Information Notice 1990-09, Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 February 5, 1990
NRC INFORMATION NOTICE NO. 90-09: EXTENDED INTERIM STORAGE OF LOW-LEVEL
RADIOACTIVE WASTE BY FUEL CYCLE AND
MATERIALS LICENSEES
Addressees
All holders of NRC materials licenses.
Purpose
This information notice provides guidance to fuel cycle and materials licensees
on information needed in license amendment requests to authorize extended interim
storage of low-level radioactive waste (LLW) at licensed operations. NRC pre- viously provided guidance on storage of LLW at nuclear power plant sites in
Generic Letters 81-38 and 85-14. However, until now NRC has not provided similar
guidance for fuel cycle and materials licensees who may, for reasons stated below, need to store their LLW for periods longer than in the past. It is expected that
recipients will review this information notice, distribute it to management and
staff involved with licensed activities, including responsible radiation safety
staff, and consider actions, as appropriate, to assure compliance with NRC re- quirements. No specific written response to this information notice is required.
Description of Circumstances
The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA) estab- lished a series of milestones, penalties and incentives to ensure that States
or Regional Compacts make adequate progress toward being able to manage their
LLW by 1993. On January 1, 1993, the existing LLW disposal sites are expected
to either close or to stop receiving LLW from outside their Regional Compacts.
What this means to licensees who generate LLW is that, unless their State or
Regional Compact either has a disposal facility operational on January 1, 1993 or has made other arrangements for storage or disposal, such licensees may have
to store their LLW onsite until disposal capacity is available. Storage of LLW
in accordance with NRC requirements may be necessary for anywhere from several
months to several years.
Discussion:
Not all licensees who will need to store LLW onsite will need amendments to their
licenses to do so. However, if the possession limits specified in a license need
to be increased to allow storage, or if the terms and conditions of a license
9001302 Z
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IN 90-09 February 5, 1990 otherwise need to be modified, a licensee will need to apply for a license amend- ment. Attachment 1 to this notice identifies information which licensees will
need to provide to NRC in such amendment requests. This information may also
be useful to licensees who will not need license amendments to store waste, as
well as to persons considering applying for a license to construct a centralized
storage facility to receive waste from others until State or Regional disposal
capacity is available. The following considerations are central to extended
storage, and are the basis of the information included in Attachment 1.
1. Storage is not a substitute for disposal. Other than storage for radio- active decay, LLW should be stored only when disposal capacity is
unavailable and for no longer than is necessary. Licensee planning
should consider a specific date by which storage will end and disposal
of the LLW will take place.
2. In general, waste should be processed before storage, packaged in a
form ready for transport and disposal at the end of the storage period, and clearly labeled in accordance with 10 CFR Subsection 20.203(f) and
Section 20.311. Adequacy of the waste form or package may have to be
reassessed before disposal.
3. To ensure integrity of packaging and maintenance of waste form, stored
waste should be shielded from the elements and from extremes of temperature and
humidity.
4. Waste should be stored in an area which allows for ready visual (direct
or remote) inspection on a routine basis. Licensees should plan to
conduct and document such inspections at least quarterly.
5. Depending on the specific waste involved, licensees may need to have
procedures and equipment in place or readily available to repackage
the waste, should the need arise.
6. Decomposition and chemical reaction of incompatible waste materials over
time can result in gas generation or other reaction products. Licensees
should evaluate what they are planning to store and use measures to prevent
these reactions. Further, licensees should determine if the need exists
for additional ventilation or fire protection/suppression systems.
7. For most waste forms, storage of waste in containers suitable for disposal
will not represent a significant increment of direct radiation exposure
potential to workers. However, licensees should consider their specific
waste and storage plans and determine if additional shielding or other
actions are warranted to keep exposures as low as is reasonably achievable
(ALARA).
8. Stored waste should be located in a restricted area and secured (e.g.,
in a locked room) against unauthorized removal for the term of storage.
7 .
IN 90-09 February 5, 1990 NRC does not advocate extended storage of LLW, as long as disposal capacity is
available to licensees. However, NRC recognizes that storage is allowed for, as an interim measure, in the framework of the LLRWPAA, and this guidance is
being issued in recognition of that fact. NRC continues to believe that, when- ever possible, storage should only be an interim step between activities that
generate waste and ultimate disposal of that waste. In the interest of public
health and safety, as well as maintaining exposures ALARA, the length of time
LLW is placed in storage should be kept to a minimum. Accordingly, NRC's ap- proval of requests by materials and fuel cycle licensees for interim extended
storage will generally be for a period of time no greater than five years.
Some licensees will need to store LLW which also contains hazardous waste as
specified under the Resource Conservation and Recovery Act, as amended (RCRA).
These mixed wastes, as they are called, are regulated both by NRC - for the
radioactive component of the waste - and the U.S. Environmental Protection Agency
(EPA) - for the hazardous component of the waste. The information and guidance
contained in this notice apply to NRC's regulations only. For information on
permitting of storage by EPA, licensees should contact the appropriate EPA
regional office or, in those States with approved mixed waste programs, the
appropriate State regulatory authority.
If you have questions about your State or Regional Compact, a list of contact
persons is provided in Attachment 2 of this notice.
Questions on your specific license or general procedures for license amendments
and reviews related to extended interim storage should be addressed to the
appropriate NRC regional office or, in the case of fuel cycle licensees, to
the Division of Industrial and Medical Nuclear Safety in NMSS.
Richard E. Cunningham, Director
Division of Industrial and Medical
Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
George Pangburn, NMSS
(301) 492-0628 Attachments:
1. Information Needed in an Amendment Request
to Authorize Extended Interim Storage of LLW.
2. Regional Compacts and Unaffiliated States.
3. List of Recently Issued NMSS Information Notices.
4. List of Recently Issued NRC Information Notices.
Attachment 1 IN 90-09 February 5, 1990 INFORMATION NEEDED IN AN AMENDMENT REQUEST TO AUTHORIZE
EXTENDED INTERIM STORAGE OF LOW-LEVEL RADIOACTIVE WASTE
The following paragraphs identify the information which NRC considers necessary
in an amendment request from a materials or fuel cycle licensee to authorize
extended interim storage of low-level radioactive waste (LLW).
1. Identification of Waste to be Stored
a. Specify any possession limit increases needed for extended interim
storage of LLW.
b. Identify the estimated maximum amount of LLW to be stored, both in
terms of volume and activity, by radionuclide.
c. Characterize the LLW to be stored:
) Volume of waste by Class (A, B, or C)
2 Physical form of the waste: solid, liquid or gas
(3) Waste processing: volume reduction, solidification
or other treatment.
(4) Additional non-radiological properties of LLW (if any):
hazardous, biologic/pathogenic, corrosive, flammable, etc.
d. Describe the amount and type of LLW currently being stored or
processed.
e. Identify any additional permits or approvals necessary for storage
(i.e., EPA hazardous waste permit, State or local approvals, etc.)
and the status of each required approval.
2. Plans for Final Disposal
a. Specify when disposal capacity will no longer be available to you
and onsite storage will begin.
b. Specify the State/Regional disposal facility to be used for ultimate
disposal of your LLW and when that facility is scheduled to begin
accepting LLW. Your Regional Compact or State LLW authority should
be able to provide this information if you do not have it.
c. Specify when you will begin shipping LLW to that facility and how
long it will take for your estimated storage inventory to be moved
out.
Attachment 1 IN 90-09 February 5, 1990 3. Physical Description of Storage Area
a. Identify the location and provide a diagram of the LLW storage area
which demonstrates where packages will be stored and how packages
will be accessible for inspection purposes. Include the locations of
waste processing equipment (if applicable), air sampling stations, effluent filters and any sources of flammable or explosive material.
b. Specify the maximum volume of LLW that can be stored in the proposed
waste storage area and relate this to annual volume of waste generated.
c. Specify the type of building/structure in which the waste will be
stored and demonstrate that the waste will be protected from weather
at all times.
d. Describe the measures to control access to the LLW storage area and
thereby ensure security of the waste.
e. Describe the ventilation system and how it will assure adequate
ventilation of the storage area.
f. Describe the fire protection and suppression system to minimize the
likelihood and extent of fire.
g. Describe how the adverse effects of extremes of temperature and
humidity on waste and waste containers will be avoided.
h. Describe vulnerability to other hazards such as tornado, hurricane, flood, industrial accident, etc.
4. Packaging and Container Integrity
a. Describe the packages or containers to be used for storage of LLW,
any hazards the waste may pose to their integrity, and the projected
storage life of the packages or containers.
b. Describe your program for periodic inspections of LLW packages to
ensure that they retain their integrity and containment of LLW.
c. Describe your program and equipment (if applicable) for remote
handling and/or repackaging damaged or leaking waste containers.
5. Radiation Protection
a. Describe your program for safe placement and inspection of waste in
storage and maintaining occupational exposures as low as is reasonably
achievable (ALARA). This program should include periodic radiation
and contamination surveys of individual packages and the storage area
in general, as well as posting the storage area in accordance with
10 CFR Section 20.203.
Attachment 1 IN 90-09 February 5, 1990 b. Describe projected exposure rates, needs for shielding (if any) and
any changes in personnel monitoring which will be required as a result
of waste storage.
c. Describe your procedures for responding to emergencies, including
notification of and coordination with local fire, police and medical
departments.
d. Describe your system for maintaining accurate records of waste in
storage (including any waste receipts or transfers from or to other
licensees) to assure accountability.
6. Training
a. Describe your program for training personnel in procedures for
packaging, handling, placement, inspection, surveying and emergency
response for LLW storage.
7. Financial Assurance
a. Review the relevant sections of Parts 30, 40 and 70 regarding financial
assurance for decommissioning. If your proposed maximum possession
limits exceed the limits specified in Sections 30.35, 40.36 or 70.25, submit with your amendment request a decommissioning funding plan or
certification of financial assurance, as appropriate. In either case, this submittal should demonstrate that financial resources are or will
be in place not only to decommission the licensed operation, but also
to provide for the estimated costs of handling, transport and ultimate
disposal of all LLW stored onsite.
a. Review the relevant sections of Parts 30, 40 and 70 regarding emergency
preparedness. If your proposed maximum possession limits exceed the
limits specified in Subsections 30.32 (i)(1), 40.31(j)(1) or 70.22 (i)(3),
you will be required to either demonstrate that an emergency plan is
not needed or to develop and maintain a plan that meets the requirements
of the aforementioned sections.
Attachment 2 IN 90-09 February 5, 1990 REGIONAL COMPACTS AND UNAFFILIATED STATES
The following is a list of the existing Regional LLW Compacts and unaffiliated
States. The list includes a contact person at either the Compact or State
level, if you have questions about LLW disposal. In addition, each Regional
Compact is further divided to show its member States.
1. Non-sited Regional Compacts*
Appalachian Compact Mark McClellan
Deputy Secretary for Environmental
Protection
Department of Environmental Resources
Commonwealth of Pennsylvania
P.O. Box 2063 Harrisburg, PA 17120
717/787-5028 (Member States are Pennsylvania Lhost
State], Delaware, Maryland and West
Virginia.)
Central Interstate Compact Ray Peery
Executive Director
Central Interstate Low-Level
Radioactive Waste Compact
3384 Peachtree Road NE, Suite 260
Atlanta, GA 30326
404/261-7114 (Member States are Nebraska [host
State], Arkansas, Kansas, Louisiana, and Oklahoma.)
Central Midwest Compact Clark Bullard
Chair, Central Midwest Compact Commission
Director, Office of Energy Research
University of Illinois
901 South Matthews
Urbana, IL 61801
217/333-7734 (Member States are Illinois Lhost
State] and Kentucky.)
Midwest Compact Gregg Larson
Executive Director
Midwest Low-Level Radioactive Waste
Compact Commission
350 North Robert, Room 588 St. Paul, MN 55101
612/293-0126
Attachment 2 IN 90-09 February 5, 1990 (Member States are Michigan [host
State], Iowa, Indiana, Minnesota, Missouri, Ohio and Wisconsin.)
Northeast Compact Denise Drace
Executive Director
Northeast Interstate Radioactive
Waste Compact Commission
195 Nassau Street, 2nd Floor
Princeton, NJ 08540
609/497-1447 (Member States are Connecticut and New
Jersey, both of which are host States.)
Southwestern Compact Don Womeldorf
Chief, Environmental Management Branch
Department of Health Services
State of California
714.P Street, Room 616 Sacramento, CA 95814
916/445-0498 (Member States are California [host
State], Arizona, North Dakota and South
Dakota.)
2. Sited Regional Compacts**
Northwest Compact Elaine Carlin
Executive Director
Northwest Compact Commission
Department of Ecology
State of Washington
Mail Stop PV-11 Olympia, WA 98504
206/459-6244 (Member States are Washington [host
Statej, Alaska, Hawaii, Idaho, Montana, Oregon and Utah.)
Rocky Mountain Compact Leonard Slosky
Executive Director
Rocky Mountain Compact Commission
1675 Broadway, Suite 1400
Denver, CO 80202
303/825-1912 (Member States are Nevada [current
host State], Colorado, New Mexico and
Wyoming.)
Attachment 2 IN 90-09 February 5, 1990 Southeast Compact Kathy Visocki
Executive Director
Southeast Compact Commission
3901 Barrett Drive, Suite 100
Raleigh, NC 27609
919/781-7152 (Member States are South Carolina
[current host State], Alabama, Florida, Georgia, Mississippi, North
Carolina, Tennessee and Virginia.)
3. Unaffiliated States***
District of Columbia Frances Bowie
Administrator
Service Facility Regulation
Administration
Department of Consumer and
Regulatory Affairs
District of Columbia
614 H Street, NW, #1014 Washington, D.C. 20001
202/727-7190
Maine Matthew Scott
Executive Director
Low-Level Radioactive Waste Siting
Authority
State of Maine
99 Western Avenue, Suite 101 Augusta, ME 04330
207/626-3249
Massachusetts Carol Amick
Executive Director
Low-Level Radioactive Waste
Management Board
Commonwealth of Massachusetts
100 Cambridge, 20th Floor
Boston, MA 02202
617/727-9800
New Hampshire Bryan Stromh
Deputy Director
Public Health Services Division
Department of Environmental Services
State of New Hampshire
6 Hazen Drive
Concord, NH 03301
603/271-3503
Attachment 2 IN 90-09 February 5, 1990 New York Jay Dunkelberger
Executive Director
Low-Level Radioactive Waste Siting
Commission
State of New York
1215 Western Avenue, Suite 306 Albany, NY 12203
518/438-6130
Puerto Rico Santos Rohena
Chair
Environmental Quality Board
Commonwealth of Puerto Rico
P.O. Box 11488 San Turce, Puerto Rico 00910
809/725-5140
Rhode Island Victor Bell
Chief
Office of Environmental Coordination
Department of Environmental Management
State of Rhode Island
9 Hayes Street
Providence, RI 02908
401/277-3434 Vermont Jonathan Lash
Secretary
Agency of Natural Resources
State of Vermont
103 South Main
Waterbury, VT 05676
802/244-7347 Texas Lawrence R. Jacobi
General Manager
Low-Level Radioactive Waste Disposal
Authority
State of Texas
7701 North Lamar Boulevard, #300
Austin, TX 78752
512/451-5292
- Non-sited Regional Compacts are those Compacts of States approved by Congress
that do not currently have an operational LLW disposal facility.
- Sited Regional Compacts are those Compacts of States approved by Congress
that do have an operational LLW disposal facility.
- Unaffiliated States are those States that are not a member of a Regional
Compact and that are pursuing LLW disposal capacitTyor other LLW disposal
arrangements independently.
Attachment 3 IN 90-09 February 5, 1990 LIST OF RECENTLY ISSUED
NMSS INFORNATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
90-01* Importance of Proper 01/12/90 All holders of NRC
Response to Self-Identified materials licenses.
Violations by Licensees
89-85 EPA's Interim Final Rule 12/15/89 All medical, academic, on Medical Waste Tracking industrial, waste
and Management broker, and waste
disposal site licensees.
89-82 Recent Safety-Related 12/07/89 All U.S. NRC licensees
Incidents at Large authorized to possess
Irradiators and use sealed sources
at large irradiators.
89-78 Failure of Packing Nuts on 11/22/89 All U.S. NRC licensees
One-Inch Uranium Hexafluoride authorized to possess
Cylinder Valves and use source material
and/or special nuclear
material for the heating, emptying, filling, or
shipping of uranium
hexafluoride in 30- and
48-inch diameter cylinders.
89-60 Maintenance of Teletherapy 08/18/89 All U.S. NRC Medical
Units Teletherapy Licensees.
89-47 Potential Problems with 05/18/89 All holders of operating
Worn or Distorted Hose licenses or construction
Clamps on Self-Contained permits for nuclear power
Breathing Apparatus reactors and fuel
facilities.
89-46 Confidentiality of 05/11/89 All holders of licenses
Exercise Scenarios for fuel cycle facilities
and byproduct material
licensees having an
approved emergency
response plan.
- Correct Nudocs Accession Number for 90-01 should be 9001080145
Attachment 4 IN 90-09 February 5, 1990 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
88-30, Target Rock Two-Stage SRV 2/2/90 All holders of OLs
Supplement 1 Setpoint Drift Update or CPs for nuclear
power reactors.
90-08 Kr-85 Hazards from Decayed 2/1/90 All holders of OLs
Fuel or CPs for nuclear
power reactors and
holders of licenses
for permanently shut- down facilities with
fuel on site.
88-23, Potential for Gas Binding 1/31/90 All holders of OLs
Supp. 2 of High-Pressure Safety or CPs for PWRs.
Injection Pumps During a
Loss-of-Coolant Accident
90-07 New Information Regarding 1/30/90 All holders of OLs
Insulation Material or CPs for nuclear
Performance and Debris power reactors.
Blockage of PWR Contain- ment Sumps
90-06 Potential for Loss of 1/29/90 All holders of OLs
Shutdown Cooling While or CPs for nuclear
at Low Reactor Coolant power reactors.
Levels
90-05 Inter-System Discharge of 1/29/90 All holders of OLs
Reactor Coolant or CPs for nuclear
power reactors.
90-04 Cracking of the Upper Shell- 1/26/90 All holders of OLs
to-Transition Cone Girth or CPs for Westinghouse- Welds in Steam Generators designed and Combustion
Engineering-designed
nuclear power reactors.
90-03 Malfunction of Borg-Warner 1/23/90 All holders of OLs
Bolted Bonnet Check Valves or CPs for nuclear
Caused by Failure of the power reactors.
Swing Arm
OL = Operating License
CP = Construction Permit
IN 90-
February , 1990 8. Stored waste should be located in a restricted area and secured
(e.g., in a locked room) against unauthorized removal for the term of
storage.
NRC does not advocate extended storage of LLW, as long as disposal capacity is
available to licensees. However, NRC recognizes that storage is allowed for, as an interim measure, in the framework of the LLRWPAA, and this guidance is
being issued in recognition of that fact. NRC continues to believe that, whenever possible, storage should only be an interim step between activities
that generate waste and ultimate disposal of that waste. In the interest of
public health and safety, as well as maintaining exposures ALARA, the length of
time LLW is placed in storage should be kept to a minimum. Accordingly, NRC's
approval of requests by materials and fuel cycle licensees for interim
extended storage will generally be for a period of time no greater than five
years.
Some licensees will need to store LLW which also contains hazardous waste as
specified under the Resource Conservation and Recovery Act, as amended (RCRA).
These mixed wastes, as they are called, are regulated both by NRC - for the
radioactive component of the waste - and the U.S. Environmental Protection Agency
(EPA) - for the hazardous component of the waste. The information and guidance
contained in this notice apply to NRC's regulations only. For information on
permitting of storage by EPA, licensees should contact the appropriate EPA
regional office or, in those States with approved mixed waste programs, the
appropriate State regulatory authority.
If you have questions about your State or Regional Compact, a list of
contact persons is provided in Attachment 2 of this notice.
Questions on your specific license or general procedures for license amendments
and reviews related to extended interim storage should be addressed to the
appropriate NRC regional office or, in the case of fuel cycle licensees, to the Division of Industrial and Medical Nuclear Safety in NMSS.
Richard E. Cunningham, Director
Division of Industrial and Medical
Nuclear Safety, NMSS
Technical Contact:
George Pangburn, NMSS
(301) 492-0628 Attachments:
1. Information Needed in an Amendment Request
to Authorize Extended Interim Storage of LLW.
2. Regional Compacts and Unaffiliated States. OGC* e
3. List of Recently Issued NMSS Information Notices. RFonner
4. List of Recently Issued NRC Information Notices. 1/24/90 Z
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IN 90-
February , 1990 8. Stored waste should be located in a restricted area and secured
(e.g., in a locked room) against unauthorized removal for the term of
"sAtorage.
NRC does not advocate extended storage of LLW, as long as disposal capacity is
availablelto licensees. However, NRC recognizes that storage is allowed for, as an inte immeasure, in the framework of the LLRWPAA, and this guidance is
being issued in recognition of that fact. NRC continues to believe that, whenever possible, storage should only be an interim step between activities
that generate baste and ultimate disposal of that waste. In the interest of
public health aho safety as well as maintaining exposures ALARA, the length of
time LLW is placed in storage should be kept to a minimum. Accordingly, NRC's
approval of requests by materials and fuel cycle licensees for interim
extended storage will generally be for a period of time no greater than five
years.
Some licensees will need to store LLW which also contains hazardous waste as
specified under the Reso'.rce Conservation and Recovery Act, as amended (RCRA).
These mixed wastes, as they are called, are regulated both by NRC - for the
radioactive component of the waste - and the U.S. Environmental Protection Agency
(EPA) - for the hazardous component of the waste. The information and guidance
contained in this Notice applies to NRC's regulations only. For information on
permitting of storage by EPA, licensees should contact the appropriate EPA
Regional Office or, in those States with approved mixed waste programs, the
appropriate State regulatory authority.
If you have questions regarding your State or Regional Compact, a list of contact
persons is provided in Attachment 2 to this Notice.
Questions regarding your specific licentse or general procedures for license
amendments and reviews related to extended interim storage should be addressed
to the appropriate NRC Regional Office or\ in the case of fuel cycle licensees, to the Division of Industrial and Medical 'uclear Safety in NMSS.
Richard\s. Cunningham, Director
Division of Industrial and Medical
Nuclear Safety, NMSS
aCnL41a
IL I kluntact: George rangburn, NmSS
(301) 492-0628 Attachments:
1. Information Needed in an Amendment Request
to Authorize Extended Interim Storage of LLW.
2. Regional Compacts and Unaffiliated States.
3. List of Recently Issued NMSS Information Notices.
4. List of Recently Issued NRC Information Notices. j/zty/7i
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