DRC-2018-005956 - 0901a0688084efd8

Div of Waste Management
and Radiation Control
JUN 1 8 2018
ENE GYSOLUTIONS NC-2M -0-05956
June 18, 2018 CD18-0112
Mr. Scott T. Anderson
Director
Utah Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, Utah 84114-4880
Subject: Radioactive Material License UT 2300249; San Onofre Nuclear
Generating Station's Unit 1 Reactor Pressure Vessel Project and
Concurrence Summary
Dear Mr. Anderson:
As requested during a phone conversation with staff, EnergySolutions herein provides the
Division of Waste Management and Radiation Control with the attached Project Log for
their concurrence request with the application of the U.S. Nuclear Regulatory
Commission's (NRC) Branch Technical Position on Concentration Averaging and
Encapsu1ation1 (BTP) to the classification of the San Onofre Nuclear Generating
Station's Unit 1 Reactor Pressure Vessel (SONGS RPV). In addition to the attached
Project Log, EnergySolutions responds further responses to the Division's amended
request for additional information regarding potential consequences from inadvertent
intrusion into the disposed SONGS RPV.
In 2000, NRC published stakeholder recommendations for appropriate performance
assessment methodologies to support rules promulgated in 1981 as 10 CFR 61.2 As part
of its efforts to revise regulations contained in 10 CFR 61, NRC requested public
comment on these original stakeholder recommendations in "Guidance for Conducting
Technical Analysis for 10 CFR Part 61, Draft Report for comment (NUREG-2175)."3
Over concerns with differences with the proposed rules with direction received from
Commissioners, NRC later retracted this document and directed staff to further revise
U.S. Nuclear Regulatory Commission. "Concentration Averaging and Encapsulation Branch Technical
Position, Revision 1: Volume 1" Office of Nuclear Material Safety and Safeguards, U.S. Nuclear
Regulatory Commission, February 2015. 2 U.S. Nuclear Regulatory Commission. "A Performance Assessment Methodology for Low-Level
Radioactive Waste Disposal Facilities — Recommendations of NRC's Performance Assessment
Working Group." (NUREG-1573). Office of Nuclear Material Safety and Safeguards, U.S. Nuclear
Regulatory Commission, October 2000.
3 Esh, D. et al. "Guidance for Conducting Technical Analyses for 10 CFR Part 61 — Draft Report for
Comment." Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission,
March 2015.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 2 of 8
their proposed changes to 10 CFR 61.4 Uncertainty in the applicability of the NUREG-
2175 draft guidance and NUREG-1573 stakeholder recommendations with
EnergySolutions ' ongoing and future license-supporting technical analysis led the
Director to establish a policy regarding Division application of NRC guidance to review
of licensee performance assessments, stating that the possible inadvertent and general
public exposure scenarios differing from those performance assessments approved in
2012 and before (including those attributable to ingestion of the Clive Facility
groundwater) are not appropriate for models other than with disposal of depleted
uranium.5
In conjunction with this policy, EnergySolutions has not observed any new industrial or
recreation activities near the Clive Facility, since the 2012 amendment was approved for
Radioactive Material License UT2300249 (authorizing construction of the Class A West
embankment).6 This license included consideration of safe management and disposal of
isotopes up to the Class A concentration limits (as defined by Utah Administrative Code
R313-15-1009), with the exception of Berkelium-247, Calcium-41, Chlorine-36, Iodine-
129, Rhenium-187, and Technitium-99 — which are highly mobile in groundwater).
EnergySolutions also notes that since the SONGS RPV classification is dominated by Ni-
63 with a half-life of 101 years, the Ni-63 activity decays to 45% of the Class A limit at
the time of possible intrusion.' Because of the embankment extends well above native
grade, previous models have considered viable groundwater well construction locations
adjacent to the embankment. The 2012 model projected that Ni-63 will not leach
downward below the embankment to the water table within 1,000 years. Therefore, no
ingestion or other exposure is projected following disposal of the SONGS RPV from
contaminated groundwater, regardless of the specific uptake scenario.
4 Vietti-Cook, Annette L. "Staff Requirements — SECY-16-0106 — Final Rule: Low-Level Radioactive
Waste Dsiposoal (10 CFR Part 61) (RIN 3150-A192)." Memorandum to Victor M. McCree, Executive
Director for Operations from the U.S. Nuclear Regulatory Commission, September 8, 2017. 5 Lundberg, Rusty, "Policy Regarding the Application of Existing Performance Assessment Rules (R313-
25-8 [sic], Technical Analyses, Utah Administrative Code) and U.S. Nuclear Regulatory Commission
(NRC) Direction (SRM-SECY-2013-075) and Applicable Federal Guidance for Performance
Assessments (NTJREG-1573)." Utah Division of Radiation Control. February 25, 2014.
6 Lundberg, Rusty. "License Amendment — Radioactive Material License UT2300249." Utah Department
of Environmental Quality: Division of Radiation Control. November 11, 2012. 7 WMG. "San Onofre Unit 1 Reactor Vessel Package Updated Classification Status" (Report 17-230-RE-
218). July 2017.
299 South Mani Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 3 of 8
Additionally, Utah Administrative Code R313-25-2 defines an Intruder Barrier to mean,
"a sufficient depth of cover over the waste that inhibits contact with waste and
helps to ensure that radiation exposures to an inadvertent intruder will meet the
performance objectives set forth in Rule R313-25, or engineered structures that
provide equivalent protection to the inadvertent intruder."
Similarly, NRC's BTP recommends
"The minimum solid volume or mass used to encapsulate waste should be
sufficient to make handling the radioactive waste by an inadvertent intruder
prohibitively difficult. The size or weight of the encapsulated waste should be
large enough to preclude movement without the assistance of mechanical
equipment. "8
Division-approved waste and cover construction specifications were selected to minimize
embankment instability from differential settlement, limit water infiltration and
biointrusion, minimize cover erosion and protect against inadvertent intrusion.9 The
SONGS RPV transport and disposal package includes additional inherent barriers against
inadvertent intrusion. The outer transportation package wall of the SONGS RPV consists
of three inches of carbon steel. The SONGS RPV itself is embedded in concrete within
the transportation package and the steel wall of the SONGS RPV ranges from 5 to 9.75
inches thick. Concrete grout has also been used within the SONGS RPV to secure the
internal components in place to prevent shifting during transit. Controlled Low-Strength
Material (CLSM) has been approved for use in disposing of reactor components to ensure
long-term stability of the disposal embankment. As with other reactor components
disposed in the embankment, the SONGS RPV will be encased in CLSM to provide
another barrier against inadvertent intrusion. Therefore, in order to excavate and be
exposed to contamination entrapped therein, an individual must intentionally intruder into
the SONGS RPV.
In addition to these design features, the remoteness of the Clive site provides an
additional barrier against inadvertent intrusion. Occupation of the site by inadvertent
intruders after site closure is highly unlikely due to a lack of natural resources in the area,
(particularly a lack of potable water). Contacting the waste after site closure is not likely
due to the lack of natural resources (no reason to drill or dig) and the design of the
8 NRC, 2015. pg 30.
9 EnergySolutions. "LLRW and 1le.(2) Construction Quality Assurance / Quality Control Manual."
(revision 28b). EnergySolutions, August 18, 2017.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
.-!------":.''
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 4 of 8
embankment cover system. Furthermore, its design features and waste disposal
operations minimize radiation dose to inadvertent intruders, including the lack of nearby
residential population, embankment cover system, CLSM Waste form (in the case of
containerized waste disposal), and granite markers. The Division concluded that
potential inadvertent intruders from waste disposal (including large components) are
protected as required by regulation by stating,
"Utah and NRC regulations require an intruder barrier for the disposal of only
Class C LLRW Since only Class A waste will be disposed of in the proposed
Disposal Embankment, no intruder barrier, as specifically defined by Utah
regulations, is required. In a more general sense, however, intruder protection is
required by the performance objective stated in URCR R313-25-20. These more
general requirements are satisfied by the remoteness of the facility from large
population centers, the cover system provided to separate the waste from the
atmosphere, the presence of an uppermost rock riprap layer on the top slope and
side slopes of the CAW Embankment cover, physical access barriers erected and
maintained at the closed facility, access controls maintained at the closed facility,
the naturally-poor quality of the area's groundwater, and monuments placed
denoting the locations of embankment boundaries."1°
Furthermore, since the Ni-63 does not present an external exposure source, the decayed
and diluted cuttings from excavation activities will result in minimal occupational
exposures (well below the BTP's recommended 500 mremlyear inadvertent intruder
limit) — see illustration in Figure 1.
SONGS RPV Shipping Container Height (ft) 38.5
SONGS RPV Shipping Container Diameter (ft) 15.6
Cylindrical SONGS RPV Volume (ft3) 7,343.0
CLSM Cap Placed over Disposed Large Containers (ft) 4.0
Possible Excavated Cubic Volume — container and cap (ft3) 11,749.2
Excavated Material Concentration Ratio — container/excavation (%) 62.5
Maximum Industrial Occupancy Factor at 2,000 hr/yr (%) 22.8
Ni-63 concentration at earliest time of Intrusion (% Class A) 44.8
10 URS Corporation. "Utah Division of Radiation Control — EnergySolutions LLRW Disposal Facility
Class A West Amendment Request — Safety Evaluation Report." (URS UT11.1101.004.01) URS Report
for the Utah Division of Radiation Control. June 2012.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 5 of 8
Figure 1 — Possible Inadvertent Intruder Excavation Evaluation
Therefore, ignoring the protection with the SONGS RPV size and other inherent intruder
barriers, an occupational individual would be externally exposed to Ni-63 activity (which
creates no external dose) at approximately 6.4% of any NRC Class A inadvertent
intruder-estimated limit (63.5% material ratio times 44.8% decayed classification of
Class A times 22.8% maximum occupational occupancy).
EnergySolutions appreciates the Division's evaluation of the proposed application of the
NRC Branch Technical Position on Concentration Averaging and Encapsulation for
disposal at the Clive Facility. Should there be any questions regarding this revised
Characterization Summary, please contact me at 801-649-2000.
Sincerely,
fait e Vem C. Rogers
cro Jun 18 2018 12:24 PM
Vern C. Rogers
Manager, Compliance and Permitting
cc: Don Verbica, DWMRC
enclosure
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 6 of 8
San Onofre Nuclear Generating Station's Unit 1
Reactor Pressure Vessel Concurrence Project Log
DATE
8/18/2017
MEDIA
Electronic
Mail
DESCRIPTION
Request from
EnergySolutions to confirm
generator-developed
classification.
ATTACHMENT(S)
Draft Shipment Manifest
WMG Report 07-064-RE-91 -
February 2008
WMG Report 07-064-RE-090 -
February 2008
WMG Report 17-230-RE-218 -
July 2017
9/20/2017 Electronic Request from
Mail EnergySolutions to confirm
generator-developed
classification.
Draft Shipment Manifest
WMG Report 07-064-RE-91 -
February 2008
WMG Report 07-064-RE-090 -
February 2008
WMG Report 17-23 O-RE-218 -
July 2017
10/13/2017 Electronic Request from
Mail EnergySolutions to confirm
generator-developed
classification.
Draft Shipment Manifest
WMG Report 07-064-RE-91 -
February 2008
WMG Report 07-064-RE-090 -
February 2008
WMG Report 17-23 O-RE-218 -
July 2017
10/23/2017 Phone Information requested by
Conference DWMRC regarding
grouting and vessel
preparation prior to
grouting
10/24/2017 Electronic Vessel internals Shipment WMG Figure 1-1
Mail Configuration reported to (Vessel/Internals Confirmation
DWMRC. for Shipment)
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 7 of 8
DATE MEDIA DESCRIPTION ATTACHMENT(S)
11/1/2017 Meeting DWIVIRC questions
regarding GTCC
Component removal
11/7/2017 Phone WMG / ES / DWMRC
Conference conference call
1/8/2018 Hardcopy DWMRC provided with WMG Letter 1/8/18
Submittal San Onofre Unit 1 BTP
Evaluation
WMG Report 20001-9088 -
October 2002
3/16/2018 Hardcopy DWIVIRC Request for 8 questions
Request Information received by
EnergySo lutions
4/17/2018 Hardcopy ES Responses to DWMRC CD18-0067
Submittal RFI / Request for
concurrence submitted
5/2/2018 Electronic Amended ES Response to SW-846 Chapter 1
Mail DWIVIRC Question 7 from
3/16/18 RFI
SW-846 Method 6010d
5/21/2018 Meeting WMG/DWMRC/ES WMG Slide Presentation
Classification Briefing
5/29/2018 Hardcopy H&H Legal Response to H&H Legal Memorandum
Submittal DWMRC Question 8
5/31/2018 Hardcopy ES / BTP Application CD18-0097
Submittal Overview submitted to
DWMRC
WMG Letter 5/31/18
GTCC Radiological Surveys
(12/2001)
6/12/2018 Hardcopy ES submits expanded CD18-0108
Submittal characterization details
WMG Letter 6/12/18
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0112
June 18, 2018
Page 8 of 8
DATE MEDIA DESCRIPTION ATTACHMENT(S)
6/13/2018 Legal DWMRC Legal
Determination Determination of SONGS
RPV disposal
Scott Anderson Letter (6/13/18)
Bret Randall Legal
Memorandum (6/11/18)
6/15/2018 Electronic ES/WMG submits to Extracted from WMG Report
Mail DWMRC Ni-63 activity in 20004-9088
GTCC Components
6/15/2018 Electronic DWMRC requests
Mail additional Inadvertent
Intruder Information
6/15/2018 Electronic Intruder Analysis Response Outline of Intruder Analysis
Mail Outline Response to DWMRC
6/18/2018 Hardcopy ES submits to DWMRC CD18-0112
Submittal SONGS RPV Project Log
and additional information
regarding possible
inadvertent intruder
exposure to the SONGS
RPV
SONGS RPV Project Log
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com