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{{#Wiki_filter:TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses | {{#Wiki_filter:TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 1 of 11 RAI-1 Gaseous Effluent Concentrations in Unrestricted Areas: | ||
RAI-1 | |||
Regulatory Basis: | Regulatory Basis: | ||
Title 10 of the Code of Federal Regulations | Title 10 of the Code of Federal Regulations (10 CFR) section 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301. The dose limits in § 20.1301 apply to the total effective dose equivalent from the licensed operation. | ||
Describe Issue: | Describe Issue: | ||
The applicant has proposed to monitor routine gaseous effluents at elevated release points and control concentrations at the points of discharge consistent with the dose limits in § 20.1301. Section 4.12.2.2.2.2 of the ER states To ensure regulatory requirements of 10 CFR Part 20.1101, 10 CFR Part 20.1302, 10 CFR Part 70.59 (CFR, 2021b), and 40 CFR Part 190 (CFR, 2021c) are met, gaseous effluent release points (stacks) are monitored. This approach assumes routine releases consist only of stack discharges. The statements in section 4.12.2.2.1 of the ER stipulate airborne activity concentration limits are | The applicant has proposed to monitor routine gaseous effluents at elevated release points and control concentrations at the points of discharge consistent with the dose limits in § 20.1301. Section 4.12.2.2.2.2 of the ER states To ensure regulatory requirements of 10 CFR Part 20.1101, 10 CFR Part 20.1302, 10 CFR Part 70.59 (CFR, 2021b), and 40 CFR Part 190 (CFR, 2021c) are met, gaseous effluent release points (stacks) are monitored. This approach assumes routine releases consist only of stack discharges. The statements in section 4.12.2.2.1 of the ER stipulate airborne activity concentration limits are 10 percent of the 10 CFR 20, Appendix B, Table 2 values and the dose at the site boundary is limited to 10 mrem per year. | ||
Based on the License Application (LA) and the Environmental Report (ER), the applicants licensed operations may include radiological environmental emissions due to normal operations or abnormal conditions. Under normal operating conditions, radiological effluents would be released from elevated stack discharge points. Some accident sequence scenarios result in releases from the stacks. The highest environmental concentrations of radioactive material resulting from stack releases are likely to be outside the controlled area. | Based on the License Application (LA) and the Environmental Report (ER), the applicants licensed operations may include radiological environmental emissions due to normal operations or abnormal conditions. Under normal operating conditions, radiological effluents would be released from elevated stack discharge points. Some accident sequence scenarios result in releases from the stacks. The highest environmental concentrations of radioactive material resulting from stack releases are likely to be outside the controlled area. | ||
TRISO-X now proposes to limit emissions based on the conservative assumption that the maximally exposed individual is at the stacks release points. This ensures that maximum environmental concentrations and the environmental concentrations at the site boundary are well below regulatory limits. However, the new proposals conflict with existing statements in the ER and the LA. | |||
TRISO-X now proposes to limit emissions based on the conservative assumption that the maximally exposed individual is at the stacks release points. This ensures that maximum environmental concentrations and the environmental concentrations at the site boundary are well below regulatory limits. However, | This new approach assumes that the applicants process and administrative controls prevent significant unmonitored routine emissions and fugitive emissions. Appropriate surveys, in the form of a radiological environmental monitoring program (REMP), in unrestricted and controlled areas, including the controlled area boundary, are necessary to validate this assumption. The REMP must also provide a capability to assist assessments of potential accidental releases. | ||
This new approach assumes that the applicants process and administrative controls prevent significant unmonitored routine | |||
In addition, the REMP should include appropriate surveys of potential build-up of uranium emissions in soil as a means to support assessments of potential accidental releases and periodic reviews of the decommissioning plans. | In addition, the REMP should include appropriate surveys of potential build-up of uranium emissions in soil as a means to support assessments of potential accidental releases and periodic reviews of the decommissioning plans. | ||
Submittals to date by the applicant do not provide sufficient information to evaluate the proposed emissions controls with respect to the adequacy of the REMP. | Submittals to date by the applicant do not provide sufficient information to evaluate the proposed emissions controls with respect to the adequacy of the REMP. | ||
Information Needed: | Information Needed: | ||
Revise the LA and ER to clarify the applicants commitment to limit effluent concentrations at the point of stack discharge to values below the 10 CFR 20, | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 2 of 11 Appendix B, Table 2 values. | |||
Revise the LA to include a map of ambient air sampling locations and specify appropriate analyses and frequencies in the LA that would verify the absence of routine ground level emissions and provide the means to assess releases under off normal conditions. | |||
Revise the LA to provide a map of locations where stormwater or precipitation is expected to accumulate and specify appropriate sampling, analyses and frequencies in the LA appropriate to monitoring accumulation of contaminants in soil as a result of wet deposition of gaseous radiological effluents. | |||
Revise the LA to provide sufficient description of methods to distinguish facility emissions from natural or other confounding sources of radioactivity, such as trace contaminants that are identified in feed material assays. | |||
TRISO-X Response to RAI-1: | TRISO-X Response to RAI-1: | ||
Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | ||
Demonstration is accomplished by | Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. License Chapter 9 will be revised to clarify this commitment. | ||
License Chapter 9 will be revised to include a map showing the approximate locations of ambient air samplers, which will be used to verify the absence of routine ground level emissions and provide a means to assess releases under off normal conditions. The types of analyses and frequency of sampling will be included. Ambient air samplers will be placed at the following locations along the security fence: | License Chapter 9 will be revised to include a map showing the approximate locations of ambient air samplers, which will be used to verify the absence of routine ground level emissions and provide a means to assess releases under off normal conditions. The types of analyses and frequency of sampling will be included. Ambient air samplers will be placed at the following locations along the security fence: | ||
North-northwest of the facility, which is the direction of the nearest residence (0.72 mi) and nearest residential well (1.12 mi). | North-northwest of the facility, which is the direction of the nearest residence (0.72 mi) and nearest residential well (1.12 mi). | ||
| Line 55: | Line 46: | ||
Southwest of the site, which is a predominant wind direction. | Southwest of the site, which is a predominant wind direction. | ||
West-northwest of the site, which is the direction of the nearest drinking water intake (Cumberland Utility District intake, 5.52 mi). | West-northwest of the site, which is the direction of the nearest drinking water intake (Cumberland Utility District intake, 5.52 mi). | ||
License Chapter 9 will be revised to include a map showing the approximate locations of stormwater or precipitation sampling, which will be sampled from the forebays of the detention basins. The forebays are where stormwater and precipitation will accumulate prior to migrating to the detention basins. Therefore, these are logical locations for accumulation of contaminants due to wet deposition of gaseous radiological effluents. The types of analyses and frequency of sampling will be included. | License Chapter 9 will be revised to include a map showing the approximate locations of stormwater or precipitation sampling, which will be sampled from the forebays of the detention basins. The forebays are where stormwater and precipitation will accumulate prior to migrating to the detention basins. Therefore, these are logical locations for accumulation of contaminants due to wet deposition of gaseous radiological effluents. The types of analyses and frequency of sampling will be included. | ||
License Chapter 9 will be revised to clarify that in order to distinguish facility emissions from natural or other confounding sources of radioactivity, baseline levels of radionuclides in media surrounding the facility are established through sampling and analysis prior to operations using SNM. Feed material is characterized for enrichment and other potential | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 3 of 11 contaminants prior to use. Future sample results are evaluated against action levels and the facility source term to identify any confounding natural sources of radioactivity or sources from operations external to the facility. | |||
License Changes: | License Changes: | ||
License Chapter 9, Section 9.5, Environmental Monitoring, will be revised as shown below (changes in red). | License Chapter 9, Section 9.5, Environmental Monitoring, will be revised as shown below (changes in red). | ||
TRISO-X conducts a routine environmental surveillance program. Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | TRISO-X conducts a routine environmental surveillance program. Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | ||
Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. | Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. | ||
Surface environmental media and groundwater samples are collected from strategic locations in the surrounding environs and analyzed for pertinent constituents of concern. Baseline levels of radionuclides in media surrounding the facility are established through sampling and analysis prior to operations using SNM are used for comparison for future environmental monitoring events. Feed material is characterized for enrichment and other potential contaminants prior to use. Future sample results are evaluated against action levels and the facility source term to identify any confounding natural sources of radioactivity or sources from operations external to the facility. Action levels and associated responsesactions to be taken if levels are exceeded are specified for each environmental medium and radionuclide as defined in approved procedures. | |||
Surface environmental media and groundwater samples are collected from strategic locations in the surrounding environs and analyzed for pertinent constituents of concern. Baseline levels of radionuclides in media surrounding the facility | The program provides additional validation of effluent monitoring systems, early detection and response to a negative trend in environmental data, and support data in the event of a release of radioactive material. Continuous stack monitoring provides a method for early detection of a negative trend in gaseous effluent releases from normal operations. Ambient air samplers verify the absence of routine ground level gaseous effluent releases and provide a method for early detection of ground level gaseous effluent releases from an off-normal event. Information from these monitoring activities is used to support assessments of normal operations or following off-normal events. | ||
The program provides additional validation of effluent monitoring systems, | |||
Feed material sources are not expected to present an external dose concern. | Feed material sources are not expected to present an external dose concern. | ||
Environmental dosimeters are co-located | Environmental dosimeters are co-located onsite with the ambient air samplers to monitor confirm the absence of ambient external doses dose rates above background in unrestricted areas and to assist with the assessment of potential accidents. | ||
Environmental dosimeter data are used to monitor external dose rates in unrestricted areas, determine doses to members of the public, and demonstrate compliance with regulatory dose limits. Doses to members of the public are calculated per 10 CFR 20.1302(b)(1), and may include considerations for the amount of time a member of the public is actually present or potentially present at a given location. | Environmental dosimeter data are used to monitor external dose rates in unrestricted areas, determine doses to members of the public, and demonstrate compliance with regulatory dose limits. Doses to members of the public are calculated per 10 CFR 20.1302(b)(1), and may include considerations for the amount of time a member of the public is actually present or potentially present at a given location. | ||
A summary of typical sampling activities is included in Table 9-1. Maps Typical of sampling locations will be provided once recommendations are available from the Environmental Reportare provided in Figure 9-1. It is expected that tThe locations for sampling of ambient air, soil, and vegetation will be concentrated along the | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 4 of 11 predominant wind directions. The locations for ambient air sampling are selected based on predominant wind directions and the direction of potential receptors. Four groundwater observation wells are installed on the site. Groundwater elevation measurements and modeling indicate that groundwater generally flows in a southwest direction toward East Fork Poplar Creek. There are no known household, public, or industrial users of groundwater downgradient of the site. | |||
Figure Table 9-1: Environmental Monitoring Parameters Type of Sample Analyses Number of Locations Typical Sampling Frequency Air Effluent Discharge Points Gross Alpha/Beta Isotopic Uranium 2 | |||
Continuous (collection weekly) | |||
Ambient Air Gross Alpha/Beta 6 | |||
Figure Table 9-1: | Continuous (collection mMonthly) | ||
Groundwater Gross Alpha/Beta Isotopic Uranium 4 | |||
Quarterly Soil Gross Alpha/Beta Isotopic Uranium 4 | |||
Semi-annually Vegetation Gross Alpha/Beta Isotopic Uranium 4 | |||
Semi-annually Stormwater Gross Alpha/Beta Isotopic Uranium 2 | |||
Quarterly Environmental Dosimetry Determined by NVLAP accredited vendor 6 | |||
Quarterly | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 5 of 11 Figure 9-1: Typical Sampling Locations | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses | |||
RAI-2 | TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 6 of 11 Environmental Report Changes: | ||
10 CFR 20.1302(b) states that a licensee shall show compliance with the annual dose limit in § 20.1301 by (1) demonstrating by measurement or calculation that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or (2) demonstrating that the annual average concentrations of radioactive material | The Environmental Report will be revised to clarify that compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. Because this revision has the potential to impact ER content in multiple sections or tables, the changes will be included in the ER Update that is planned for submittal to NRC in August 2024. | ||
RAI-2 Maximum Exposed Individual Regulatory Basis: | |||
10 CFR 20.1302(b) states that a licensee shall show compliance with the annual dose limit in § 20.1301 by (1) demonstrating by measurement or calculation that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or (2) demonstrating that the annual average concentrations of radioactive material at the boundary of the unrestricted area do not exceed values specified in table 2 of appendix B to part 20. | |||
Describe Issue: | Describe Issue: | ||
The proposed facility would generally release radiological effluents from elevated release points. The applicant currently proposes to define the unrestricted area boundary as the point of discharge from the stacks. However, this is not clearly explained in the LA. The use of 10 CFR 20.1302(b)(1) to demonstrate compliance with table 2 of appendix B to part 20 by measuring concentrations at the point of discharge from the stacks is conservative but conflicts with statements in the existing ER. | The proposed facility would generally release radiological effluents from elevated release points. The applicant currently proposes to define the unrestricted area boundary as the point of discharge from the stacks. However, this is not clearly explained in the LA. The use of 10 CFR 20.1302(b)(1) to demonstrate compliance with table 2 of appendix B to part 20 by measuring concentrations at the point of discharge from the stacks is conservative but conflicts with statements in the existing ER. | ||
Information Needed: | Information Needed: | ||
Revise the LA to clearly explain that TRISO-X is calculating the maximumly exposed individual to be at the point of discharge | Revise the LA to clearly explain that TRISO-X is calculating the maximumly exposed individual to be at the point of discharge from the stacks. Review and update the LA and ER, as needed, to ensure this approach is used consistently with the applicants current proposal for effluent monitoring and controls. Review ER Table 4.12.2-3 to ensure that units of distance are correctly specified. | ||
TRISO-X Response to RAI-2: | TRISO-X Response to RAI-2: | ||
The License and the Environmental Report will be revised to clearly explain that compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | The License and the Environmental Report will be revised to clearly explain that compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | ||
Demonstration is accomplished by | Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. | ||
Environmental Report Table 4.12.2-3 will be corrected to specify units of miles (mi) instead of meters (m) in the column labeled Distance. | |||
Environmental Report Table 4.12.2-3 will be corrected to specify units of miles (mi) instead of meters (m) in the column labeled Distance. | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 7 of 11 License Changes: | |||
See the license changes in the response to RAI-1. | See the license changes in the response to RAI-1. | ||
Environmental Report Changes: | Environmental Report Changes: | ||
Environmental Report Table 4.12.2-3 will be revised as shown below (changes in red). | Environmental Report Table 4.12.2-3 will be revised as shown below (changes in red). | ||
Table 4.12.2-3 Site Boundary X/Q and D/Q Factors Sector Distance (mi) | |||
Table 4.12.2-3 Site Boundary X/Q and D/Q Factors | |||
X/Q (s/m3) | X/Q (s/m3) | ||
D/Q (1/m2) | |||
Undepleted Undepleted Depleted N 0.09 4.00E-04 3.90E-04 3.80E-04 2.20E-07 NNE 0.09 9.00E-04 8.90E-04 8.70E-04 6.40E-07 NE 0.09 2.30E-03 2.30E-03 2.30E-03 1.60E-06 ENE 0.17 1.20E-03 1.10E-03 1.10E-03 5.90E-07 E 0.16 1.00E-03 1.00E-03 9.90E-04 4.70E-07 ESE 0.11 1.20E-03 1.20E-03 1.10E-03 3.70E-07 SE 0.11 8.70E-04 8.60E-04 8.40E-04 2.40E-07 SSE 0.05 2.60E-03 2.60E-03 2.60E-03 5.90E-07 S 0.04 3.50E-03 3.50E-03 3.40E-03 7.60E-07 SSW 0.10 1.30E-03 1.30E-03 1.30E-03 4.10E-07 SW 0.15 1.50E-03 1.50E-03 1.50E-03 6.30E-07 WSW 0.18 | No Decay 2.26 day Decay 8 day Decay Undepleted Undepleted Depleted N | ||
0.09 4.00E-04 3.90E-04 3.80E-04 2.20E-07 NNE 0.09 9.00E-04 8.90E-04 8.70E-04 6.40E-07 NE 0.09 2.30E-03 2.30E-03 2.30E-03 1.60E-06 ENE 0.17 1.20E-03 1.10E-03 1.10E-03 5.90E-07 E | |||
RAI-3 | 0.16 1.00E-03 1.00E-03 9.90E-04 4.70E-07 ESE 0.11 1.20E-03 1.20E-03 1.10E-03 3.70E-07 SE 0.11 8.70E-04 8.60E-04 8.40E-04 2.40E-07 SSE 0.05 2.60E-03 2.60E-03 2.60E-03 5.90E-07 S | ||
0.04 3.50E-03 3.50E-03 3.40E-03 7.60E-07 SSW 0.10 1.30E-03 1.30E-03 1.30E-03 4.10E-07 SW 0.15 1.50E-03 1.50E-03 1.50E-03 6.30E-07 WSW 0.18 9.20E-04 9.10E-04 8.80E-04 3.70E-07 W | |||
0.10 7.10E-04 7.00E-04 6.90E-04 3.60E-07 WNW 0.07 4.60E-04 4.60E-04 4.50E-04 2.30E-07 NW 0.07 4.20E-04 4.20E-04 4.10E-04 1.80E-07 NNW 0.07 3.40E-04 3.30E-04 3.30E-04 1.50E-07 RAI-3 Discharges to Sanitary Sewer: | |||
Regulatory Basis: | Regulatory Basis: | ||
10 CFR 20.2003, Disposal by release into sanitary sewerage states in part that (a) A licensee may discharge licensed material into sanitary sewerage provide they meet certain specific conditions including solubility, concentration, and does not exceed specified quantities or radiological activity limits. | 10 CFR 20.2003, Disposal by release into sanitary sewerage states in part that (a) A licensee may discharge licensed material into sanitary sewerage provide they meet certain specific conditions including solubility, concentration, and does not exceed specified quantities or radiological activity limits. | ||
Describe Issue: | Describe Issue: | ||
The ER indicates no planned liquid discharges to surface water or ground water are expected from the licensed activities. The | The ER indicates no planned liquid discharges to surface water or ground water are expected from the licensed activities. The ER indicates licensed material may be transported outside radiologically controlled areas. In addition, the LA Chapter 1, Section 1.1.4.7, states that bathrooms and showers discharge waste to the sanitary sewer system and thence to the City of Oak Ridge publicly owned treatment works. Chapter 9, Section 9.3.1, states sewer discharges to the City of Oak Ridge sewer system include restrooms and non-radiological process streams. The Safety Analysis Report and the ER do not include provisions to comply with 10 CFR 20.2003. The LA seems to imply that discharges | ||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 8 of 11 will comply with City of Oak Ridge specifications but does not state the requirements or commit to specific limits. If the applicant is using the discharge requirements of the City of Oak Ridge to demonstrate compliance with the release limits in 10 CFR 20.2003, this assumption is not stated clearly in the application and no corresponding commitment is provided. | |||
If TRISO-X will allow storage, processing or transiting of unsealed sources in areas that have sanitary sewer system drains, controls or monitoring must be implemented to prevent discharges that do not comply with the waste acceptance criteria or permit requirements of the local sewer treatment facility. | If TRISO-X will allow storage, processing or transiting of unsealed sources in areas that have sanitary sewer system drains, controls or monitoring must be implemented to prevent discharges that do not comply with the waste acceptance criteria or permit requirements of the local sewer treatment facility. | ||
The LA is not clear regarding the presence of restrooms within the radiologically controlled area. The application is unclear if restrooms are located within the radiologically controlled area and do not explain how sewer discharges will be sampled and analyzed prior to discharge to the sewer, or how radioactive material discharges to the sewer will be prevented. The application also does not explain how TRISO-X plans to move radioactive material through uncontrolled areas that have connections to the sewer system. | The LA is not clear regarding the presence of restrooms within the radiologically controlled area. The application is unclear if restrooms are located within the radiologically controlled area and do not explain how sewer discharges will be sampled and analyzed prior to discharge to the sewer, or how radioactive material discharges to the sewer will be prevented. The application also does not explain how TRISO-X plans to move radioactive material through uncontrolled areas that have connections to the sewer system. | ||
Information Needed: | Information Needed: | ||
Revise the LA to provide the following information: | Revise the LA to provide the following information: | ||
Update the LA to specify the locations of restrooms and drains that lead to the sanitary sewer in relation to the controlled area and to changeroom facilities. | |||
Update the LA to describe how TRISO-X will prevent licensed radioactive material discharges to the sanitary sewer in excess of applicable U.S. Nuclear Regulatory Commission (NRC) limitations from restrooms or showers located in the controlled area or in changeroom facilities. | |||
Clarify whether the commitment to comply with the City of Oak Ridge discharge limits is being used to demonstrate compliance with the NRC release limits. If so, provide sufficient data to describe the waste acceptance criteria and permit limitations of the City of Oak Ridge treatment works to confirm the limits are bounding. | |||
Update the LA to describe how TRISO-X will prevent transport of dispersible radioactive material through uncontrolled areas that have restrooms or process streams connected to the municipal sewer. | |||
TRISO-X Response to RAI-3: | TRISO-X Response to RAI-3: | ||
TRISO-X prevents licensed radioactive material discharges to the sanitary sewer by locating restrooms, changeroom facilities (i.e | TRISO-X prevents licensed radioactive material discharges to the sanitary sewer by locating restrooms, changeroom facilities (i.e., locker rooms, showers, and bathrooms), | ||
and drains that lead to the sanitary sewer outside of the Restricted Area (the process area boundary), which includes the Radiologically Controlled Area (RCA). Personnel will be required to doff personal protective | and drains that lead to the sanitary sewer outside of the Restricted Area (the process area boundary), which includes the Radiologically Controlled Area (RCA). Personnel will be required to doff personal protective equipment (PPE) and proceed through contamination monitors prior to exiting the Restricted Area. The sanitary sewer is not physically connected to the Restricted Area or to any process equipment within the Restricted Area. | ||
The commitment to comply with the City of Oak Ridge discharge limits is not being used to demonstrate compliance with NRC release limits in 10 CFR 20.2003. TRISO-X is not planning to seek a permit to discharge radioactive material to the sanitary sewer. | The commitment to comply with the City of Oak Ridge discharge limits is not being used to demonstrate compliance with NRC release limits in 10 CFR 20.2003. TRISO-X is not planning to seek a permit to discharge radioactive material to the sanitary sewer. | ||
TRISO-X prevents transport of dispersible radioactive material outside the Restricted Area by requiring personnel to doff PPE and proceed through contamination monitors prior to exiting the Restricted Area. In addition, the Restricted Area will be kept at a slight negative pressure, which prevents dispersible radioactive material from migrating outside of the | |||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 9 of 11 Restricted Area. License Chapter 4 establishes a rigorous Contamination Control Program that includes routine contamination control surveys and radiological surveys for any items removed from the restricted area and documents the contamination status of areas both inside and outside of the Restricted Area. | |||
License Changes: | License Changes: | ||
License Chapter 9, Section 9.3.1, Wastewater Collection/Treatment, will be revised as follows (changes in red). | License Chapter 9, Section 9.3.1, Wastewater Collection/Treatment, will be revised as follows (changes in red). | ||
9.3.1 Wastewater Collection/Treatment Process solutions generated by process systems and equipment are recycled to the maximum extent practical. Process solutions contaminated with uranium that cannot be recovered/ recycled are identified as liquid wastes. Liquid wastes are collected and sampled to determine appropriate handling/treatment steps. Treatment typically involves adjustment of pH, filtering, ion exchange, and/or precipitation. Precipitates are de-watered, and the solids are packaged for off-site disposal. If needed, liquid wastes that have been handled/treated can be sampled and discharged through an inline monitor to shipping packages or conveyances for off-site disposal. | 9.3.1 Wastewater Collection/Treatment Process solutions generated by process systems and equipment are recycled to the maximum extent practical. Process solutions contaminated with uranium that cannot be recovered/ recycled are identified as liquid wastes. Liquid wastes are collected and sampled to determine appropriate handling/treatment steps. Treatment typically involves adjustment of pH, filtering, ion exchange, and/or precipitation. Precipitates are de-watered, and the solids are packaged for off-site disposal. If needed, liquid wastes that have been handled/treated can be sampled and discharged through an inline monitor to shipping packages or conveyances for off-site disposal. | ||
Sanitary sewer discharges to the City of Oak Ridge sewer system from facility restrooms and non-radiological process streams related to equipment blowdowns, flushes, and cleaning activities are conducted in accordance with a locally-issued permit. Used oils may also be sampled and containerized for shipment to a licensed disposal facility. | Sanitary sewer discharges to the City of Oak Ridge sewer system from facility restrooms and non-radiological process streams related to equipment blowdowns, flushes, and cleaning activities are conducted in accordance with a locally-issued permit. Used oils may also be sampled and containerized for shipment to a licensed disposal facility. | ||
Licensed radioactive material discharges to the sanitary sewer are prevented by locating restrooms, changeroom facilities (i.e., locker rooms, showers, and bathrooms), | |||
Licensed radioactive material discharges to the sanitary sewer are prevented by locating restrooms, changeroom facilities (i .e., locker rooms, showers, and bathrooms), | |||
and drains that lead to the sanitary sewer outside of the Restricted Area (the process area boundary). The Restricted Area includes the Radiologically Controlled Area (RCA). Personnel are required to doff personal protective equipment (PPE) and proceed through contamination monitors prior to exiting the Restricted Area. The sanitary sewer is not physically connected to the Restricted Area or to any process equipment within the Restricted Area. | and drains that lead to the sanitary sewer outside of the Restricted Area (the process area boundary). The Restricted Area includes the Radiologically Controlled Area (RCA). Personnel are required to doff personal protective equipment (PPE) and proceed through contamination monitors prior to exiting the Restricted Area. The sanitary sewer is not physically connected to the Restricted Area or to any process equipment within the Restricted Area. | ||
TRISO-X prevents transport of dispersible radioactive material outside the Restricted Area by requiring personnel to doff PPE and proceed through contamination monitors prior to exiting the Restricted Area. In addition, the Restricted Area is kept at a slight negative pressure, which prevents dispersible radioactive material from migrating outside of the Restricted Area. License Chapter 4 establishes a rigorous Contamination Control Program that includes routine contamination control surveys and radiological surveys for any items removed from the Restricted Area and documents the contamination status of areas both inside and outside of the Restricted Area. | TRISO-X prevents transport of dispersible radioactive material outside the Restricted Area by requiring personnel to doff PPE and proceed through contamination monitors prior to exiting the Restricted Area. In addition, the Restricted Area is kept at a slight negative pressure, which prevents dispersible radioactive material from migrating outside of the Restricted Area. License Chapter 4 establishes a rigorous Contamination Control Program that includes routine contamination control surveys and radiological surveys for any items removed from the Restricted Area and documents the contamination status of areas both inside and outside of the Restricted Area. | ||
Environmental Report Changes: | Environmental Report Changes: | ||
None. | None. | ||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 10 of 11 RAI-4 Validation of Gaseous Effluent Concentrations in Unrestricted Areas: | |||
Regulatory Basis: | Regulatory Basis: | ||
10 CFR 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301. | 10 CFR 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301. | ||
Describe Issue: | Describe Issue: | ||
With respect to environmental monitoring, the LA states (Chapter 9, Section 9.5) the program provides additional validation of effluent monitoring systems, early detection and response to a negative trend in environmental data, and support data in the event of a release of radioactive material. The LA further identifies air effluent discharge points and ambient air (Table 9-1) as environmental | With respect to environmental monitoring, the LA states (Chapter 9, Section 9.5) the program provides additional validation of effluent monitoring systems, early detection and response to a negative trend in environmental data, and support data in the event of a release of radioactive material. The LA further identifies air effluent discharge points and ambient air (Table 9-1) as environmental monitoring parameters. However, the ambient air monitoring described in the LA and the ER does not provide sufficient detail to substantiate the performance of the validation, detection, response and assessments mentioned above. | ||
Section 6.2.1.1 of the ER commits the applicant to providing an onsite meteorological tower to support assessments of accidental gaseous releases, but does not commit to utilize this data for long term | Section 6.2.1.1 of the ER commits the applicant to providing an onsite meteorological tower to support assessments of accidental gaseous releases, but does not commit to utilize this data for long term assessments or trending of environmental data. | ||
Information Needed: | Information Needed: | ||
Revise the LA to explain how the measurements provided by the environmental monitoring program would validate effluent monitoring systems, provide early detection and response to a negative trend in effluent releases, and support assessments in the event of an accidental release of radioactive material. | |||
Revise ER Section 6.2.1.1 to include application of data provided by the onsite meteorological tower for long term assessments or trending of environmental data. | |||
TRISO-X Response to RAI-4: | TRISO-X Response to RAI-4: | ||
Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. | ||
Demonstration is accomplished by | Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. Continuous stack monitoring provides a method for early detection of a negative trend in gaseous effluent releases from normal operations. Ambient air samplers at the locations described in the response to RAI-1 provide a method for early detection of ground level gaseous effluent releases from an off-normal event. Information from these monitoring activities is used to support assessments of normal operations or following off-normal events. As stated in License Chapter 9, Section 9.2.1, paragraph 2, action levels are established for air monitoring activities. Action levels are used to provide early detection and trigger response, including the potential need for corrective action, to a negative trend in gaseous effluent releases. | ||
Environmental Report Section 6.2.1.1 will be revised to state that data provided by the onsite meteorological tower will be used for long term assessments and trending of environmental data. | Environmental Report Section 6.2.1.1 will be revised to state that data provided by the onsite meteorological tower will be used for long term assessments and trending of environmental data. | ||
License Changes: | License Changes: | ||
See the license changes in the response to RAI-1 | See the license changes in the response to RAI-1. | ||
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 11 of 11 Environmental Report Changes: | |||
Environmental Report Section 6.2.1.1, Meteorological Monitoring, will be revised as shown below (changes in red). | |||
6.2.1 AIR MONITORING 6.2.1.1 Meteorological Monitoring An on-site meteorological station records wind speed, wind direction, air temperature and relative humidity. Wind speed/direction are recorded at the industry standard (33 ft. [10 m]) level and at near stack level (100 ft. [30.5 m]) above ground level (AGL). | 6.2.1 AIR MONITORING 6.2.1.1 Meteorological Monitoring An on-site meteorological station records wind speed, wind direction, air temperature and relative humidity. Wind speed/direction are recorded at the industry standard (33 ft. [10 m]) level and at near stack level (100 ft. [30.5 m]) above ground level (AGL). | ||
Parameters recorded by the on-site meteorological station are input into plume modeling software that supports emergency response in case of an accidental release. | Parameters recorded by the on-site meteorological station are input into plume modeling software that supports emergency response in case of an accidental release. | ||
Data provided by the onsite meteorological tower will be used for long term assessments and trending of environmental data. | Data provided by the onsite meteorological tower will be used for long term assessments and trending of environmental data. | ||
The meteorological station is located near the TRISO-X Fuel Fabrication Facilitys emergency operations center, as described in Section 1.3.1.3, Site Layout and shown in Figure 1.3-3.}} | |||
The meteorological station is located near the TRISO-X Fuel Fabrication Facilitys emergency operations center, as described in Section 1.3.1.3, Site Layout and shown in Figure 1.3-3. | |||
Latest revision as of 19:36, 24 November 2024
| ML24087A236 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 03/27/2024 |
| From: | Triso-X |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24087A234 | List: |
| References | |
| TX0-REG-LTR-0038 | |
| Download: ML24087A236 (1) | |
Text
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 1 of 11 RAI-1 Gaseous Effluent Concentrations in Unrestricted Areas:
Regulatory Basis:
Title 10 of the Code of Federal Regulations (10 CFR) section 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301. The dose limits in § 20.1301 apply to the total effective dose equivalent from the licensed operation.
Describe Issue:
The applicant has proposed to monitor routine gaseous effluents at elevated release points and control concentrations at the points of discharge consistent with the dose limits in § 20.1301. Section 4.12.2.2.2.2 of the ER states To ensure regulatory requirements of 10 CFR Part 20.1101, 10 CFR Part 20.1302, 10 CFR Part 70.59 (CFR, 2021b), and 40 CFR Part 190 (CFR, 2021c) are met, gaseous effluent release points (stacks) are monitored. This approach assumes routine releases consist only of stack discharges. The statements in section 4.12.2.2.1 of the ER stipulate airborne activity concentration limits are 10 percent of the 10 CFR 20, Appendix B, Table 2 values and the dose at the site boundary is limited to 10 mrem per year.
Based on the License Application (LA) and the Environmental Report (ER), the applicants licensed operations may include radiological environmental emissions due to normal operations or abnormal conditions. Under normal operating conditions, radiological effluents would be released from elevated stack discharge points. Some accident sequence scenarios result in releases from the stacks. The highest environmental concentrations of radioactive material resulting from stack releases are likely to be outside the controlled area.
TRISO-X now proposes to limit emissions based on the conservative assumption that the maximally exposed individual is at the stacks release points. This ensures that maximum environmental concentrations and the environmental concentrations at the site boundary are well below regulatory limits. However, the new proposals conflict with existing statements in the ER and the LA.
This new approach assumes that the applicants process and administrative controls prevent significant unmonitored routine emissions and fugitive emissions. Appropriate surveys, in the form of a radiological environmental monitoring program (REMP), in unrestricted and controlled areas, including the controlled area boundary, are necessary to validate this assumption. The REMP must also provide a capability to assist assessments of potential accidental releases.
In addition, the REMP should include appropriate surveys of potential build-up of uranium emissions in soil as a means to support assessments of potential accidental releases and periodic reviews of the decommissioning plans.
Submittals to date by the applicant do not provide sufficient information to evaluate the proposed emissions controls with respect to the adequacy of the REMP.
Information Needed:
Revise the LA and ER to clarify the applicants commitment to limit effluent concentrations at the point of stack discharge to values below the 10 CFR 20,
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 2 of 11 Appendix B, Table 2 values.
Revise the LA to include a map of ambient air sampling locations and specify appropriate analyses and frequencies in the LA that would verify the absence of routine ground level emissions and provide the means to assess releases under off normal conditions.
Revise the LA to provide a map of locations where stormwater or precipitation is expected to accumulate and specify appropriate sampling, analyses and frequencies in the LA appropriate to monitoring accumulation of contaminants in soil as a result of wet deposition of gaseous radiological effluents.
Revise the LA to provide sufficient description of methods to distinguish facility emissions from natural or other confounding sources of radioactivity, such as trace contaminants that are identified in feed material assays.
TRISO-X Response to RAI-1:
Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20.
Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. License Chapter 9 will be revised to clarify this commitment.
License Chapter 9 will be revised to include a map showing the approximate locations of ambient air samplers, which will be used to verify the absence of routine ground level emissions and provide a means to assess releases under off normal conditions. The types of analyses and frequency of sampling will be included. Ambient air samplers will be placed at the following locations along the security fence:
North-northwest of the facility, which is the direction of the nearest residence (0.72 mi) and nearest residential well (1.12 mi).
Northeast of the facility, which is a predominant wind direction, and the direction of the nearest school (Dyllis Springs Elementary, 3.2 mi), nearest elder care facility (Canterfield of Oak Ridge, 8.4 mi), and nearest hospital (Methodist Medical Center, 8.28 mi).
East of the facility, which is the direction of the nearest major road (Highway 95).
South-southeast of the facility, which is the direction of the nearest commercial business (Philotechnics).
Southwest of the site, which is a predominant wind direction.
West-northwest of the site, which is the direction of the nearest drinking water intake (Cumberland Utility District intake, 5.52 mi).
License Chapter 9 will be revised to include a map showing the approximate locations of stormwater or precipitation sampling, which will be sampled from the forebays of the detention basins. The forebays are where stormwater and precipitation will accumulate prior to migrating to the detention basins. Therefore, these are logical locations for accumulation of contaminants due to wet deposition of gaseous radiological effluents. The types of analyses and frequency of sampling will be included.
License Chapter 9 will be revised to clarify that in order to distinguish facility emissions from natural or other confounding sources of radioactivity, baseline levels of radionuclides in media surrounding the facility are established through sampling and analysis prior to operations using SNM. Feed material is characterized for enrichment and other potential
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 3 of 11 contaminants prior to use. Future sample results are evaluated against action levels and the facility source term to identify any confounding natural sources of radioactivity or sources from operations external to the facility.
License Changes:
License Chapter 9, Section 9.5, Environmental Monitoring, will be revised as shown below (changes in red).
TRISO-X conducts a routine environmental surveillance program. Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20.
Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits.
Surface environmental media and groundwater samples are collected from strategic locations in the surrounding environs and analyzed for pertinent constituents of concern. Baseline levels of radionuclides in media surrounding the facility are established through sampling and analysis prior to operations using SNM are used for comparison for future environmental monitoring events. Feed material is characterized for enrichment and other potential contaminants prior to use. Future sample results are evaluated against action levels and the facility source term to identify any confounding natural sources of radioactivity or sources from operations external to the facility. Action levels and associated responsesactions to be taken if levels are exceeded are specified for each environmental medium and radionuclide as defined in approved procedures.
The program provides additional validation of effluent monitoring systems, early detection and response to a negative trend in environmental data, and support data in the event of a release of radioactive material. Continuous stack monitoring provides a method for early detection of a negative trend in gaseous effluent releases from normal operations. Ambient air samplers verify the absence of routine ground level gaseous effluent releases and provide a method for early detection of ground level gaseous effluent releases from an off-normal event. Information from these monitoring activities is used to support assessments of normal operations or following off-normal events.
Feed material sources are not expected to present an external dose concern.
Environmental dosimeters are co-located onsite with the ambient air samplers to monitor confirm the absence of ambient external doses dose rates above background in unrestricted areas and to assist with the assessment of potential accidents.
Environmental dosimeter data are used to monitor external dose rates in unrestricted areas, determine doses to members of the public, and demonstrate compliance with regulatory dose limits. Doses to members of the public are calculated per 10 CFR 20.1302(b)(1), and may include considerations for the amount of time a member of the public is actually present or potentially present at a given location.
A summary of typical sampling activities is included in Table 9-1. Maps Typical of sampling locations will be provided once recommendations are available from the Environmental Reportare provided in Figure 9-1. It is expected that tThe locations for sampling of ambient air, soil, and vegetation will be concentrated along the
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 4 of 11 predominant wind directions. The locations for ambient air sampling are selected based on predominant wind directions and the direction of potential receptors. Four groundwater observation wells are installed on the site. Groundwater elevation measurements and modeling indicate that groundwater generally flows in a southwest direction toward East Fork Poplar Creek. There are no known household, public, or industrial users of groundwater downgradient of the site.
Figure Table 9-1: Environmental Monitoring Parameters Type of Sample Analyses Number of Locations Typical Sampling Frequency Air Effluent Discharge Points Gross Alpha/Beta Isotopic Uranium 2
Continuous (collection weekly)
Ambient Air Gross Alpha/Beta 6
Continuous (collection mMonthly)
Groundwater Gross Alpha/Beta Isotopic Uranium 4
Quarterly Soil Gross Alpha/Beta Isotopic Uranium 4
Semi-annually Vegetation Gross Alpha/Beta Isotopic Uranium 4
Semi-annually Stormwater Gross Alpha/Beta Isotopic Uranium 2
Quarterly Environmental Dosimetry Determined by NVLAP accredited vendor 6
Quarterly
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 5 of 11 Figure 9-1: Typical Sampling Locations
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 6 of 11 Environmental Report Changes:
The Environmental Report will be revised to clarify that compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. Because this revision has the potential to impact ER content in multiple sections or tables, the changes will be included in the ER Update that is planned for submittal to NRC in August 2024.
RAI-2 Maximum Exposed Individual Regulatory Basis:
10 CFR 20.1302(b) states that a licensee shall show compliance with the annual dose limit in § 20.1301 by (1) demonstrating by measurement or calculation that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or (2) demonstrating that the annual average concentrations of radioactive material at the boundary of the unrestricted area do not exceed values specified in table 2 of appendix B to part 20.
Describe Issue:
The proposed facility would generally release radiological effluents from elevated release points. The applicant currently proposes to define the unrestricted area boundary as the point of discharge from the stacks. However, this is not clearly explained in the LA. The use of 10 CFR 20.1302(b)(1) to demonstrate compliance with table 2 of appendix B to part 20 by measuring concentrations at the point of discharge from the stacks is conservative but conflicts with statements in the existing ER.
Information Needed:
Revise the LA to clearly explain that TRISO-X is calculating the maximumly exposed individual to be at the point of discharge from the stacks. Review and update the LA and ER, as needed, to ensure this approach is used consistently with the applicants current proposal for effluent monitoring and controls. Review ER Table 4.12.2-3 to ensure that units of distance are correctly specified.
TRISO-X Response to RAI-2:
The License and the Environmental Report will be revised to clearly explain that compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20.
Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits.
Environmental Report Table 4.12.2-3 will be corrected to specify units of miles (mi) instead of meters (m) in the column labeled Distance.
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 7 of 11 License Changes:
See the license changes in the response to RAI-1.
Environmental Report Changes:
Environmental Report Table 4.12.2-3 will be revised as shown below (changes in red).
Table 4.12.2-3 Site Boundary X/Q and D/Q Factors Sector Distance (mi)
X/Q (s/m3)
D/Q (1/m2)
No Decay 2.26 day Decay 8 day Decay Undepleted Undepleted Depleted N
0.09 4.00E-04 3.90E-04 3.80E-04 2.20E-07 NNE 0.09 9.00E-04 8.90E-04 8.70E-04 6.40E-07 NE 0.09 2.30E-03 2.30E-03 2.30E-03 1.60E-06 ENE 0.17 1.20E-03 1.10E-03 1.10E-03 5.90E-07 E
0.16 1.00E-03 1.00E-03 9.90E-04 4.70E-07 ESE 0.11 1.20E-03 1.20E-03 1.10E-03 3.70E-07 SE 0.11 8.70E-04 8.60E-04 8.40E-04 2.40E-07 SSE 0.05 2.60E-03 2.60E-03 2.60E-03 5.90E-07 S
0.04 3.50E-03 3.50E-03 3.40E-03 7.60E-07 SSW 0.10 1.30E-03 1.30E-03 1.30E-03 4.10E-07 SW 0.15 1.50E-03 1.50E-03 1.50E-03 6.30E-07 WSW 0.18 9.20E-04 9.10E-04 8.80E-04 3.70E-07 W
0.10 7.10E-04 7.00E-04 6.90E-04 3.60E-07 WNW 0.07 4.60E-04 4.60E-04 4.50E-04 2.30E-07 NW 0.07 4.20E-04 4.20E-04 4.10E-04 1.80E-07 NNW 0.07 3.40E-04 3.30E-04 3.30E-04 1.50E-07 RAI-3 Discharges to Sanitary Sewer:
Regulatory Basis:
10 CFR 20.2003, Disposal by release into sanitary sewerage states in part that (a) A licensee may discharge licensed material into sanitary sewerage provide they meet certain specific conditions including solubility, concentration, and does not exceed specified quantities or radiological activity limits.
Describe Issue:
The ER indicates no planned liquid discharges to surface water or ground water are expected from the licensed activities. The ER indicates licensed material may be transported outside radiologically controlled areas. In addition, the LA Chapter 1, Section 1.1.4.7, states that bathrooms and showers discharge waste to the sanitary sewer system and thence to the City of Oak Ridge publicly owned treatment works. Chapter 9, Section 9.3.1, states sewer discharges to the City of Oak Ridge sewer system include restrooms and non-radiological process streams. The Safety Analysis Report and the ER do not include provisions to comply with 10 CFR 20.2003. The LA seems to imply that discharges
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 8 of 11 will comply with City of Oak Ridge specifications but does not state the requirements or commit to specific limits. If the applicant is using the discharge requirements of the City of Oak Ridge to demonstrate compliance with the release limits in 10 CFR 20.2003, this assumption is not stated clearly in the application and no corresponding commitment is provided.
If TRISO-X will allow storage, processing or transiting of unsealed sources in areas that have sanitary sewer system drains, controls or monitoring must be implemented to prevent discharges that do not comply with the waste acceptance criteria or permit requirements of the local sewer treatment facility.
The LA is not clear regarding the presence of restrooms within the radiologically controlled area. The application is unclear if restrooms are located within the radiologically controlled area and do not explain how sewer discharges will be sampled and analyzed prior to discharge to the sewer, or how radioactive material discharges to the sewer will be prevented. The application also does not explain how TRISO-X plans to move radioactive material through uncontrolled areas that have connections to the sewer system.
Information Needed:
Revise the LA to provide the following information:
Update the LA to specify the locations of restrooms and drains that lead to the sanitary sewer in relation to the controlled area and to changeroom facilities.
Update the LA to describe how TRISO-X will prevent licensed radioactive material discharges to the sanitary sewer in excess of applicable U.S. Nuclear Regulatory Commission (NRC) limitations from restrooms or showers located in the controlled area or in changeroom facilities.
Clarify whether the commitment to comply with the City of Oak Ridge discharge limits is being used to demonstrate compliance with the NRC release limits. If so, provide sufficient data to describe the waste acceptance criteria and permit limitations of the City of Oak Ridge treatment works to confirm the limits are bounding.
Update the LA to describe how TRISO-X will prevent transport of dispersible radioactive material through uncontrolled areas that have restrooms or process streams connected to the municipal sewer.
TRISO-X Response to RAI-3:
TRISO-X prevents licensed radioactive material discharges to the sanitary sewer by locating restrooms, changeroom facilities (i.e., locker rooms, showers, and bathrooms),
and drains that lead to the sanitary sewer outside of the Restricted Area (the process area boundary), which includes the Radiologically Controlled Area (RCA). Personnel will be required to doff personal protective equipment (PPE) and proceed through contamination monitors prior to exiting the Restricted Area. The sanitary sewer is not physically connected to the Restricted Area or to any process equipment within the Restricted Area.
The commitment to comply with the City of Oak Ridge discharge limits is not being used to demonstrate compliance with NRC release limits in 10 CFR 20.2003. TRISO-X is not planning to seek a permit to discharge radioactive material to the sanitary sewer.
TRISO-X prevents transport of dispersible radioactive material outside the Restricted Area by requiring personnel to doff PPE and proceed through contamination monitors prior to exiting the Restricted Area. In addition, the Restricted Area will be kept at a slight negative pressure, which prevents dispersible radioactive material from migrating outside of the
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 9 of 11 Restricted Area. License Chapter 4 establishes a rigorous Contamination Control Program that includes routine contamination control surveys and radiological surveys for any items removed from the restricted area and documents the contamination status of areas both inside and outside of the Restricted Area.
License Changes:
License Chapter 9, Section 9.3.1, Wastewater Collection/Treatment, will be revised as follows (changes in red).
9.3.1 Wastewater Collection/Treatment Process solutions generated by process systems and equipment are recycled to the maximum extent practical. Process solutions contaminated with uranium that cannot be recovered/ recycled are identified as liquid wastes. Liquid wastes are collected and sampled to determine appropriate handling/treatment steps. Treatment typically involves adjustment of pH, filtering, ion exchange, and/or precipitation. Precipitates are de-watered, and the solids are packaged for off-site disposal. If needed, liquid wastes that have been handled/treated can be sampled and discharged through an inline monitor to shipping packages or conveyances for off-site disposal.
Sanitary sewer discharges to the City of Oak Ridge sewer system from facility restrooms and non-radiological process streams related to equipment blowdowns, flushes, and cleaning activities are conducted in accordance with a locally-issued permit. Used oils may also be sampled and containerized for shipment to a licensed disposal facility.
Licensed radioactive material discharges to the sanitary sewer are prevented by locating restrooms, changeroom facilities (i.e., locker rooms, showers, and bathrooms),
and drains that lead to the sanitary sewer outside of the Restricted Area (the process area boundary). The Restricted Area includes the Radiologically Controlled Area (RCA). Personnel are required to doff personal protective equipment (PPE) and proceed through contamination monitors prior to exiting the Restricted Area. The sanitary sewer is not physically connected to the Restricted Area or to any process equipment within the Restricted Area.
TRISO-X prevents transport of dispersible radioactive material outside the Restricted Area by requiring personnel to doff PPE and proceed through contamination monitors prior to exiting the Restricted Area. In addition, the Restricted Area is kept at a slight negative pressure, which prevents dispersible radioactive material from migrating outside of the Restricted Area. License Chapter 4 establishes a rigorous Contamination Control Program that includes routine contamination control surveys and radiological surveys for any items removed from the Restricted Area and documents the contamination status of areas both inside and outside of the Restricted Area.
Environmental Report Changes:
None.
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 10 of 11 RAI-4 Validation of Gaseous Effluent Concentrations in Unrestricted Areas:
Regulatory Basis:
10 CFR 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301.
Describe Issue:
With respect to environmental monitoring, the LA states (Chapter 9, Section 9.5) the program provides additional validation of effluent monitoring systems, early detection and response to a negative trend in environmental data, and support data in the event of a release of radioactive material. The LA further identifies air effluent discharge points and ambient air (Table 9-1) as environmental monitoring parameters. However, the ambient air monitoring described in the LA and the ER does not provide sufficient detail to substantiate the performance of the validation, detection, response and assessments mentioned above.
Section 6.2.1.1 of the ER commits the applicant to providing an onsite meteorological tower to support assessments of accidental gaseous releases, but does not commit to utilize this data for long term assessments or trending of environmental data.
Information Needed:
Revise the LA to explain how the measurements provided by the environmental monitoring program would validate effluent monitoring systems, provide early detection and response to a negative trend in effluent releases, and support assessments in the event of an accidental release of radioactive material.
Revise ER Section 6.2.1.1 to include application of data provided by the onsite meteorological tower for long term assessments or trending of environmental data.
TRISO-X Response to RAI-4:
Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 20.1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20.
Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. Continuous stack monitoring provides a method for early detection of a negative trend in gaseous effluent releases from normal operations. Ambient air samplers at the locations described in the response to RAI-1 provide a method for early detection of ground level gaseous effluent releases from an off-normal event. Information from these monitoring activities is used to support assessments of normal operations or following off-normal events. As stated in License Chapter 9, Section 9.2.1, paragraph 2, action levels are established for air monitoring activities. Action levels are used to provide early detection and trigger response, including the potential need for corrective action, to a negative trend in gaseous effluent releases.
Environmental Report Section 6.2.1.1 will be revised to state that data provided by the onsite meteorological tower will be used for long term assessments and trending of environmental data.
License Changes:
See the license changes in the response to RAI-1.
TX0-REG-LTR-0038 Enclosure - Set 7 Environmental Safety RAI Responses Page 11 of 11 Environmental Report Changes:
Environmental Report Section 6.2.1.1, Meteorological Monitoring, will be revised as shown below (changes in red).
6.2.1 AIR MONITORING 6.2.1.1 Meteorological Monitoring An on-site meteorological station records wind speed, wind direction, air temperature and relative humidity. Wind speed/direction are recorded at the industry standard (33 ft. [10 m]) level and at near stack level (100 ft. [30.5 m]) above ground level (AGL).
Parameters recorded by the on-site meteorological station are input into plume modeling software that supports emergency response in case of an accidental release.
Data provided by the onsite meteorological tower will be used for long term assessments and trending of environmental data.
The meteorological station is located near the TRISO-X Fuel Fabrication Facilitys emergency operations center, as described in Section 1.3.1.3, Site Layout and shown in Figure 1.3-3.