An Assessment of Potential Dose Impacts from External Contamination on Naval Reactors Facility Waste Canisters (Special Analysis)
This Special Analysis (SA) was performed to address a request by Naval Reactors Facility (NRF) Waste Programs for a permanent exception to limits of removable surface contamination on the exterior of waste canisters shipped to the Remote-Handled Low-Level Waste (RHLLW) Disposal Facility as specified in the waste acceptance criteria (WAC) (PLN-5446). The purpose of this SA is to determine if the NRF-requested levels for removable surface contamination on the exterior of all NRF waste canisters is within the bounds of the current performance assessment (PA). This was done by calculating the groundwater all-pathways dose contribution from surface contamination on the exterior of NRF canisters for the following cases: (1) the exteriors of all NRF waste canisters are contaminated to the 10 CFR 835 Appendix D allowable limits in the current WAC, and (2) the exteriors of all NRF waste canisters are contaminated to the limits requested by NRF Waste Programs. Dose impacts for each case were compared to each other and to the all pathways dose for the PA base case. Dose impacts were also compared to the all pathways dose limit specified in DOE O 435.1. A simple assessment of the potential impacts of the increase in surface contamination using the NRF-requested limits on the biotic, air, and inadvertent intruder pathways was also performed. Based on the results of this SA, the increase in canister exterior contamination limits requested by NRF are well within the bounds of the current PA and will not result in a violation of performance objectives. The results also show the increased limits do not reflect or necessitate a fundamental change to the PA conceptual model, nor a change to the way exterior contamination is not included in PA dose calculations. Therefore, it is recommended the NRF request for an exception to the current limits for external surface contamination be accepted and the revised limits for NRF-generated waste canisters be added to the WAC. The monitoring plan will also be revised to identify external canister contamination as a potential mobile source term that may be detected by monitoring earlier than potential releases from waste. The PA, composite analysis (CA), closure plan, and PA/CA maintenance plan do not require revision. Recommendations are also included for inclusion of NRF procedures used to limit water pool radionuclide variability (and thus canister surface contamination variability) to the waste generator certification process.