ML060320293

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Slides from Consumers Energy for NRC Meeting on Big Rock Point Restoration Project
ML060320293
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Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/04/2000
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Consumers Energy
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NRC/FSME
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ML060320259 List:
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FOIA/PA-2005-0293
Download: ML060320293 (18)
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DECOMMISSIONING DEBRIS DISPOSAL Big Rock Point -Restoration Project Consumers Energy NRC Meeting Rockville, MD May 4, 2000 4MTG.WPD May 4, 2000

6 Big Rock PointRestorationProjectNRC Meeting AGENDA GENERAL DISCUSSION Decommissioning Objectives Purpose of License Amendment Request Defueled Technical Specification Change Request Bulk Materials Control Manual BMCM Contents TECHNICAL DISCUSSION Part 1 Specifications Part 2 Methodology for Requirement Implementation Surface Contamination Screening Methodology for Bulk Materials Monitoring MDA Determination Selection of an Appropriate MDA Value Hypothetical Resident/Farmer Pathways Analysis Landfill Worker Pathways Analysis Transportation Pathways Analysis May 4.2000 5-4MTG.WPD 5-4MTG.WPD of 18 Page 22 of Page 18 MaY4, 2000

Big Rock PointRestoration ProjectNRC Meeting GENERAL DISCUSSION May 4.2000 5-4MTG.WPD Page of 18 3 of Page 2 18 May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting Decommissioning Objectives 0 Return the plant site to "Greenrfield Conditions" prior to license termination using State of Michigan authorized decommissioning funding O Remove radioactive materials to a licensed waste processor or radioactive waste disposal facility U Remove clean demolition debrisfrom the sitefor local landfill disposal U Submit a License Termination Plan (LTP) after achieving "Greenfield Conditions"'

U Conduct the Final Status Survey on the "Greenfield" site after LTP submittal 0 License the onsite Independent Spent Fuel Storage Installation (ISFSI) under the existing 10 CFR 50 license - not a new 10 CFR Part 72 Genreal License May 4,2000 5-4MTG.WPD 5-4MTG.WPD of 18 Pacge 44 of Page 18 May 4, 2000

I Big Rock PointRestorationProjectNRC Meeting Purpose of License Amendment Request C Provide a definition of "clean material" in the Big Rock Point licensing basis to fill a regulatory void D Existing regulations do not address how to declare material that has been in a Restricted Area as clean and available for removal by methods other than those in identified in 10 CFR 20.2001 U Material may have had the potential for exposure to radioactive contamination or neutron activation U Material may have been contaminated but has since been decontaminated D Existing 10 CFR 20.2001 Regulatory Requirements state that:

U A licensee shall dispose of licensed material only:

  • By transfer to an authorized recipient
  • By decay in storage
  • By release in effluents within the limits in §20.1301
  • As authorized under §§20.2002, 20.2003, 20.2004, or

§20.2005

  • l Existing guidance in IE Circular 81-07 and Information Notice 85-92 pertaining to how hard to look for radioactive material was never intended for the volume of bulk materials generated by the decommissioning of a former nuclear power plant May 4, 2000 5-4MTG.WPD of 18 Page 55 of Page 18 May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting Defueled Technical Specification Change Request 0 Establish a new Bulk Materials Control Program requirement in the Administrative Controls Section 0 Bulk Materials Control Program A program shall be established to control the offsite removal of demolition debris for local landfill disposal during the decommissioning process. The program shall be contained in the Bulk Materials Control Manual (BMCM) and shall be implemented by facility procedures. The program shall include the following elements:

U Monitoring requirements for the removal of materials from the site to ensure that potential annual doses or dose commitment to an average member of the critical group from undetected licensed radioactive material shall be limited to 1 mrem.

U Screening requirements for surface contamination levels of building materials prior to final demolition of structures.

1 Minimum detectable activity (MDA) requirements for bulk materials monitoring instrumentation.

E The methodology and pathway analyses used to ensure that potential doses or dose commitment to an average member of the critical group shall be limited to 1 mrem/y.

U Record requirements to demonstrate that potential doses or dose commitment to an average member of the critical group is maintained to a limit of 1 mrem/y.

5.-4TG.PD Pge of 8 My 4,200 5-4MTG.WPD Page 6 of 18 May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting Bulk Materials Control Manual Cl Proposed Defueled Technical Specification Definition The BULKMATERIALS CONIROL MANUAL (BMCM) contains the methodology and parameters to control the offsite removal of demolition debris (bulk materials)forlocal landfill disposalduringtHr decommissioning process. This methodology ensures that no detectable licensed radioactive materials are contained in the bulk materials releasedfrom the site. The BMCM shall also contain the Bulk MaterialsControl Programrequiredby Section 6.6.2.11.

El Changes to the BMCM are allowed and become effective after a 50.59 review and approval by the Site General Manager O It must be determined that the change will not result in the potential to exceed an annual dose or dose commitment to an average member of the critical group of 1 mrem O Changes to the BMCM shall be submitted to the Commission in the Radioactive Effluent Release Report for the period in which the changes were made effective 5-4MTG.WPD Page 7 of 18 May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting BMCMI Contents Part 1 - Specifications

  • Surface Contamination Screening
  • Total Contamination U Removable Contamination
  • Bulk Materials Monitoring U Bulk Materials Monitoring Instrumentation U Minimum Detectable Activity Determination Part 2 - Methodology
  • Methodology for Requirement Implementation U Materials Stream Analysis O Surface Contamination Screening L Methodology for MDA Ietermination E Pathways Modeling and Radiological Assessment U Hypothetical Resident Farmer U Disposal Facility Operator U Transportation Part 3 - Record Requirements Part 4- Reporting of 18 May 4, 2000 5-4MTG.WPD-354MTG.WPD Passe 88 of Page 18 May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting TECHNICAL DISCUSSION May 4,2000 5-4MTG.WPD of 18 Pagle 99 of Page 18 May 4, 2000

Big Rock PointRestorationProjectNRC Meeting Part 1 Specifications Cl Format of Section:

LI Specification Requirement L Action Statement L Surveillance Requirement L Basis El Specifications Included:

U Surface Contamination Screening

  • Total Contamination
  • Removable Contamination U Bulk Materials Monitoriing
  • Bulk Materials Monitoring Instrumentation
  • Minimum Detectable Activity Determination 5-4MTG.WPD~ Pag 10 of1 a 20 5-4MTG.WPD Page 10 of 18 May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting Part 2 Methodology for Requirement Implementation 0 The BMCM is developed on the following fundamental assumptions:

U Concrete and other demolition debris will not be processed for any other use or recycled - it will only be sent to a landfill for disposal U The disposal site will be at minimum a Class II landfill that fulfills the State of Michigan requirements for such a landfill U The landfill will be local to the area within a transportable distance of 100 miles from the plant site 18 May-4. 2000 5-4MTG.WPD I11 of Page 11 Page of 18 May-4, 2000

Big Rock PointRestoration ProjectNRC Meeting Surface Contanmination Screening O Based on IE Circular 81-07, Control of Radioactive Material O Allowable Direct Survey Methods:

U Direct Surface Scans

  • Primary function iis to identify locations of elevated direct radiation
  • Sensitivity is a function of survey instrumentation and surveyor's ability
  • Guidance for the performance of direct surface scans is found in NUREG-1505 U In Situ Gamma Spectrometry Measurements
  • Allows measurement of a specific radionuclide of concern
  • May be significantly more sensitive than gross activity measurements
  • NUREG-1506 provides guidance for the design of in situ gamma spectrometry surveys U Statistically Based Direct Surface Measurements May 4, 2000 5-4MTG.WPD Page of 18 12 of Page 12 18 May 4, 2000

Rig Rock PointRestoration ProjectNRC Meeting Methodology for Bulk Materials Monitoring MDA Determination a Based on Information Notice 85-92 guidance for monitoring aggregate quantities El Basis of Bulk Container Assay System MDA o The RESRAD code is used to generate individual 1 mrem/y guideline MDAs and DS]Rs based on a comprehensive pathways analysis for each radionuclide specified L The pathways analysis is conducted for different scenarios including an upper bound scenario for landfill disposal with conservative assumptions U Hard to detect radionuclides are scaled to easily detectable radionuclides O For a mixture of radionuclides, the unity rule applies El Derivation of Bulk Container Assay System MDA U Fundamental basis is that the sum of the dose contribution from each individual radionuclide shall not exceed 1 mrem/y TEDE U IF laboratory analyses identify potential radionuclides whose individual dose contribution is less than 5 percent of the total dose, THEN that radionuclide may be disregarded providing that the sum of these percentages for all of the radionuclides disregarded in the mixture does not exceed 10 percent Page of 18 May 4, 2000 5-4MTG.WPD 5-4MTG.WPD Page 13 13 of 18 May 4, 2000

Big Rock PointRestorationProjectNRC Meeting Selection of an Appropriate MDA Value 0 Option One - Selection of the Minimum MDA Value U After selecting the most restrictive MDA value for each radionuclide from the pathway analyses, the relationship between MDAs becomes:

cI + C2

  • MDA4 1 AMDA IMA2 U A conservative approach may be taken by determining the minimum MDA based on the equation above and calculating the minimum MDA from the following equation:

1 A X Cl + C2 + ... + C,,

MJUAmin C' C2

+ + ... + Cn MDA 1 MA 2 UI This minimum MDA value may then be used as the MDA value for the bulk container assay system 5-4MTG.WPD Page 14 of 18 May 4, 2000

Big Rock Point RestorationProjectNRC Meeting Selection of an Appropriate MDA Value (Cont.)

0 Option Two - Use of Surrogate Radionuclides U When multiple radionuclides are potentially present, it is possible to assay for just one of the radionuclides U Based on laboratory analyses of representative samples, a surrogate ratio may be determined to scale a hard to detect radionuclide to a gamma emitting radionuclide easily detected by the assay system using the following equation:

AdDAsur mod = A . x Fc IDAHTD

[ HTDCsur x AIDAsur ] + ADAJTD U If there is an established ratio among the concentrations of the n radionuclides in a mixture of radionuclides that may contribute to dose, the concentration of every radionuclide can be expressed in terms of any one of them o Applying this concept, the concentration of one radionuclide may be calculated to ensure the potential dose from the mixture would be maintained below 1 narem/y using the following equation:

C -1 I DSRI + DSR2 x R2 + DSRn x Rn

- where: Rn is the surrogate ratio of the concentration G of radionuclide n to the concentration C, of

-- radionuclide 1 Pa. 15o 8Ma 20 5-4MTG.WP_ Page 15 of 18 May 4, 2000

&4MTG.WPD

Big Rock PointRestoration ProjectNRC Meeting Hypothetical Resident/Farmer Pathways Analysis 0 Pathways Analyses were performed using the RESRAD code L Default parameters were used unless modification was justified based on site specific assumptions U Single nuclide guideline MDA and DSR values were calculated based on a TEDE of 1 mrem/y O Exposure Pathways Analyzed U External Exposure U Inhalation U Ingestion of Ground Water U Ingestion of Plants U Ingestion of Meat U Ingestion of Milk U Ingestion of Aquatic Food U Ingestion of Soil U Radon O Site Specific Assumptions U Landfill operates for 20 years after debris placement U Post-closure monitoring is performed for 30 years with public access restricted U Disposal site is released for potential residential use after the post-closure monitoring period ends U No covering-remains after the post-closure monitoring period ends U No credit is taken- for groundwater protection either during site operation, during the post-closure monitoring period or after resident/farmer use is established U Radionuclides with T% less than 180 days are not included May 4, 2000 5-4MTG.WPD Page of IS 16 of Page 16 la May 4, 2000

Big Rock PointRestoration ProjectNRC Meeting Landfill Worker Pathways Analysis D RESRAD was also used to perform the pathways analyses 5 Exposure Pathways Analyzed included U External Exposure U Inhalation O Resident/Farmer site specific assumptions were used where applicable O Landfill Worker site specific assumptions included:

U The most exposed landfill worker is the bulldozer operator who positions and spreads the demolition debris and places a daily soil cap over the debris O It was assumed that only one worker was involved (potential dose was not distributed)

U The landfill operator works 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> days U Based on debris volume estimates and daily disposition rates, the

- - landfill worker exposure period is 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> over a one year duration U The daily 6 inch soil cover was assumed to completely erode by the end of the post-closure monitoring period O Maximum potential landfill worker dose based on the most restrictive Resident/Farmer pathways analysis radionuclide mixture - 0.1 mrem/y May 4, 2000 5-4MTG.WPD 5-4MTrG.WPD Page 17 of Page 17 of 115 8 May 4, 2000

Big Rock PointRestorationProjectNRC Meeting Transportation Pathways Analysis O Pathways analyses were performed using the MicroShield code 0 Truck transportation from the BRP site to the landfill is the only mode available O Transport systems analyzed included:

U Roll-Off Container System U Dual-Trailer Mule System U Wide-Bodied Demolition Hauler 0 Specific assumptions included:

U Three truck drivers were involved U Transport time from the BRP site to the landfill is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> U Individual truck driver exposure period is 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> over a one year duration El Maximum potential truck driver dose based on the most restrictive Resident/Farmer pathways analysis radionuclide mixture - 0.09 mrem/y Page of 18 18 of May 4, 2000 5-4MTG.WPD Page 18 18 May 4, 2000

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