes the water, chemicals, and oil together. This mode does not provide an effluent waste path so the water and chemicals are not allowed to leave the system. The polishing filters are isolated. After recirculation for approximately eight hours, the centrifuge is placed in the purification mode and water, chemicals, and insolubles which have formed are removed in the effluent waste stream. After the balance of the waste is removed, the polishing filters are placed on line to remove fine precipitate material. Occasionally, the centrifuge head must also be cleaned. This process may be repeated as often as necessary until the desired level of decontamination is achieved.
The key to success in this effort is to select sequestering or chelating agents which are more soluble in water than oil, to use the correct buffers at the correct pH and frequently to alter ionic states using reducing or oxidizing agents. Essentially everything can be removed, although Co is occasionally detected at concentration of 10-7 to 10-8 pCi/ml (see Figure II). The plant has axperimented with citric acid, oxalic acid, EDTA, Nitroso-R-Salt, NH40H, and NaOH as chelating or sequestering agents; hydrazine, socium thiosulfate, and hydrogen peroxide as reducing or oxidizing agents; and attempts have also been made to run the oil through demineralizer resins and activated clays. The plant has determined that waste contaminated oils can be essentially decontaminated with multiple runs using different chemistries and that careful selection among these techniques will produce predictable results.
CP&L has thus far treated approximately 12,000 gallons of waste oil using this process and has obtained a reduction in total activity to an average of 5.64 E-7 pC1/ml. Early batches contained the largest residual concentrations of Co as well as measurable quantities of Mn'" and Co.
However, only Co remained in measurable concentrations in the latter
-batches as the process was refined.
This process and the work on 12,000 gallons of waste oil represents a substantial effort by CP&L to find a solut'on to the contaminated waste oil disposal problem which can be implemented at BSEP with minimal environmental impact.
2
3 P
II. ' Safety Analysis - On-Site Incineration
'CP&L proposes to incinerate oil under the conditions stipulated in the transmittal letter.-
,~rs 1
Procedures CP&L plans to continue to treat waste oil as necessary with the centrifuge as previously described.
If the oil meets the proposed
' limits, after sampling and analysis, the analytical results and batch volume will-be _ recorded and 'the oil transferred to 55-gallon drums or '
other suitable containers.
Periodically,Lcontainers of oil will be moved to the auxiliary boiler and burned along with number 2 fuel oil.
Alternatively, the oil may be sent to an on-site general purpose incinerator and burned.
Impact Analysis' The following assumptions are made:
- 1. - All radioactivity in-the oil is released to the atmosphere.
i 2.
Dispersion factors-(x/q) for ground level releases from the plant vents.are applicable to the boiler or general purpose incinerator.
3.
Credit is_taken-for oil treatment. For the worst case, it is assumed that Co-60 is the only radionuclide present at a concentration of 4.8E-6 pCi/ml.
4.
All 12,000 gallons of treated oil will be burned undiluted in-the shortest possible time in the auxiliary boiler to achieve maximum impact.
The_following is an analysis to determine the worst case airborne concentration _of Co which could be present as a result of oil incineration and.the resulting radiation exposure dose. Typically, the burning of oil utilizes at least 25 percent-excess air beyond that required'to ensure efficient combustion; however, to ensure conservatism, only the minimum volume of air necessary to completely-burn the oil is determined.
The following parameters hold for the average oils commonly used at BSEP:
o API - 29.3*
BTU /lb - 19,500 HHV (high heat valve)
Density - 7.32 lbs/ gallon t.
3
Minimum amount of air required for complete combustion of oils
' o with' API of 30* minimum '(from Perry's Chemical Engineers i
Handbook, 5th. Edition)(1):
7.45.1bs' air /10,000 BTU, HHV o.
Minimum amount of ; air required to burn one gallon of oil:
(1 gal)(7.32 lbs/ gal)(7.45 lbs air /10,000 BTU)(19,500 BTU /lb) =
106-lbs air required per gallon of oil.
o Minimum volume of air required to burn one gallon of oil
'. Perry)(1):
(106 lbs/ gal)(13.055 ft*/lb)(2.832 x 10" ml/ft') =
7 3.93 x 10.m1 air required per gallon of oil.
' Assume that allLthe Co activity becomes airborne; then 1.0 pCi(Co)1 per.55 gallons = 0.018 pCi(Co) per gallon.
Therefore, the' worst case concentration of Co which could be present in incineration exhaust would be:
0.018'pC1/ gallon of oil'
= 4.58E-10 pCi/ml of Co
3.93 x 10' ml air / gallon of oil burned The proposed boiler.will require a flow rate of 85 gpm which yields the-following source term:
(85' gpm)(1 min /60 sec)(4.58E -10 pCi/ml air)(3.79E3 ml oil / gal oil)
(1.037 E4 ml air /ml o11)(10' pCi/pC1) = 2.55E4_pci/sec
. Assuming that all 12,000 gallons of waste oil were to be burned undiluted at 85 gpm, a burn time of 2.353 hrs would be required.
Uring'the worst case dispersion factor cited in Table 2.3.4-15 of-tie'BSEP FSAR for a ground-level release (x/q = 8.4E-4), and eqcations C3 and C4 of Regulatory Guide l.109, the incineration process would yield the.following maximum doses at the site boundary (3000 ft):
Table 1 - Whole body and lung doses resulting from the incineration of 12,000 gallons of waste oil.
Age Group.
Whole Body Dose (mrem /yr)
Lung Dose (mrem /yr)
Adult 8.506E-5 3.430E-2 Teenager 1.142E-4 5.009E-2
' Child-1.302E-4 4.061E-2 Infant 6.769E-5 2.595E-2 4.
Of course, many conservative assumptions have been made and the actual doses expected would be far less than those shown in Table 1.
For instance, when waste oil is burned in the auxiliary boiler, a 10 fold dilution with clean fuel oil will be required to ensure uniform burning.
If the waste oil is burned in a general purpose incinerator, additional clean material waste will also be available for burning. Also, no credit has been taken for plume rise due to elevated exhaust gas temperatures or for more favorable combustion and meteorological conditions. Finally, the above analysis is based on a concentration of 1 pCi per 55 gallon drum, giving a total activity of 218.2 pC1 for the 12,000 gallons of treated oil.
In fact, however, the total measured activity residing in the treated oil is just 20.7 pCi, an order of magnitude less than assumed for the purpose of this sa'ety analysis (5). Future incineration of waste oil will consist of approximately 2000 gallons / year and would certainly yield doses less than those of Table 1.
The plant is further restricted in that only 50 pCi may be incinerated per year.
In conclusion, the proposed incineration of waste oils does not pose any threat to the health and safety of the general public.
III. Cost Analysis This section is intended to give very conservative estimates of the cost savings which could be realized by replacing solidification and burial of waste oil with on-site incineration. These estimates are considered to be conservative since inflation and cost escalation are not taken into account.
The following unit costs are used for estimating the cost of cement solidification and shallow land burial at the Richland, Washington site:
Item Unit Cost ($)
55 gallon drums 25.00 each Cement solidification 257.00/ drum (21 gallon oil / drum)
Shipping cost to 5,765.00/ shipment Richland, WA (60 drums / shipment)
Disposal feet per cubic foot 18.97/ft*
Assuming that the plant operates for 30 years and disposes of 12,000 gallons of oil the first year and 2000 gallons / year for the remainder of its life yields a total volume of 70,000 gallons. Disposal will require 3,334 drums, M shipments, and 25,005 cubic feet of disposal space. The total cost of disposal, ignoring inflation and other cost escalation, would be $1,737,373.00.
5
a References 1.
Chemical Engineers-Handbook, Perry and Chilton, 5th Edition, pp. 9-17.
2.
Meteorology and Atomic Energy 1968, USAEC, Figures 3.10 and 3.11, pp.99-103.
.3.
Regulatory Guide 1.109, Calculation of Annual Doses to Man From Routine
- Releases of Reactor Effluents for Purposes of Evaluating Compliance with 4
4.
Table 2.3.4-15, Final Safety Analysis Report - Brunswick Steam Electric
- Plant.
5.
Waste oil decontamination records,- Brunswick Steam Electric Plant.
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