ML073470226
| ML073470226 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/2008 |
| From: | Camper L NRC/FSME/DWMEP |
| To: | |
| Shared Package | |
| ML073330609 | List:
|
| References | |
| RIS-08-012 | |
| Download: ML073470226 (5) | |
See also: RIS 2008-12
Text
INFORMATION THAT NRC STAFF MAY REQUIRE TO AUTHORIZE
EXTENDED INTERIM STORAGE OF LOW-LEVEL RADIOACTIVE WASTE
The following identifies the information that the U.S. Nuclear Regulatory Commission (NRC)
considers pertinent to any request from a materials or fuel cycle licensee to authorize extended
interim storage of low-level radioactive waste (LLRW). Licensees whose LLRW storage
circumstances do not dictate the need for license amendment may also find the information
useful for a self-audit of the adequacy of their extended interim LLRW storage in conjunction
with other licensed operations.
1. Identification of Waste To Be Stored
a. Any possession limit increases needed for extended interim storage of LLRW.
Increases in possession limits to accommodate interim storage of LLRW may result in
the imposition of additional requirements, such as the requirements described in the
increased controls and fingerprinting orders issued to licensees authorized to possess
certain quantities of radionuclides of concern (see, e.g., 70 Federal Register 72128
(December 1, 2005); 72 Federal Register 70901 December 13, 2007)). Licensees
should note that, although low specific activity radioactive material inventories pose a
low risk, the increased controls requirements were imposed on certain types of
licensees, by either license condition or order based on authorized possession limits.
Specific activity thresholds were not established for categorical exclusion. However,
licensees were permitted to request relief from the increased controls if compliance with
any of the requirements was unnecessary in specific circumstances.
b. The estimated maximum amount of LLRW to be stored, both in terms of volume and
activity, by radionuclide. Estimates should be based on licensee operations which
generate LLW, any anticipated changes to these practices and best available
assessment of external factors which will affect future disposal availability.
c. Characterization of the LLRW to be stored:
1) volume and activity of waste by class (A, B, C, or greater than Class C per 10 CFR
61.55);
2) physical form of the waste (solid, liquid, or gas);
3) any processing of the waste either in-house or by an external vendor (volume
reduction, solidification, or other treatment);
4) additional non-radiological properties of LLRW, if any (e.g., toxic,
biologic/pathogenic, corrosive, flammable).
d. The amount and type of LLRW currently being stored or processed and current
disposition pathways (e.g., disposal by broker/processor, decay-in-storage).
Enclosure 1
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e. Any additional permits or approvals necessary for storage. These may include, for
instance, U.S. Environmental Protection Agency hazardous waste permits, state
approvals, and local approvals. The licensee may wish to assess the potential impact of
such approvals on the future disposition of particular waste streams.
2. Plans for Final Disposition
a. The volume, activity, and specific waste streams that must be stored because disposal
capacity/disposition options do not currently exist for the waste streams.
b. Disposition timeline and pathway for all waste streams likely to be stored for more than 1
calendar year for any discretionary reason (e.g., operational or business considerations).
For waste streams that are likely to be stored for more than 1 calendar year for
nondiscretionary reasons (e.g., lack of disposal capacity) dependent on third-party
actions, the licensee may wish to provide estimates by or on behalf of the third party of
the potential timeline and pathway of disposition. If no such estimate exists, the licensee
may provide an acknowledgement of the circumstance.
3. Physical Description of Storage Area or Storage Structure
a. The location and description or diagram of the LLRW storage area (or storage structure).
This may demonstrate where packages will be stored and how packages will be
accessible for inspection purposes. The licensee may wish to include the locations of
waste processing equipment (if applicable), air sampling stations, effluent filters, and any
sources of flammable or explosive material and any sources of material that are mobile
or could be rendered mobile (e.g., liquids, gases, sludges, ash, or fine-grained material)
if the primary containment was compromised.
b. The maximum volume of LLRW that can be stored in the proposed waste storage area
related to the annual volume of waste generated.
c. The type of building/structure or enclosure within which the waste will be stored. The
licensee may wish to briefly describe the means (if not self-evident) by which waste will
be protected from deleterious impacts of both chronic (e.g., precipitation, changes in
temperature, humidity) and applicable extreme (hurricanes, tornadoes) climatological
conditions. The licensee may wish to identify aspects of the storage area that require
periodic maintenance or testing (e.g., mechanical and electrical systems, gaskets, and
seals) and the frequency of such maintenance.
d. General measures to control access to the LLRW storage area and other methods, as
applicable, to ensure security of the waste. It is not necessary for licensees that are
implementing the increased controls requirements, to submit their increased controls
documentation during the licensing process unless requested. The NRC strongly
recommends not submitting such information and will rely on NRC inspectors to review
this documentation during licensee inspections. However, whenever a licensee believes
that this information is needed in order to respond to the increased controls
requirements or to respond to an apparent violation, then the document may be
submitted, provided it is properly marked in accordance with 10 CFR 2.390, Public
Inspections, Exemptions, Requests for Withholding.
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e. The ventilation system to assure adequate ventilation of an enclosed storage area.
f. The fire detection, protection, and suppression system to minimize the likelihood and
extent of fire.
g. Mitigation of the adverse effects of extremes of temperature and humidity, not
climatologically induced or otherwise described according to item 3.c above, on waste
and waste containers.
h. The vulnerability of the waste to other hazards, both anthropologically induced (e.g.,
industrial accidents) and, to the extent beyond the scope of item 3.c above, natural (e.g.,
flooding, earthquakes).
4. Packaging and Container Integrity
a. The nature of packages or containers to be used for storage of LLRW. Licensees may
wish to inform themselves of any hazards the waste may pose to package or container
integrity (structural stability, containment of radioactive waste, contribution to shielding,
and utility of handling and manipulation), and the projected storage life of the packages
or containers.
b. The program for periodic inspections of LLRW packages to ensure that they retain their
integrity and containment of LLRW.
c. The program for the identification and mitigation of damaged, leaking, or deteriorating
waste packages or containers. This may include, if applicable, equipment for remote
handling and/or repackaging damaged or leaking waste containers.
d. Additional, information related to possible problem areas related to waste packages and
waste forms is found in NUREG/CR-4062, Extended Storage of Low-Level Radioactive
Waste: Potential Problem Areas.
5. Radiation Protection
a. The 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 20.1902, Posting Requirements. The radiation protection program, including
the ALARA plan for the waste storage area or facilities, should be an integral part of the
overall facility radiation protection program.
b. 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. If procedures for responding to emergencies are not otherwise described in overall
facility licensing documentation, the licensee may wish to describe the procedures,
including triggering mechanisms, responsibilities and authorities, internal and external
notifications and notification of and coordination with local fire, police, and medical
departments and/or other emergency service providers. The licensee may wish to
consider formal agreements with emergency response providers that clearly define roles
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and responsibilities. The licensee may wish to consider periodic drills. As licensees that
are implementing or will be implementing the increased controls requirements are
aware, the specifics of a licensees security program must be protected, and the
specifics of the radioactive materials possessed are sensitive security-related
information. This information can be shared only with those who are considered
trustworthy and reliable and have a need to know.
d. The system for maintaining accurate records of waste in storage (including any waste
receipts or transfers from or to other licensees) to ensure accountability.
6. Training and Qualifications
a. The program for training personnel in procedures for packaging, handling, placement,
inspection, surveying, and emergency response for LLRW storage.
b. Qualifications for all personnel responsible for aspects of LLRW storage (if they differ
from those responsible for management of other licensed radioactive material). In most
cases, management of LLRW storage will represent only a portion of individual job
responsibility for a number of facility personnel. Licensees may wish to estimate the
percentage of each individuals time allocated to some aspect of LLRW storage.
7. Financial Assurance
a. The adequacy of financial assurance in accordance with 10 CFR 30.35, 10 CFR 40.36,
or 10 CFR 70.25, all titled Financial Assurance and Recordkeeping for
Decommissioning, based on any increases in possession limits mandated by
nondiscretionary extended interim storage. If amended possession limits exceed the
limits specified in these sections, regulations require a decommissioning funding plan or
certification of financial assurance. 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 reasonable best estimated cost of handling,
transport, and disposal of all LLRW stored on site.
b. The adequacy of facility liability and/or comprehensive insurance given the added
requirement for extended interim storage of LLRW.
The adequacy of licensee emergency preparedness with respect to increased possession
limits as a result of requirements for LLRW storage. Licensees may wish to review the
relevant sections of 10 CFR Part 30, Rules of General Applicability to Domestic Licensing
of Byproduct Material, 10 CFR Part 40, Domestic Licensing of Source Material, and
10 CFR Part 70, Domestic Licensing of Special Nuclear Material, to ensure that regulatory
requirements regarding emergency preparedness are met. If proposed maximum
possession limits exceed the limits specified in 10 CFR 30.32(i)(1), 10 CFR 40.31(j)(1), or
10 CFR 70.22(i)(3), either demonstrate that an emergency plan is not needed or develop
and maintain a plan that meets the requirements of these sections.
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9. Security/Increased Controls
Security measures consistent with the attractiveness and accessibility of the material and
vulnerability to theft and sabotage. Commission regulations in 10 CFR 20.1801, Security of
Stored Material, and 10 CFR 20.1802, Control of Material Not in Storage, require
licensees (1) to secure from unauthorized removal or access licensed materials that are
stored in controlled or unrestricted areas and (2) to control and maintain constant
surveillance of licensed material that is in a controlled or unrestricted area and that is not in
storage.
Low specific activity radioactive material inventories pose lower risk. The NRC is issuing
increased controls requirements to certain types of licensees based on their authorized
possession limits. Specific activity thresholds were not established for categorical exclusion.
Rather, implementation of the increased controls is based on possession of radionuclides of
concern in quantities greater than or equal to the activity limits provided Table 1 of the
increased controls orders (see, e.g., 70 Federal Register 72128 (December 1, 2005). There
is a process by which a licensee may request relief from the increased controls if
compliance with any of the requirements is deemed unnecessary in specific circumstances.
The NRC strongly recommends that licensees not submit their increased controls
documentation during the licensing process. NRC inspectors will review this documentation
during licensee inspections. However, whenever a licensee believes that this information is
needed to respond to the increased controls requirements or to respond to an apparent
violation, then the licensee may submit the document, provided that it is properly marked in
accordance with 10 CFR 2.390.
For licensees implementing the increased controls requirements, the specifics of a
licensees security system must be protected. Further, specific information related to the
radioactive materials possessed is considered sensitive security- related information that
can be shared only with those who are considered trustworthy and reliable and have a need
to know. Licensees who need assistance in determining when such information can be
appropriately shared with public officials should contact the appropriate NRC regional office.