DRC-2018-006303 - 0901a0688085c522

ENERGYSOLUTIONS
Div of Waste Management
and Radiation Control

JUN 2 I 2018

June 27, 2018
DRC - 2DA.0-1c)90 6 3O 3
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; Request for Written
Concurrence and Summary of Information for Concurrence with
Characterization of the San Onofre Nuclear Generating Station's Unit
1 Reactor Pressure Vessel
Dear Mr. Anderson:
EnergySolutions herein summarizes information previously provided to the Division of
Waste Management and Radiation Control regarding the characterization and
classification of the San Onofre Nuclear Generating Station's Unit 1 Reactor Pressure
Vessel (SONGS RPV).1,2,3,4 EnergySolutions also requests written concurrence of this
characterization and classification. A log of all correspondence between EnergySolutions
and the Division on this subject has been previously provided.5 A detailed summary of
the information included in the correspondences is provided in the remainder of this
letter.
1 Rogers, Vern "Clive's SONGS RPV classification hand check" electronic mail to Kevin Carney, Utah
Division of Waste Management and Radiation Control, August 18, 2017. Electronically forwarded to
Boyd Imai, September 20, 2017. Electronically forwarded to Don Verbica, October 13, 2017. 2 Rogers, Vern "Radioactive Material License UT 2300249; Request for Written Concurrence and
Responses to the Request for Information Precursory to Concurrence with Characterization of the San
Onofre Nuclear Generating Station's (SONGS) Unit 1 Reactor Pressure Vessel" (CD18-0067). Letter
from EnergySolutions to Scott Anderson, Utah Division of Waste Management and Radiation Control,
April 17, 2018. 3 Rogers, Vern "Radioactive Material License UT 2300249; Expanded Request for Written Concurrence
with Characterization of the San Onofre Nuclear Generating Station's Unit 1 Reactor Pressure Vessel"
(CD18-0097). Letter from EnergySolutions to Scott Anderson, Utah Division of Waste Management
and Radiation Control, May 31, 2018.
4 Rogers, Vern "Radioactive Material License UT 2300249; Expanded WMG Characterization
Summary of the San Onofre Nuclear Generating Station's Unit 1 Reactor Pressure Vessel" (CD18-
0108). Letter from Energysolutions to Scott Anderson, Utah Division of Waste Management and
Radiation Control, June 12, 2018.
5 Rogers, Vern "Radioactive Material License UT 2300249; San Onofre Nuclear Generating Station's
Unit 1 Reactor Pressure Vessel Project and Concurrence Summary" (CD18-0112). Letter from
EnergySolutions to Scott Anderson, Utah Division of Waste Management and Radiation Control, June
18, 2018.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 2 of 29
The San Onofre Nuclear Generating Station, operated by Southern California Edison, is
approximately 60 miles south of Los Angeles, California. The site originally comprised
of three nuclear power plants. Unit 1 commenced operation on January 1, 1968, and
ceased operation on November 30, 1992. On November 3, 1994, Unit 1 was placed in
safe storage (SAFSTOR) until the remaining units could be successfully
decommissioned. On December 15, 1998, following a change in U.S. Nuclear Regulatory
Commission (NRC) decommissioning regulations, plans were undertaken to commence
decommissioning of the Unit 1 power plant in 2000. The spent fuel (i.e., High Level
Waste) from Unit 1 was transferred to an independent spent fuel storage installation.
Greater Than Class C components were removed from the SONGS RPV and are being
managed separately.6 The reactor vessel package was then filled with low density cellular
concrete grout for structural stability.7 The interior grout was added to prevent movement
of components during transport. An additional layer of grout was added between the
vessel wall and the package shell for structural stability and to absorb impact from
conditions normally incident to transport.8
After removal of the spent fuel, the SONGS RPV was characterized by WMG based on
NRC-accepted industry standard practices involving neutron activation analysis and dose
rate measurements of reactor components.9 Neutron activation analysis is a method by
which the concentrations of the 10 CFR 61 radionuclides are calculated and then
benchmarked (normalized) with measured data from physical radiation surveys. Neutron
activation analysis methods have been successfully employed for characterizing
numerous reactor vessel components irradiated near the active fuel region of the core.
Neutron activation analysis requires key input data for the performance of the activation
calculations, including material compositions, irradiation history and cooling time, and
geometry data to determine neutron flux magnitude and spectrum. Neutron activation
analysis produces radionuclide distribution ratios ("scaling factors") that are then used to
scale hard-to-detect radionuclide activity from Co-60 (an isotope whose gamma decay is
comparatively easy to detect) based on measured radiation dose rates. This activation
analysis and the resulting scaling factors are isotope specific, ensuring that the projected
6 WMG. "San Onofre Nuclear Generator Station Unit 1 — Reactor Vessel and Internals Characterization
(Report WMG-20004-9088, Rev. 6)." WMG Project 9088D Report to Southern California Edison.
October 2002. 7 Tuite, Kevin, "WMG Overview of the Characterization and Classification of the SONGS Unit 1
Reactor Pressure Vessel Package." WMG Memorandum to the Utah Division of Waste Management
and Radiation Control (submitted as attachment to CD18-0108), June 11, 2018. 8 Ibid. 9 WMG. 2002.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 3 of 29
nickel activity is predominantly created as Ni-63 and not other longer-lived nickel
isotopes.1°
Initial radiation surveys were performed internal to the reactor vessel to normalize the
activation analysis. This resulted in a conservatively high radionuclide activity estimate,
since the dose rate measurements were biased high due to cumulative dose rate effects
from other high activity components within the SONGS RPV. These initial
characterization results were documented in the WMG report "WMG-200004-9088, Rev.
6." The waste classification is controlled by the Ni-63 activity and was reported in this
document at 11,400 curies.
Subsequent to the initial surveys, additional detailed radiation surveys were obtained on
Greater Than Class C components which were removed from the SONGS RPV and
surveyed in an area with low background radiation (Core Barrel, Core Baffle and Core
Formers).11 These radiation survey results represent the best available empirical
information to benchmark or calibrate the neutron activation analysis results. The
components were modelled using point kernel shielding techniques. The calculated
radiation dose rates were found to be more than a factor of two higher than the actual
radiation levels measured from the removed components.
10 Tuite, Kevin, June 11, 2018. 11 Tuite, Kevin, June 11, 2018.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
„..._. --___..:,_•.---..---
EN ERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 4 of 29
Table 1
Greater Than Class C Component Analytical Data
Canister
ID No. Contents
Net
Weight
lbs.
Maximum
Dose Rate
R/hr @6"
Average
Dose Rate
R/hr @6"
Co-60 at
Measurement
(Ci)
L2 Core Barrel 2789 1600 697 1.75E+03
L3 Core Barrel 2719 1000 774 1.91E+03
L4 Core Barrel 2773 1600 879 2.20E+03
L5 Core Barrel 2012 500 358 7.19E+02
L6 Core Barrel 2708 1000 692 1.70E+03
L7 Core Barrel 2177 2200 799 1.70E+03
S2 Core Baffle 1948 6000 3850 7.30E+03
S3 Core Baffle 1902 7000 4158 7.77E+03
S4 Core Baffle 1566 4500 3458 5.74E+03
S5 Core Baffle 2296 6000 4483 9.48E+03
S6 Core Baffle 1850 6000 3850 7.07E+03
S7 Core Formers 1430 2400 1300 2.05E+03
Ll Core Formers 1497 3400 1542 2.64E+03
Total 5.20E+04
The activation analysis results were then re-normalized in an updated analysis performed
in 2008 which resulted in a reduction in activity by about a factor of two which was the
ratio of the modelled dose rate to the actual measured dose rate (1.1E+05 Ci/ 5.2E+04 Ci
= 2.12).1213 The Ni-63 activity in the segregated components was also estimated as:
12 WMG. "SONGS 1 Reactor Vessel Package Re-Characterization (Report 07-064-RE-090)." WMG
Project 07-046D Report to EnergySolutions. February 2008.
13 WMG. "San Onofre Unit 1 Reactor Vessel Package Part 61 Classification (Report 07-064-RE-091)."
WMG Project 07-046D Report to EnergySolutions . February 2008.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 5 of 29
Table 2
Greater Than Class C Component Analytical Data
GTCC
Component
Ni-63
Activity (Ci)
Report
Table
Baffle Plates 8.12E+03 3-5
Core Reformers 2.02E+04 3-4
Center Section of Core Support Barrel 3.97E+04 3-8
Instrumentation Thimbles 5.30E+02 3-11
6.86E+04
This yielded a refined Ni-63 activity of 5,140 curies as of the reference date in February
2008. In anticipation of a December 2018 ship date, WMG then prepared an updated
report in July 2017 takin into account decay time which further reduced the Ni-63
activity to 4,790 curies.
After the spent fuel and other highly radioactive vessel internals were removed, the
remaining Low-Level Radioactive Waste (LLRW) internals of the SONGS RPV were
gouted in place using low density cellular concrete to secure the internal components in
order to avoid shifting during transit. The NRC BTP allows the activity contained in the
SONGS RPV to be averaged over the entire large component, since the SONGS RPV is
the disposal package. The SONGS RPV has been encapsulated in additional concrete
and packaged within a three-inch thick steel-walled shipping package to comply with
U.S. Department of Transportation regulations.15
Responses originally provided to the Division's requests for further clarification with
analysis in the January 8, 2018 Package Characterization (submitted April 17, 2019 via
14 WMG. "San Onofre Unit 1 Reactor Vessel Package Updated Classification Status" (Report 17-230-
RE-218). July 2017. 15 U.S. Nuclear Regulatory Commission. "San Onofre — Unit 1" < https://www.nrc.gov/info-
finder/decommissioning/power-reactor/san-onofre-unit-1.html> accessed May 22, 2018, July 8, 2016.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 6 of 29
CD18-0067) have been supplemented by WMG. 16'17'18 A summary of the Division's
eight requests and associated responses follows:
Division Request #1: The text states (p.3) that the Ni-63 in the activated metal
is the classification controlling nuclide at 88% of the class a limit, which
appears correct. However, accounting for the uncertainty associated with the
normalization factor, if calculated as the square root of the sum of squares of
measured and calculated dose, respectively, would suggest a 63Ni specific
activity concentration of —30 uCi/cc, and therefore in excess of the Class A
limit (Part 61, Table 2). Please explain.
In response to a licensee violation cited by an agreement state associated with
measurement uncertainty, the U.S. Nuclear Regulatory Commission (NRC)
clearly stated it inappropriate to require measurement uncertainty be included in
demonstration of compliance with regulatory limits 19
"The [NRC] Offices became aware of a letter transmitting a notice of
violation that appeared to send an incorrect message to licensees. The
incorrect message was that licensees must consider inherent uncertainties
when measuring radiation levels approaching regulatory limits and must
establish procedural limits that are less than the regulatory limits by an
amount that equals (or exceeds) the 'instrument error.' That message is
incorrect."
"The NRC position is that the result of a valid measurement obtained by a
method that provides a reasonable demonstration of compliance or of
noncompliance should be accepted and that the uncertainty inherent in
that measured value need not be considered in determining compliance or
non-compliance with a regulatory limit. Thus, only the measured value
16 WMG "San Onofre Unit 1 Reactor Pressure Vessel Package Characterization." Memorandum to Scott
Anderson of the Utah Division of Waste Management and Radiation Control from WMG, January 8,
2018. 17 Anderson, Scott T. "Request for information regarding characterization of the San Onofre Nuclear
Generating Station's (SONGS) Unit 1 Reactor Pressure Vessel." Letter to Vern Rogers of
EnergySolutions from the Utah Division of Waste Management and Radiation Control, March 16,
2018.
18 Tuite, Kevin of WMG. Personal communication with Bret Rogers of EnergySolutions, April 9, 2018.
19 Hickley, J. W. N., et al. "Consideration of Measurement Uncertainty When Measuring Radiation
Levels Approaching Regulatory Limits." (HPPOS-223 PDF-9111220129) U.S. Nuclear Regulatory
Commission, (accessed April 3, 2018 from https://www.nrc.gov/about-nrc/radiation/protects-
you/hppos/hppos223.html). August 3, 1990.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 7 of 29
(and not the sum of the measured value and its uncertainty) need be less
than the value of the limit to demonstrate compliance with the limit.
Conversely, only the measured value (and not the measured value less its
uncertainty) need be greater than the value of the limit to demonstrate
non-compliance with the limit."2° [emphasis added]
In support of this directive, NRC further notes,
"The methods of demonstrating compliance with [regulatory] limits are
usually lefi to the regulated person. Any method which provides a
reasonable demonstration of compliance will be accepted. In most cases,
exact measured values are not required. "21 [emphasis added]
In offering a 2006 concurrence regarding EnergySolutions ' prior application of
the Branch Technical Position on Concentration Averaging and Encapsulation
(BTP) to classification of a similar reactor vessel destined for Clive Facility
disposal, the Division acknowledged,
"The generator has the responsibility for determining the component is
adequately characterized to support classification determination. "22
The Division's request acknowledges as correct the referenced text report of the
Ni-63 activity in the activated metal (projected at 88% of the Class A limit).
However, the Division's direction to further account for uncertainty in
demonstrating compliance with regulatory limits is contrary to its own practice,
and inappropriate and divergent from NRC policy and guidance.23
20 Ibid.
21 Ibid.
22 Finerfrock, Dane L. "EnergySolutions letter dated Octover 12, 2006, (CD06-0397) concurrence
regarding the U.S. Nuclear Regulatory Commission 'Branch Technical Position on Concentration
Averaging and Encapsulation' RML UT23900249." Letter to Tye Rogers of EnergySolutions from the
Utah Division of Radiation Control. November 6, 2006. 23 Ibid.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 8 of 29
Division Request #2: The text further states (p.5), that the reactor vessel was
characterized using several radiation surveys at multiple locations and that it
is accepted practice by the NRC to apparently disregard upper tail
uncertainties. It appears that if the upper tail uncertainty is used, 63Ni would
be in excess of the Class A limit. Please explain and provide a reference.
Please see the response provided to the Division's first request. The Division's
suggestion that "if the upper tail uncertainty is used, 63Ni would be in excess of
the Class A limit" is contrary to its own practice and inappropriate and contrary to
NRC policy.24
Division Request #3: The text presents (p.7) a flow chart, depicting the NRC
Branch Technical Position guidance overview as how to average single,
discrete items. While the Division agrees that Section 3.3.1 of the NRC BTP is
relevant for the concentration averaging characterization of the reactor, no
mention is made, apart from three statements, of potential constraints as
outlined in Section 3.3.4 of the BTP (see Figure 5 of the BTP, classification of
encapsulated items, which should be followed.) If the intent is, however, to
follow Section 3.8.4 of the BTP, the relevant information should be
duplicated for the San Onofre reactor in an analog fashion.
Encapsulation of LLRW is addressed in the NRC BTP and allows for averaging
the activity over the volume of the encapsulation media to determine the waste
class (in accordance with Utah Administrative Code [UAC] R313-15-1009). The
following information provides the detail regarding the determination of the
SONGS RPV as a Class A LLRW disposal package. NRC's BTP
... provides acceptable methods that can be used by waste generators,
processors, disposal facility operators, Agreement State regulators, and
others to perform concentration averaging of specific wastes and mixtures
of waste for the purpose of determining their waste class [in accordance
with Utah Administrative Code R313-15-1009] for disposal. "25
Because the SONGS RPV has been encapsulated with grout and the activity
averaged over the encapsulation media, the NRC BTP is utilized to determine its
24 Ibid. 25 U.S. Nuclear Regulatory Commission; 2015, pg 7.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 9 of 29
appropriate disposal waste classification. As is identified in BTP Section 1.4,
classification guidance is provided for "two broad categories of waste: blendable
waste and discrete items,"26 where constraints are recommended for discrete
items, based on their "size and the amount of concentration of radioactivity they
contain.”27 NRC's BTP directs classification of encapsulated discrete items (such
as the SONGS RPV) follow guidance illustrated in BTP Figure 5 (reproduced
below) and Section 3.3.4, Encapsulation of Discrete Items.
1. In the flowsheet depicted in Figure 5, a determination must be made as to
whether disposal classification is controlled primarily by gamma-emitting
radionuclide decay. In the case of the SONGS RPV, the WMG analyses
illustrates the waste classification is principally driven by Ni-63, a non-
gamma emitter.28
2. For encapsulated discrete items whose waste classification is not dominated
by a gamma-emitting source term, Figure 5 then suggests comparison of the
encapsulated discrete item's primary gamma emitter concentrations to Table 2
values from 10 CFR 61.55 (equivalent to Table II of UAC R313-15-1009) or a
multiple of ten times the waste disposal class limit. For the case of the
SONGS RPV, the gamma-emitter concentrations are well below ten times the
waste disposal Class A limits 29
Figure 5 then suggests a determination be made as to if the discrete item's waste
loading exceeds 14%. In the case of the SONGS RPV, WMG's analyses projects
a waste loading of 23% (1,330 ft3 of metal and 5,840 ft3 of total volume with
encapsulation media).
3. For encapsulated discrete items with a mass loading exceeding 14%, Figure 5
recommends consideration of the final disposal volume. Since the disposal
volume of 155.2 m3 exceeds the decision criterion of 9.4 m3, Figure 5 suggests
pursuit of the alternative approach outlined in BTP Section 3.8 for
classification of the SONGS RPV. In evaluation of the waste disposal volume
and weight, the BTP recommends,
26 Ibid.
27 NRC; 2015. pg 11. 28 WIVIG. July 2017. 29 Ibid.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
Classify based on oncapsulatian volume
Figure 1
No Primary gamma emitters Yes in each item..g Table 2 values Or < 7X class limit?
emery gammas emitters control classification?
Primary gamma einitteis in each items < Table 2 values or -c 10X class limit?
Yes
Yes
Each item c Table 3
or Factor of '10 constraint met for each item?
Yes
s waste 10ad1ng5 14%?
No
Classify based on the lessor of 0.2 m3 or encapsulation volume
No
Use Alternative Approach (Section 3.8)
ZN`N. Is final waste volume 5 9.4 m3?
Yes
Yes hic
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 10 of 29
BTP Figure 5. Classification of Encapsulated Items.3°
30 NRC, 2015. pg. 32.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUT1ONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 11 of 29
"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. "31
Since the SONGS RPV weighs 471 tons and the total waste package volume is
greater than 155 m3, it qualifies as "large enough to preclude movement without
the assistance of mechanical equipment."
BTP Section 3.8 describes an alternative approach for waste-specific disposal
classification that ensures appropriate inadvertent intruder protection. In
providing this alternative guidance, NRC encourages "detailed discussions
between staff of the regulatory agency and licensee" to ensure that waste is
classified appropriately before shipment and disposa1.32 Discussions with
Division staff conducted since 2017 as are herein summarized have been
undertaken in accordance with this NRC BTP guidance.
Site-Specific Intruder Assessments (BTP Section 3.8.1):33
In order to appropriately apply concentration averaging, BTP Section 3.8.1
suggests that alternative disposal classification approaches should include, as
applicable:
• An overview of the proposed alternative approach and how it will protect
an inadvertent intruder.
In 2000, NRC published stakeholder recommendations for appropriate
performance assessment methodologies to support rules promulgated in 1981
as 10 CFR 61.34 As part of its efforts to revise regulations contained in 10
31 NRC, 2015. pg 30.
32 NRC, 2015. pg 36. 33 U.S. Nuclear Regulatory Commission. "Concentration Averaging and Encapsulation Branch Technical
Position, Revision 1 — Volume 2" Office of Nuclear Material Safety and Safeguards, U.S. Nuclear
Regulatory Commission, February 2015. (p. 36) 34 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.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 12 of 29
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)."35 Over concerns
with differences with the proposed rules with direction received from
Commissioners, NRC later retracted this document and directed staff to
further revise their proposed changes to 10 CFR 61.36 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.37
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).38 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
35 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. 36 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.
37 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 (NUREG-1573)." Utah Division of Radiation Control. February 25, 2014. 38 Lundberg, Rusty. "License Amendment — Radioactive Material License UT2300249." Utah
Department of Environmental Quality: Division of Radiation Control. November 11, 2012.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
„,,...---=-•
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 13 of 29
45% of the Class A limit at the earliest time of possible intrusion.39 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.
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 so id volume or mass used to encapsulate waste should
be sufficient to m ke handling the radioactive waste by an inadvertent
intruder prohibitively dOcult. The size or weight of the encapsulated
waste should be large enough to preclude movement without the
assistance of mechanical equipment."4°
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.41 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
39 WMG. "San Onofre Unit 1 Reactor Vessel Package Updated Classification Status" (Report 17-230-
RE-218). July 2017. 40 NRC, 2015. pg 30.
41 EnergySolutions. "LLRW and 11e.(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
CD18-0119
June 27, 2018
Page 14 of 29
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 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-
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] . Fax: [phone] • www.energysolutions.com
EN ERGYSOLUTIONS
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Page 15 of 29
poor quality of the area's groundwater, and monuments placed
denoting the locations of embankment boundaries."42
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 mrem/year
inadvertent intruder limit) — see illustration in Table 3 and Figure 1.
Table 3
Inadvertent Intruder Excavation Souceterm
Description Value
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
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).
On November 11, 2012, EnergySolutions was awarded amendment 14 of
Radioactive Material License UT2300249 which combined legacy waste
disposal embankments into a single Class A West (CAW) facility.43 In a
manner similar to that approved for the legacy Class A and Class A North
embankments, EnergySolutions proposed continued placement of large
components on the lowest level within the new CAW embankment.
42 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. 43 Lundberg, Rusty. "License Amendment — Radioactive Material License UT2300249." Utah
Department of Environmental Quality: Division of Radiation Control. November 11, 2012.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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Figure 1 —Inadvertent Intruder Excavation Souceterm
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
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"Waste placement will generally progress from the southern boundary
of the existing Class A footprint to the north, with large component
and Containerized Waste Facility disposal areas developed separately
prior to being enveloped by bulk waste placement. This is consistent
with current approved practices. "44
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.45 The SONGS RPV transport and disposal package
includes 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.
While these have been deemed appropriate and sufficient protection against
inadvertent intrusion as the basis for granting Radioactive Material License
UT2300249 for Class A waste disposal in CAW, the embankment design was
augmented and determined as sufficient to also protect inadvertent intrusion
from disposal of wastes up to Class C limits.46 Therefore, if closed according
to approved design, CAW will provide enhanced inadvertent intrusion
protection for wastes disposed up to the Class C limit (which requires disposal
a minimum of 5 meters below the cover surface to qualify as an intruder
barrier).
44 EnergySolutions. "Class A West License Amendment Application." EnergySolutions, February 23,
2012. pg. 14. 45 EnergySolutions. "LLRW and lle.(2) Construction Quality Assurance / Quality Control Manual."
(revision 28b). EnergySolutions, August 18, 2017. 46 Sinclair, W.J. "Final Executive Secretary Decision, Envirocare containerized Class A, B, C low-level
radioactive waste application of November 1, 1999." Letter from the Utah Division of Radiation
Control to Charles Judd, Envirocare, July 9, 2001.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
..---,...."-:-----
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Even though UAC R313-25-2 allows intrusion barriers be provided by either
(1) depth of disposal or (2) other engineered structures, the CAW
embankment has been designed to provide both types of inadvertent intrusion
barriers. Additionally, $2,104,759.80 has been secured by surety bond
(pledged in accordance with License Condition 73) to fund complete
entombment of large components (as an engineered structural barrier against
inadvertent intrusion) in the event that EnergySolutions is not capable to
complete authorized CAW closure to its full design capacity.47 These aspects
of the disposal methodology combine to provide a level of intruder protection
that far exceeds those required for Class A LLRW.
In addition to site and design-specific protections against inadvertent
intrusion, EnergySolutions also demonstrated that Class A waste disposal in
the CAW (when average disposal concentrations are limited to those
promulgated in Table 55A of Radioactive Material License UT2300249)
satisfies Utah Groundwater Protection Limits (in the event that contaminants
are leached from the waste into groundwater and then are transported to a
well).48 The groundwater at Clive is classified as Class IV, saline ground
water according to UAC R317-6-3 Ground Water Classes, with total dissolved
solids (TDS) concentrations ranging from 30,000 mg/L to 100,000 mg/L. Due
to extreme total dissolved solid levels, the groundwater beneath the CAW
embankment has been assigned a Class IV classification. UAC R317-6-4.7
states,
"Protection levels for Class IV ground water will be established to protect
human health and the environment."
Because of the naturally poor quality and high salinity, the Director and U.S.
Department of Energy determined that the underlying groundwater in the
vicinity of the Clive site is not suitable for most human uses or potable for
humans.49'50 Even so, the Director established "protection levels for Class IV
ground water ... to protect human health and the environment" by requiring
47 Section 31 of the LLRW Surety funds sufficient CLSM for full large component entombment via line
1180 with a total direct cost of $2,104,759.80 (excluding indirect multipliers). 48 Whetstone Associates, Inc. "EnergySolutions Class A West Disposal Cell Infiltration and Transport
Modeling Report." (4104K.120223) Whetstone Associates, Gunnison Colorado, February 23, 2012. 49 Lundberg, Rusty. "License Amendment — Radioactive Material License UT2300249." Utah
Department of Environmental Quality: Division of Radiation Control. November 11, 2012. 50 U.S. Department of Energy. "UMTRCA Title 1: Salt Lake City, Utah, Processing and Disposal Sites."
Office of Legacy Management, U.S. Department of Energy, Grand Junction. November 2017.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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radioactive waste disposal facilities to demonstrate non-degradation of the
groundwater for 500 years for radiological contaminants.51 As a groundwater
quality standard, non-degradation is required to be demonstrated using
groundwater protection levels based on a potential groundwater ingestion dose
of 4 mrem/year.52 For performance assessment purposes, official Division
policy is to consider site-specific data regarding groundwater quality, uses,
and reasonable receptor pathways as an appropriate approach in a manner
consistent with prior performance assessment approvals for the facility.53
Therefore, since the CAW License approval is based on Class IV groundwater
beneath Class A LLRW disposal, hypothetical ingestion of groundwater
contaminated by up to 35 Ci/m3 of Class A LLRW disposed in the CAW
embankment will not exceed an ingestion dose of 4 mrem/year (where the
SONGS RPV average Ni-63 concentration at time of disposal is 30 Ci/m3). In
fact, the infiltration modeling that served as the basis for the CAW
embankment license projects that no Ni-63 contamination will be transported
downward below the embankment to the water table within 10,000 years
(contaminant being carried downward due to precipitation infiltration will also
undergo 100 repeated half-lives of decay over this duration). Therefore, the
Ni-63 groundwater quality protection limits will not be exceeded well beyond
the 500 year protection limit nor present any appreciable risk to human health
associated with exposure or uptake of groundwater from an adjacent well,
regardless of well construction location.
Therefore, the SONGS RPV with a current Ni-63 concentration at 88% of the
Class A limit (decaying to only 45% of the Class A limit after the required
and surety-funded 100-year institutional control period) is significantly lower
than the Ni-63 concentration limit modeled as the basis for the CAW License
amendment and will not compromise the other design and site-specific
inadvertent intrusion barriers. 54
51 Ibid. 52 Division of Water Quality — Utah Water Quality Board. "Groundwater Quality Discharge Permit DRC-
2014-005989." Division of Water Quality, Department of Environmental Quality, State of Utah.
October 9, 2014. 53 Lundberg, Rusty. "Policy Regarding the Application of Existing Performance Assessment Rules
(R313-25-8, Technical Analyses, Utah Administrative Code) and U.S. Nuclear Regulatory
Commission (NRC) Direction (SRM-SECY-2016-075) and Applicable Federal Guidance for
Performance Assessments (NUREG-1573). February 25, 2014. 54 The Division concluded that potential contaminant transport via groundwater to well from waste
disposal (including large components) does not exceed regulation, in URS Corporate. "Utah Division
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
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CD18-0119
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• A detailed description of the waste form(s) covered by the alternative
averaging approach.
SONGS 1 was a first generation Westinghouse 3-loop pressurized water
reactor, originally rated at 450 MWe. The unit operated from January 1968 to
November 1992 when it was permanently retired from service. Containment
consisted of a 2.5 cm thick steel sphere. In 1976, a one meter thick steel-
reinforced concrete sphere enclosure building was constructed around the
sphere for post-accident radiation shielding. Fuel was removed and the
reactor placed in Safe Store (SAFSTOR) in 1993.
CLSM has been approved for use in disposing of reactor components to
ensure long-term stability of the disposal embankment. The SONGS RPV will
be encased in CLSM as with other reactor components in the embankment
which provides another barrier for intrusion. In addition to the CLSM
entombment, the outer transportation package wall of the SONGS RPV
consists of three inches of carbon steel. The SONGS RPV itself is encased 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. Figure 1 illustrates the package configuration for the
SONGS RPV.
BTP Section 3.8.2 suggests that alternative analysis for encapsulated items
should provide "reasonable assurance that the applicable carry-away
scenario is not credible for a specific disposal configuration (site and waste
form)."55 With a mass of 471 tons and gross volume of 155.2 m3, appropriate
assurance is demonstrated that the SONGS RPV disposal is sufficiently robust
so that cannot be easily opened in the field. While this alone satisfies BTP
Section 3.8.2, disposal of the SONGS RPV will be at a sufficient depth to
render as not credible the carry-away scenario (via entombment if prematurely
closed or entombment and 40 feet of waste between cover and the SONGS
RPV if closed at full capacity).
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.
55 NRC, 2015. pg. 38.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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CD18-0119
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A detailed description of the SONGS RPV, including physical and
radiological characteristics and a description of any source-containing
devices, encapsulating media, and any additional packaging proposed for
disposal has previously been provided (required by BTP Section 3.8.2).565758
Similarly, please refer to responses provided for BTP Sections 3.8.1 and 3.8.2
for descriptions of how the alternative approach differs from the CA BTP's
position on encapsulation in Section 3.3.4 — volume exceeding that proposed
in the BTP; an overview of the proposed alternative provision (e.g., depth of
burial), and how the alternative provision protects the intruder; a description
of site characteristics pertinent to the proposal; an analysis of the effects of
degradation of packaging and engineered barriers over the period that the item
remains hazardous to an intruder, as applicable; and an identification of the
proposed limits for items to be disposed, based on the alternative inadvertent
intruder analysis.
• An identification of the BTP's existing position for which an alternative is
required.
Encapsulation is authorized by NRC in the BTP, requiring an alternative
approach due to the volume of the component (exceeds 9.4 m3). BTP Section
3.8.2 states,
"The position on encapsulation in Section 3.3.4 is considered generally
suitable for all LLW disposal facilities licensed under 10 CFR Part 61 or
the equivalent Agreement State regulation. Other provisions may be used
on a specific basis for the encapsulation of items if—after an evaluation of
the specific characteristics of the waste form, the disposal site, intrusion
scenarios, and the method of disposal—there is reasonable assurance of
compliance with the inadvertent intruder performance objective in 10
CFR 61.42. "59
56 WMG, 2002. 57 WMG, 2008.
58 W1VIG. 2017. 59 NRC, 2015. pg 30.
299 South Main Street, Suite 1700 • Salt lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
EN ERGYSOLUTIONS
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CD18-0119
June 27, 2018
Page 22 of 29
• A description of site characteristics pertinent to the proposal.
The Clive site is on the eastern edge of the Great Salt Lake Desert, three miles
west of the Cedar Mountains, 2.5 miles south of Interstate 80, and 1 mile
south of a switch point called Clive on the Union Pacific rail system. The
disposal site is a parcel of land, consisting of one square mile in Tooele
County, Utah. The land was owned by the State of Utah, and, with the
exception of approximately 100 acres used in the Vitro Remedial Action
project, has been purchased by EnergySolutions. The U.S. Department of
Energy owns the 100 acres used in the Vitro Remedial Action project. The
licensed property owned by EnergySolutions, is Utah Section 32, Township 1
South, Range 11 West, Tooele County, Utah.
Most of the land within a 10-mile radius of the site is predominantly within
the public domain, as administered by the U.S. Bureau of Land Management
(BLM). Non-federally owned lands around the Clive facility have been
designated as a Hazardous Industrial District MG-H by Tooele County.6° This
designation limits, through zoning, the future uses of land in the area of the
disposal facility to heavy industrial processes (General Industrial District M-G
type uses) and to industries dealing with hazardous wastes, by the issuance of
conditional use permits. Because the Hazardous Industrial District MG-H
designation does not authorize any other types of land-use, it also reduces the
potential for population encroachment near EnergySolutions' Clive facility.
The remoteness of the site from the urbanized areas of Tooele County makes
the surrounding area an improbable location for any other significant
industrial use which might be impacted by the disposal project. BLM has
seasonal sheep and cattle grazing allotments near Clive. Additionally, the low
precipitation and high evaporation rates are not conducive to any sustainable
crop yields.
The groundwater at Clive is classified as Class IV, saline ground water
according to UAC R317-6-3 Ground Water Classes, with total dissolved
solids (TDS) concentrations ranging from 30,000 mg/L to 100,000 mg/L.
Because of the naturally poor quality and high salinity, the underlying
60 Tooele County, Utah. County Ordinance Chapter 18-1.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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Page 23 of 29
groundwater in the vicinity of the Clive site is not suitable for most human
uses or potable for humans.61
The Clive site affords several principal features that provide long-term
isolation of the disposed waste, minimize the need for continuing active
maintenance after site closure, and improve the site's natural characteristics in
order to protect public health and safety. These features satisfy the following
functional requirements:
1) Minimizes infiltration of water into the embankment;
2) Ensures the integrity of the embankment cover;
3) Provides the structural stability of backfill, wastes, and cover;
4) Minimizes contact of waste with standing water;
5) Provides adequate site drainage during operations and after
Embankment closure;
6) Facilitates site closure and stabilization;
7) Minimizes the need for long-term maintenance;
8) Provides a barrier against inadvertent intrusion;
9) Maintains occupational exposures as low as reasonably achievable;
10) Provides adequate monitoring of the disposal site; and
11) Provides an adequate buffer zone for monitoring and potential
mitigative action.
• An analysis of the effects of degradation of packaging and engineered
barriers over the period that the waste remains hazardous to an intruder.
Ni-63 is the classification controlling radionuclide measured at 88% of the
Class A limit at time of disposal. Since Ni-63 decays by beta emission, it does
not represent a significant external exposure hazard (the low energy betas
emitted cannot penetrate the outer dead layer of skin). Having a half-life of
100 years, the activity of the Ni-63 would be less than 45% of the Class A
limit at the first time inadvertent intrusion into the waste is feasible.
Additionally, while it is recognized that the grout and CLSM will degrade at
some future time, the site remoteness, poor groundwater quality, permanent
fencing, markers and layers of carbon and stainless steel will continue to
provide adequate barriers to inadvertent intrusion.
Lundberg, Rusty. "License Amendment — Radioactive Material License UT2300249." Utah
Department of Environmental Quality: Division of Radiation Control. November 11, 2012.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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Encapsulation of Discrete Items, Including Sealed Sources (BTP Section 3.8.2):
BTP Section 3.8.2 suggests that alternative analysis for encapsulated items should
provide "reasonable assurance that the applicable carry-away scenario is not
credible for a specific disposal configuration (site and waste form)."62 With a
mass of 471 tons and gross volume of 155.2 m3, appropriate assurance is
demonstrated that the SONGS RPV disposal is sufficiently robust so that cannot
be easily opened in the field. While this alone satisfies BTP Section 3.8.2,
disposal of the SONGS RPV will be at a sufficient depth to render as not credible
the carry-away scenario (via entombment if prematurely closed or entombment
and 40 feet of waste between cover and the SONGS RPV if closed at full
capacity).
A detailed description of the SONGS RPV, including physical and radiological
characteristics and a description of any source-containing devices, encapsulating
media, and any additional packaging proposed for disposal has previously been
provided (required by BTP Section 3.8.2).63,64,65 Similarly, please refer to
responses provided for BTP Sections 3.8.1 and 3.8.2 for descriptions of how the
alternative approach differs from the CA BTP's position on encapsulation in
Section 3.3.4 — volume exceeding that proposed in the BTP; an overview of the
proposed alternative provision (e.g., depth of burial), and how the alternative
provision protects the intruder; a description of site characteristics pertinent to the
proposal; an analysis of the effects of degadation of packaging and engineered
barriers over the period that the item remains hazardous to an intruder, as
applicable; and an identification of the proposed limits for items to be disposed,
based on the alternative inadvertent intruder analysis.
Likelihood of Intrusion (BTP Section 3.8.3):
In Section 3.8.3 of the BTP, NRC clarifies when considering likelihood of
intrusion,
,,... [t]he staff continues to believe that these waste types might pose a unique
hazard and that averaging constraints are appropriate. In developing
averaging constraints for discrete items, the staff has used stylized carry-away
scenarios."
62 NRC, 2015. pg. 38. 63 WMG, 2002.
64 WMG, 2008. 65 WMG. 2017.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
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Clearly, the grout already present within the SONGS RPV, its 8-inch thick outer
steel shell, the minimum 4-feet of CLSM large component entombment, and then
40 feet of other waste and rock armor above the entombed large components
reasonably minimize any inadvertent intruder "carry-away scenario" risk (as has
already been demonstrated an Division approved with Energysolutions' historic
reactor pressure vessel and other large component placement).
Even though the barriers inherent with the waste form, site and method of
disposal make inadvertent intrusion is highly unlikely, permit-based modeling and
associated groundwater quality measurements demonstrate that if intrusion does
occur, intrusion-related doses will not exceed the drinking water regulatory limit
of 4 mrem/year or the much lower limits promulgated in UAC R313-25-20 for
protection of the general public.
Therefore, the SONGS RPV has been adequately characterized and classified as a
Class A LLRW package using industry accepted methods that have also been
used on many other reactor vessels shipped for disposal as LLRW. The NRC
BTP allows generators to average the activity over the encapsulation media for
waste classification purposes. EnergySolutions has engaged the Division in this
specific case due to the size of the encapsulated component and to ensure
concurrence at this stage of the project is provided due to the significant planning
effort and expense of preparing for the shipment of the SONGS RPV to the Clive
disposal facility. Several layers of mitigating factors ensure the safe and
compliant disposal of the SONGS RPV. These mitigating factors include the
depth of burial, CLSM entombment, size and thickness of package and
component, low probability of intrusion, disposal embankment design, decay of
Ni-63 to less than 50 percent of the Class A limit, low dose consequence of Ni-63
as a low energy beta emitter, etc. and minimize risk of exposure to a potential
inadvertent intruder. As such, the guidance of the BTP ensures adequate measures
are in place to prevent unacceptable exposures to a potential inadvertent intruder.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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Mr. Scott T. Anderson
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Division Request #4: The October 2002 Reactor Vessel and Internals
Characterization Report WMG-20004-9088, Rev. 6 states that the RPV head
and piping have been removed. The WMG-20004-9088 Report (Section 3.5.1)
states that the RPV is low-allow carbon steel with a nominal wall thickness of
9.75 inches in the cylindrical region and 5.0 inches in the bottom head region.
The Division assumes that the piping and head flange openings have been
sealed. No mention of the cover material is made. Please provide a
description of the materials used to secure these flanges, the material
thickness and the method used to secure them. Also, the Division would like
to see how these were accounted for in the evaluation for an inadvertent
intruder scenario.
The RPV primary coolant nozzles were cut flush with the exterior of the RPV
wall and 4 inch A-36 steel cover plates were welded in place. It should be noted
that the nozzle cover plates are contained within the canister lower assembly
shell. The 3 inch thick ASTM A572 Gr42 steel upper canister closure plate was
attached to the RPV flange using six rigging studs. Belzona 2131 polymeric
elastomer sealing material was used to seal all penetrations through the canister
plate assembly as required. The upper canister closure plate was then welded to
the canister lower assembly using a full penetration weld.66
Refer to the response to question #3 for a discussion on the inadvertent intruder
scenario.
Division Request #5: The October 2002 Reactor Vessel and Internals
Characterization Report WMG-20004-9088, Rev. 6, Table 5-1, shows a
volume of 1,333 ft3 and a weight of 658,695 lbs. The January 2018 Reactor
Pressure Vessel Package Characterization Table 1, shows a volume of 5.48e3
ft3 and a weight of 9.43e5 lbs. This is a difference of 4,147 ft3 and 284,305 lbs.
Please account for these disparities.
The results from WMG-20004-9088 Rev. 6 did not include the weight of the
cementitious grout in the package. The additional weight and volume account for
the grout which is consistent with the regulatory guidance for encapsulation.67
66 Tuite, 2018.
67 Tuite, 2018.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
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Division Request #6: The October 2002 Reactor Vessel and Internals
Characterization Report WMG-20004-9088, Rev. 6, Table 5-1, shows a
package activity of 1.14e4 curies for 63Ni. The January 2018 Reactor Pressure
Vessel Package Characterization Table 1 and the table shown in Updated
Classification Status Report, 17-230-RD-218, July 2017 shows a package
activity of 4.79e3 curies for 63Ni. It is noted in the Updated Classification
Status Report, 17-230-RE-218, July 2017, that the characterization results
were "decay corrected to the earliest anticipated shipping date of December
1, 2018." However, 63Ni activity would have decayed to 1.0186e4 curies in the
period between October 2002 and December, 2018. Please account for this
discrepancy.
The RPV characterization results reported in WMG-20004-9088 were based on
the original neutron transport and activation analysis. Initial dose rate
measurements were conservatively taken inside the RPV and were used to
normalize the activation analysis. This resulted in a high activity estimate, since
the dose rate measurements were biased high with shine from other components
within the RPV.
In Decernber of 2001, detailed radiation surveys were obtained on components
which were removed from the reactor vessel and surveyed in an area with low
background radiation. These radiation survey results represent the best available
empirical information to benchmark or calibrate the activation analysis results.
The components were modelled using point kernel shielding techniques and the
calculated radiation dose rates were more than a factor of 2 higher than the actual
radiation levels on the components. Therefore, the activation analysis results
were normalized in a revised analysis performed in February of 2008 thereby
reducing the activity by a factor of 2.121 which was the ratio of the modelled dose
rate to the actual measured dose rate. This yielded a calculated Ni-63 activity of
4.79E+03 as of the reference date.68
68 Tuite, 2018.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.com
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Division Request #7: The January 8, 2018 San Onofre Unit 1 Reactor
Pressure Vessel Package Characterization report states, "... a waste is not
considered a RCRA characteristic waste if the TCLP lead result is 4.5 mg/L.
TCLP with an uncertainty value of 1.0 mg/L." Please provide a reference for
this statement. Based on the uncertainty of 1.0 mg/L in your example, it
would be considered a characteristic waste in Utah.
Comparing two unrelated analyses is imprecise. Chemical analyses do not have
"uncertainty" to them in the same way that radiological analyses do, so the
situation described is not accurate. EPA approved analytical methods for
chemical analyses are quantified under the SW-846 compendium.69 These
methods require a certain amount of Quality Assurance and Control (QA/QC) to
ensure the system is operating correctly and the resulting analysis can be
confirmed reliable. The QA/QC system is described in SW-846 Chapter 1.
Specific QA/QC methodology and acceptability for TCLP metals analysis (as was
used in the RPV characterization report example) is detailed in SW-846 6010d.
In general, the EPA QA/QC methodology includes lab control standards (LCS),
method blanks (MB), and matrix spikes (MS/MSD) to ensure the system is
operating within normal parameters. The samples used to perform these quality
methods is any single sample from the instrument run. Therefore, many times it
is not directly associated with the sample in question unless they happen to use
that sample to perform the QA analyses. The results of these QA/QC analyses
show whether the system is biased high or low for that run, but if they are within
the acceptable tolerance (+/-20% recovery for LCS; +/-25% recovery for
MS/MSD; see sections 9.7.2 and 9.7.3 in SW-846 Method 6010d), then the
system is performing correctly and the results are good as found and no
adjustment is done to them. If these are out of tolerance, then the samples are re-
run or are qualified that there is some matrix interference or something.
69 EPA, "SW-846 Update V" U.S. Environmental Protection Agency, July 2014.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
Mr. Scott T. Anderson
CD18-0119
June 27, 2018
Page 29 of 29
Division Request #8: Utah Code 19-3-102(8)(a) states: "high-level nuclear
waste" means spent reactor fuel assemblies, dismantled nuclear reactor
components, and solid and liquid wastes from fuel reprocessing and defense-
related wastes." Please clarify how the SONGS Unit 1 RPV does not fit the
description of "dismantled nuclear reactor components."
In response to a legal analysis submitted by EnergySolutions," the Director
concluded that "the SONGS reactor pressure vessel may be disposed at
EnergySolutions' Clive facility without violating the Utah Code, provided it meets
the definition of Class A low level radioactive waste. "71
EnergySolutions appreciates the Division's willingness to continue its long-standing
practice of providing concurrence regarding application of the BTP to the classification
of large reactor components. EnergySolutions herein requests the Division's written
concurrence with said application of the NRC Branch Technical Position on
Concentration Averaging and Encapsulation and that the SONGS RPV can be disposed at
Clive as Class A low-level radioactive waste (subject to the accuracy of the generator's
final characterization and classification — as directed by the NRC).72 Should there be any
questions regarding this summary or Request, please contact me at 801-649-2000.
Sincerely,
Vern C. Rogers
Jun 27 2018 11:13 AM
O‘an
Vern C. Rogers
Manager, Compliance and Permitting
cc: Don Verbica, DWMRC
Otis Willoughby, DWMRC
70 Smith, Amanda. "EnergySolutions Additional Information and Analysis Regarding Request for
Written Concurrence and Responses to the Request for Information Precursory to Concurrence with
Characterization of the San Onofre Nuclear Generating Station Unit 1 Reactor Pressure Vessel." Letter
from Holland and Hart to Scott Anderson, Utah Division of Waste Management and Radiation
Control. May 29, 2018. 71 Anderson, Scott. "Disposal of Reactor Pressure Vessel from the San Onofre Nuclear Generating
Stations (SONGS)." Letter from Utah Division of Waste Management and Radiation Control to Vern
Rogers of EnergySolutions, June 13, 2018. 72 Hickley, 1990.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com