ML20012D633
| ML20012D633 | |
| Person / Time | |
|---|---|
| Issue date: | 03/21/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Carr, Roberts, Rogers NRC COMMISSION (OCM) |
| References | |
| IEIN-90-009, IEIN-90-9, NUDOCS 9003280156 | |
| Download: ML20012D633 (1) | |
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MAR 21'1930 i
MEMORANDUM F0iu Chairman Carr Commissioner Roberts-
. Comissioner Rogers Comissioner Curtiss Comissioner Remick FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
STORAGE Of LOW. LEVEL RADI0 ACTIVE WASTE BY FUEL CYCLE AND MATERIALS LICENSEES j
g In a Staff Requirements Memorandum'(SRM) of February 14, 1990, the Comission 1
directed the staff to "... ensure that in the process of preparing guidance on i
on-site storage of low-level waste by HRC licensees and in evaluating such proposed storage, licensees be advised that the Commission will not look favorably upon long-term on. site storage beyond January 1,1996.*
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'On February 5,1990, th9 staff issued Information Notice 90-09, " Extended c
Interim Storage of Low. Level Radioactive Waste by Fuel Cycle and Materials Licensees"(Enclosure). This notice provided guidance to licensees planning to submit license amendment requests for extended interim storage of waste.
l Although the notice was issued before the SRM, the staff had anticipated the need to discourage long-term storage beyond 1995. The notice states that storage is not a substitute for disposal, and that waste should be stored only when disposal capacity is not available and for no longer than necessary, t
Also, the notice states'that license amendment requests should include final disposal plans that specify when and where waste will be shipped for disposal, and that-storage authorizations will not normally be granted for more then-five years. This is consistent with discouraging long-term storage beyond 1995.
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'In processing amendment requests for long-term storage by materials licensees, the staff will ensure that any proposal for long-term waste storage beyond 1995 i
'is carefully reviewed by Headquarters management before final action.
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= eJ R The staff is also coordinating with the Office of Governmental and Public '
e l - du Affairs to> issue a letter to Agreement Statesgnona}ng gem of the Commission's!
dvi LJg view on. storage beyond January 1,1996.
f om 3 4
,ye James M. Taylor 3,
i James M. Taylor-5
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1 8m Executive Director' '
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- ~ n, UNITED STATES NUCLEAR REGULATORY C0m!S$10N 0FFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C. 20555 February 5, 1990 i i i NRC INFORMATION NOTICE NO. 90-09: EXTENDED INTERIM STORAGE OF LOW-LEVEL f RADI0ACT!YE WASTE BY FUEL CYCLE AND i MATERIALS LICENSEES Addressees: 5 All holders of NRC materials licenses. purpose i \\ This infomation 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- + vious y srovided guidance on storage of LLW at nuclear power plant sites in Generic.etters 8148 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 infonnation notice, distribute it to management and r 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 infonnation notice is required. - Description of Circumstances: t The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA) estab-lished a series of milestones, penalties and incentives to ensure that States i or Regional Compacts make adequate progress toward being able to manage their i 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 cr 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 i in accordance with NRC re months to several years. quirements may be necessary for anywhere from several Discussion: Not all licensees who will need to store LLW onsite will need amendments to their i licenses to do so. However, if the possession limits specified in a license need l - to be increased to allow storage, or if the terms and conditions of a license t ENCLOSURE k f h
.y 4Rq..J ,s.- J IN 90-09 l l' February 5; 1990 Page 2 of 3 o. 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-Nell.as'to persons considering applying for a license to construct a centralized ' storage facility to receive waste from others until State or Regional disposal 4 capacity is available. The following considerations are central to extended storage, and are the basis of the information included in Attachment 1. i
- 1... Storage is not a substitute-for disposal. Other than storage for radio-active decay, LLW'should be stored only when disposal. capacity is
't unavailable and for no longer than is necessary. Licensee planning should consider a specific date by which storage will=end and disposal of the l' r 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 l reassessed before disposal. 3. To-ensure integrity of packaging and maintenance of waste fom, 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 L or remote) inspection on a routine basis. Licensees should plan to conduct and document such inspections at least quarterly. 5.1 Depending on the specific waste involved, licensees may need to have procedures and equi) ment in place or readily available to repackage the waste, should tie need arise. 6. Decomposition and chemical reaction of incompatible waste materials over i . time can result in gas generation or other reaction products. Licensees it 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 fonns, 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, s
q ~ IN 90-09 February 5, 1990-Page 3 of 3 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, i L If you have questions about your State or Regional Compact, a list of contact persons is provided in Attachment 2 of this notice, l Questions on your specific license or general procedures for license amendments and reviews related to extended interim storage should be addressed to the a)propriate NRC regional office or, in the case of fuel cycle licensees, to tie Division of Industrial and Medical Nuclear Safety in~NMSS. h U l b b:m w m ~ Richard E.-Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical
Contact:
George Pangburn, hMSS (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. =
..3 IN 90-09 February 5, 1990 Page 1 of 3 l INFORMATION NEEDED IN AN AMENDMENT REQUEST TO AUTHORIZE l l EXTENDED INTERIM STORAGE OF LOW-LEVEL RADI0 ACTIVE WASTE l 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. L 1. D b. Identify the estimated maximum amount of LLW to be stored, both in [ terms of volume and activity, by radionuclide. L c. Characterize the LLW to be stored:
- 1) Volume of waste by Class (A B, or C) 2)- Physical fonn 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. Identify any additional permits or approvals necessary for storage e. (i.e.,EPAhazardouswastepermit,Stateorlocalapprovals,etc.) and the status of each required approval. 2. Plans for Final Disposal Specify when disposal capacity will no longer be available to you a. 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. Specify when you will begin shipping LLW to that facility and how c. long it will take for your estimated storage inventory to be moved out.
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'1 i IN 90-09 u February 5, 1990 9 Page=2 of 3-1 \\ 3. Physical Description of Storage Area .1' L a. Identify the location and provide & diagram of the LLW storage area-L which demonstrates where packages will be stored and how packages i b 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 c stored and demonstrate that the waste will be protected from weather at all times, j d. Describe the measures to control access to the LLW storage area and i 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 - "t sture and humidity on waste and waste containers will t* t - ' h. Describe vulnerability to other hazards such as wenado, 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 equipnent (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. ---.l -- ,---e
, =,, ? ' Attachment 1 ~IN 90-09 February 5; 1990 Page 3 of 3 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, Describe your procedures for responding to emergencies.-including c. 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' Describe your program for training personnel in procedures-for a. i, packaging, handling, placement, inspection, surveying and emergency response for LLW storage. 7. Financial Assurance . Review the relevant sections of Parts 30, 40 and 70 regarding financial' a. assurance for decomissioning. 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 decommissio certification of financial assurance, as appropr.ning funding plan or, iate. In either case, this submittal should demonstrate that financial resources are or will be in place not only to decomission the licensed operation, but also to provide for the estimated costs of handling, transport and ultimate L disposal of all LLW stored onsite, j 8.- Emergency Preparedness Review the relevant sections of Parts 30, 40 and 70 regarding emergency a. 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. i -_,_---..-,----w
( q 1 /. .c IN 90-09 February 5, 1990 Page-1 of 4 4 REGIONAL COMPACTS AND UNAFFILIATED STATES t 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 a Protection + Department of Environmental Resources b Commonwealth of Pennsylvania 1 P.O. Box 2063 L Harrisburg, PA 17120 717/787-5028 (Member States are' Pennsylvania Lhost State). Delaware,MarylandandWest i Virginia.) ' Central Interstate Compact Ray Peery Executive Director i 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, i and Ok13homa.) Central Midwest Compact Clark Bullard Chair, Central Midwest Compact Comission Director, Office of Energy Research University of Illinois 901 South Matthews Urbana, IL 61801 217/333-7734-(Member States are Illinois [ host 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
. ~.... . ~.. yG " > < [ iAttachment2-L IN 90-09 1 February 5,71990~ Page-2 of-4 1 '~e m (MemberStatesareMichigan[ host-Statej, Iowa Indiana, Minnesota,- . Missouri.0hioand. Wisconsin.) Northeast Compact Denise Drace ll Executive Director Northeast Interstate Radioactive-Waste Compact Comission ~ D 195. Nassau Street, 2nd Floor Princeton, NJ 08540 609/497-1447 (Member States are Connecticut and New Jersey,-both of which are host States.) o - 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 Comission 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.) .m ~, --,-r
{ ..,4-y z-s a J o -IN 90-09 February 5,1990-Page 3:of 4 I Southeast Compact-Kathy Visocki. Executive Director Southeast' Compact Commission' 3901-Barrett Drive,. Suite 100 Raleigh..NC 27609 919/781-7152' 4 [(currenthost~ State], Alabama', Mem 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 Hamoshire 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
9:.;,3 'a l ~
Attachment:
2 1 IN 90-09 j February 5, 1990 Page_4 of-4 I J .New York . Jay.Dunkelberger.- Executive Director. J
- o Low-Level Radioactive Waste' Siting d
Comission l State of New York-m'~ 1215 Western Avenue, Suite 306 i Albany, NY 12203. 518/438-6130 Puerto Rico Santos Rohena Chair r 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 L-Providen:e,-RI 02908 401/277-3434-Vermont- -Jonathan Lash ~ E Secretary Agency of Natural Resources State of Vermont 103 South Main ) Waterbury..VT 05676 802/244-7347 i p Texas Lawrence R. Jacobi General Manager L Low-Level Radioactive Waste Disposal' Authority State of Texas 7701 North Lamar Boulevard, #300 p Austin, TX 78752 512/451-5292 l 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 pursuin
-arrangements independently. g LLW disposal capacity or other LLW disposal a}}