ML19250J218
| ML19250J218 | |
| Person / Time | |
|---|---|
| Issue date: | 01/12/1981 |
| From: | Bradford P NRC COMMISSION (OCM) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19250J216 | List: |
| References | |
| SECY-81-383, TAC-48752, NUDOCS 8107200141 | |
| Download: ML19250J218 (7) | |
Text
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ENCLOSURE 2
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ATTACHMENT B
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- January 12,. 1981' OFMcE OFTHE
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MEMO TD:
Chairman Ahearne Comissioner Bilinsi;y
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Coraissioner Hendrie M.
Peter A. Bradford fROM:
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SUBJECT:
SECY-80-511 STOP. AGE OF LOW-LEVEL RADI0 ACTIVE h r.S AT POWER
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REACTOR SITES I think the staff's proposal in this paper.is a good one, except that by leaving the NRC regulatory process to Part 30, it does not address the issue of whether a reactor licensee should seek NRC approval prior to construction of a low-level waste storage facility. My own-conclusion is that it would be prudent regulatory policy to impose such a requirement.
Otherwise, NRC is not able to offer early suggestions on issues like. seismic design and waste retrievability. The absence of early involvement could therefore result ia a denial of a license for a costly facility or acceptance of a completed facility which could have been substantially improved.
The mill tailings regulations are, precedent for such early NRC involvement in materials licensing.
I would suggest
.that the staff work up a proposal whereby reactor licensees would need to file applications and NRC construction authorization would need to be given prior to construction of type 2 and 3 low-level waste storage facilities.
If hearings w' ere held, those wou~d have to be completed prior:to construction unless the Board ruled that construction could proceed while the heari'ngs continued.
While. net directly related to this s'taff paper, it is apparent that' 30.32(f) needs work.
It is now a classic Catch-22, where an application need be filed before construction only if the Comission determines the activity will significantly affect the quality of the environment.
Of course, without notice of the activity, the Comission could have difficult making the determination.
Accordingly, the staff should be required to resolve this issue on a generic basis.
The resolution need not hold up action on the low-level waste paper.
cc:
Samuel J. Chilk-Edward Hanrahan Leonard Bickwit 0107200141 010619 CF SUBJ CF
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ENC!.0SURE 3 b
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ATTACHMENT C
. RADIOLOGICAL SAFETY / GUIDANCE FOR,
ONSITE CONTINGENCY STORAGE CAPACITY I.
Introduction The objective of this tehenical position is to provide g'uidance to the licensees considering additional onsite lod level radioactive waste storage capabilities. The duration of the intended storage, the. type and fom of waste, and the magnitude of radionuclides present will dictate the safe-guards and the level of complexity required to assure pubite health and safety, and minimal risk to operating personnel.
The longer the intendet storage period, the greater the degree of controls that will be required for radiation protection and accident prevention.
For purposes of this document, the duration of temporary waste storage is to be up to two (2) years. The magnitude of the onsite storage safety hazard is predicated on the type of waste being stored, the amount of radionuclides present, and how readily they might be transported into the environment.
In general, it is preferable to store radioactive material in solid fom.
Under some circumstances, hewever, temporary storage in a liquid form may be desirable or required.
The specific design and operation of any storage facility will be signifi-cantly influenced by the various waste foms, consequently, this document addresses wet waste, solidified wet vaste and dry low level radioactive waste.
II.
General-Infomation 3
Prior to any implementation of additional onsite storage, substantial safety review and environmental assessments should be conducted to assure adequate public health and safety, and minimal environmental impact.
The acceptance criteria and perfomance objectives of any proposed storage facility, or area, will need to meet minimal requirements in areas of design, operations, safety considerations and policy considerations.
For purposes of this tech-nical position, the major emph' asis will be on safety :ensiderations in the storing, handling and eventual disposition of the radioactive waste.
Design and operational acceptability will be based on minimal requirements which are defined in existing SRPs, Regulatory Guides, and industry standards for proper management of radioactive waste.
Considerations for waste minimiza-tion and volume reduction will also have to be incorporated into the waste management plan and the onsite storage alternative.
Additional considera-tions for ALARA, decontamination, and decommissioning of the temporary s'..orage fccility, including disposal which should be perfomed as early as possible because future requirements for waste foms may make stare' wastes unaccept-able for final disposition.
Facility design and operation should assure that r:m 'ogical consequences of design basis events (fire, tornado, seismic event, flood) should not exceed a small fraction (10". of 10 CFR Part 100, i.e., no more than a few rer whole body dose.
The added capacity would typically extend storage to accommadate no more than an amount of waste generated during a nominal two-year period.
In addition, waste should not be stored for a duration that exceeds two years.
Storage of waste in excess of the quantities and duration degcribed herein requires Part 30 licensing approval.
The design capaci'.y (f t', Ci) should be deter-mined from historical waste generation rates for the station, considering both volume minimization / reduction programs and the need for surge capacity due to operations which may generate unusually large arounts of waste.
In any case, the nominal two year storage capacity should not exceed approxi-3 mately 10,000 Ci of mixed fission and activation prodducts and 100,000 f t,
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III. General 1y Applicable Guidance (a)
The quantity of radioactive material allowed and the shielding config-urations will be dictated by the dose rate criteria for both the site boundary and unrestricted areas onsite. The 40 CFR 190 limits will restrict the annual dose from direct radiation and ef fluent release to the whole body from all sources of the uranium fuel cycle; therefore, offsite doses from onsite storage must be sufficiently lov to account for other sources (e.g., < 1 mrem / year).
Onsite dose lim:.s associated with temporary storage will be controlled per 10 CFR Part 20 including the ALARA principle of 10 CFR 20.1.
(b)
For low level dry waste and solidified waste storage, 1.
Potential release pathways of all radionuclides praent in the solidified waste form shall be monitored as per 10 CFR 50 Appen -
dix A.
Surveillance programs shall incorporate adequate methods for detecting failure or containe; integrity and measuring releases to the environment.
For outside storage, periodic direct radiation and surface contamination monitoring shall be coWcted to insure that levels are belcw limits specified in 10 CFG TJ.202, 20.205, and 49 CFR 173.397.
- All containers should be decontaminated to these levels or below before storage.
2.
Provisions should be incorporated for collecting liquid drainage including provisions for sampiing all collected liquids.
Routing of the collectec liquids should be to radwaste systems if contam-S
. ination is detected or to normal discharge patNays if the water ingress was from external sources and remained uncontaminated.
3.
Waste stored in outside areas should be held securely by installed hold down systems.
The hold down system should secure all contain-ers during severe environmental conditions up to and including the design basis e' vent for this waste storage facility.
4.
Container integrity should be assured against corrosion from the '
external environment; external weather protect, ion should be in-cluded where necessary and practical.
Storage containers should be raised off storage pads where water accumulation can be expected to cause external corrosion and possible degradation cf container integri ty.
5.
Total curie limits should be established based on the design of the storage area and the safety features provided.
6.
Inventory records of waste types, contents, dates of storage, shipment, etc., shoul d be maintained.
1Y.* Wet Radioactive Waste Storage (a)
Vet radioactive waste will be defined as any liquid or liquid / solid slurry.
For storage considerations, wet waste is further defined as any waste which contains free liquid in amounts which exceed the re-quirements for burial as established by the burial ground licensing authori ty.
t (b)
The facility supporting structure and tanks should be designed to pre-vent uncontrolled releases of radioactive materials due to spillage or accident conditions.
(c)
The following design objectives and criteria are applicable for wet radioactive waste storagte facilities:
1.
Structures that house liquid radweste storage tanks should be des Wed to seismic criteria to dafined in Standard Review Plan
' (Section 11.2).
Foundations and walls shall also be desi;ned and fabricated to contain the liquid inventory which might be released during a container / tank failure.
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2.
All tanks or containers should be designated to withstand the corrosive nature of the wet waste stored.
With duration of storage under which the corrosive conditions exist shall also be considered in the design.
4-3.
All storage structures should have curbs or elevated thresholds
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with floor drains and sumps to safely collect wet waste assuming the failure of all tanks or containers.
Provisions should be incorporated to remove spilled wet waste to the radwaste treat-ment systems.
4.
All tanks and containers shall have ' provisions to monitor liquid levels and to alarm potential overflow conditions..,
5.
All potential release pathways of radionuclide's (e.g., evolved
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gases, breach of container, etc.) shall be controlled and inonitored as per 10 CFR 50 Appendix A (General Design criteria 60 and 64).
Surveillance programs should incorporate adequate methods for monitoring breach of container integrity or accidental releases.
6.
All temporarily stored wet waste will require additional repro-cessing prior to shipment offsite; therefore, provision should be established to integrate the required +.reatment with the waste '
processing and solidification systems.
The interface and associa-ted systems should be designed and tested in accordance with the codes and standards described in Standard Review Plan Section 11.
Y.
Solidified Radioactive k'aste Storage (a)
Solidified redwaste for storage purposes shall bc defined as that waste which meets burial site solidified waste criteria.
For purposes of this document, resins or filter sludges dewatered to the above criteria will be defined under this waste classification / criteria.
(b)
Any storage plans should address container protection as well as any reprocessing requirements for eventual shipment and burial.
(c)
Casks, tanks, and liners containing solidified radioactive waste sheuld be designed with good engineering judgement to preclude or reduce the probability of occurrence of uncontrolled releases of radioactive materials due to handling, transportation or st:rcse.
Accident nitigation and control for design basis events (e.g., fire, flooding, tornadoes, etc.) must be evaluated and protected against unless cther-wise justified.
(d)
The folluing design objectives and criteria are applicable for solidi-fied waste storage containers and facilities:
1.
All solidified rtdwaste should be located in restricted areas where ef fective material control and accountability can be main-tained. L'hile structures are not required to meet seismic criteria,
- protection should be afforded to insure the radioactivity is con-tained safely by use of good engineering judg ent, such as the use of curbs and drains to contain spD s of dewatered resins or sludges.
2.
If liquids exist which are corrosive, proven provisions should be
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made to protect the container (i.e., special liners or coatings) and, or neutralize the excess liquids.
If deemed appropriate and necessary, highly non-corrosive materials (e.g., stainless steel) should be used.
Potential corrosion between the solid waste forms and the container should also be considered.
In the case of de-watered resins, highly corrosive acids and bases can be generated which will significantly reduce the longevity of the container.
The Process Control Program (PCP) should implement steps to assure the above does not occur; provisions on container material selec-tion and precoating should be made to insure that container breach does not occur during temporary storage periods.
3.
Provision should be made for additional repr > cessing or repackaging due to container failure and/or, as required for final transporting and burial as per DOT and burial site criteria.
Contamination isolation and decontamination capabilities should be develcped.
whereby significant handling and personnel exposure can be antici-pated, ALARA methodolgy shold be incorporated as per Regulatory Guides 8.8 and 8.10.
4.
Procedures should be developed and implemented for early detection, prevention and mitigation of accidents (e.g., fires).
Storage areas and facility designs should incorporate good engipeer'ng features and contingencies so as to handle accidents and provide safeguard systems such as fire detectors and suppression systems, (e.g., smoke detector and sprirklers).
Personnel training and administrativt procedures should be established to insure both control of radioactive materials and minimum personnel exposures:
Fire suppression devices may not be necessary if combustible materials are minimal in the area.
V.
Lew Level Dry Waste Storace (a)
Low level dry waste is classified as contaminated material (e.g., paper, trash, air filters) which contains radioactive material dispersed in small concentrations throughout large volumes of inert material and contains no free water.
Generally, this censists of dry material such as rags, clothing, paper and small equipment (i.e., tools and instru-ments) which cannot be easily decontaminated.
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Licer-
's should implement controls to segregate and minimize the genera-tion.. low level dry waste to lessen the impact on waste storage.
Integration of Volume Reduction (VR) hardware should be considered to minimize the need for additional wasta storage facilities.
(c)
The following desig'n objectives and criteria are applicable for low level dry waste storage containers and facilities.
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1.
All dry or compacted radwaste should be located in restricted areas
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where effective material control and accountabilit/ can be main-tained.
While structures are not required to meet seismic critaria, protection should be afforded to insure the radioactivity is con-tained safely by use of good engineering judgment.
The waste container should be designed to insure radioactive material 2.
con.tainment during normal and abnormal occurrences. The waste container materials should not support combustion. The packaged material should not cause fires through spontaneous chemical reactions, retained heat, etc.
3.
Containers shb~uld generally comply with the criteria of 10 CFR 71 and 49 CFR 170 to minimize the need for repackaging for shipment.
4.
Increased container handling and personnel exposure can be anti-cipated, consequently, all ALARA methodology should be incorporated per Regulatory Guides 8.8 and 8.10.
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