ML20023B125

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Forwards Comments on Waste Mgt Section of long-range Research Plan.Steering Committee Should Be Established to Coordinate High Level Waste Research Planning
ML20023B125
Person / Time
Issue date: 12/01/1982
From: Bunting J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Brown R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-6 NUDOCS 8212230126
Download: ML20023B125 (22)


Text

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MEMORANDUM FOR:

Robert S. Brown, Jr., Assistant to the Director and Chief Program Support Branch FROM:

Joseph 0. Bunting, Jr., Chief Licensing Process & Integration Branch

SUBJECT:

THIS YEAR'S LONG RANGE RESEARCH PLAN (NMSS 821104)

Our specific comments on the Waste Managernent section of the Long Range Research Plan are included on the attached draft.

We feel that the approach of identifying the regulatory need, the justification, and the research program description is a significant improvement over previous approaches. We would, however, offer the following general comments which we believe will further improve the presentation.

1.

The discussion of HLW issues which are DOE's responsibility and for which there is no NRC research planned should be deleted.

2.

The Justification sections should be more specific as to what research is required and why, and should draw on the the systematic research planning and coordination activity that RES has been conducting to define research to support HLW licensing, and on the schedules contained in the HLW Program Plan.

3.

There are misrepresentations of the lessons learned at Maxey Flats and other humid eastern sites.

Broad statements such as, " land burial facility design has generally proven inadequate for humid sites in the eastern U.S." are incorrect and overstate the problems at Maxey Flats.

4.

A Research Program Description section should be included after each Justification secti m.

This should include more specific l

identification of the research to be performed and the sequence of activities leading to the final product.

5.

There needs to be a stronger emphasis that NRC reraarch is not duplicating DOE efforts, particularly in the HLW area.

It is 8212230126 821201 PDR WASTE WM-6 PDR OFC :

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NAME :

DATE :82/11/30 I

414.4/MSK/82/11/24/0

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difficult to see the difference between DOE and NRC research when very general descriptions are given.

6.

References to Part 60 should clearly identify that we are basing the research program on the proposed technical criteria.

7.

References to Part 61 reflect a misunderstanding of the nature of the regulation.

The regulation is based on establishing performance objectives for the overall facility and individual components making up the facility. The regulation is not prescriptive and therefore did not attempt to define the "how to" for each section.

Examples of our concerns on the references to Part 61 have been noted in the markup.

l RES has recently suggested that a steering committee be set up for the HLW research planning and coordinating activity that they are conducting with our participation, since January,1982.

We believe that_this has been a well conceived and performed activity that should now be married with the staffs analysis of DOE's SCR's to ensure that our limited research resources are brought to bear on the issues most important to the successful accomplishment of NRC's role in the national HLW program.

We agree that such a steering committee be set up and are working with RES to do this.

We will meet with RES to resolve the comments documented in this memorandum.

It will be a task of the steering committee to draft the waste management portion of the LLRP in the future.

/I (a'

Joseph 0. Bunting, Jr., Chief Licensing Process & Integration Branch

Attachment:

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13.

WASTE MANAGEMENT Regulation.of radioactive waste management requires a technical capability to assess com;5liance of a waste management system with the regulatory requirements for operational safety, occupational radiological protection, and long-term,, / m "%o -

t waste isolation and to assess the risks associated with its operation [ The yi,g<.,

p sources of uncertainty in the assessment of compliance and risk differ in the I gas three program elements of high-level waste, low-level waste, and uranium recovery.

13.1 High-Level Waste High-level-waste (HLW) management involves the regulation of operational safety, occupational radiation protection, and the long-term isolation of HLW. mm 7 High-level radioactive wastes must be disposed of in compliance with standards and regulations established or to be established by the Environmental Protection Agency (EPA) and the NRC (40 CFR Part 191 and 10.CFR Part 60, respectively).

DOE, the licensee, is developing plans to isolate HLW in facilities to be constructed in deep ' geologic formations that will.be-

-ee nidered by 00E te comply with EPA and NRC regulatory requirements.

In licensing an HLW repository, the NRC will 4e required tc-assess whether DOE's j

license application l, if implemented, would comply with the4tandards and N s.e x

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regulation and "d"re ur.ccrtcintic; te cccept:bic levch. NRC's compliance

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assessment requires the technical capability to analyze relevant phenomena and Therefore, NRC needs a means of evaluating proposed safety and processes.

radiological health protection programs and the impact of the repository on A %c <.c the environment and of predicting whether41ong-term releases from the repository be il LL a m in compliance with established requirements.

No new c. ate m. pwg 4.55ess % ~ts s.4e Additicris? 1.icensing-criteric must be provided in the following six regulctory-3 4

areas in support of NRC authorization to construct the first HLW repository in, 1992 and'for NRC approval to emplace wastes in 1998.

11/01/82 13-1 LRRP SEC 13 1984

b 13.1.1 Major Regulatory Needs and Their Justifications

1. CompMwe.e. w s% oce a w Ti.wd it,=4.i 8..,ica l G fe D N%cTW C/ftYhY[forassessingwhetherengineeredfacilitydesignandoperational methods proposed by DOE for HLW repositories comply with para-graph 60.130(b)(9) of 10 CFR Part 60 and will provide occupational radio-logical safety protection in compliance with 10 CFR Part 20,-tc be uced 4cr acccccing i.ne appi kotien to canstvect the #Nt MLW repository-

-( FV 1999),

Justification The licensing staff must determine whether engineered facility designs and operational practices proposed by DOE will provide radiological safety in accordance with the requirements of 10 CFR Part 20.

Although the NRC has extensive experience in licensing, inspecting, and enforcing radiation g

health protection for reactors, the NRC has no similar experience related W VCOM.A.4 to a deep underground repository facility.

The underground facility will ib NffD pose unique considerations and health protection uncertainties related to MEW monitoring, waste emplacement, handling, ventilation, and accidental goggg releases that will require a limited amount of research for resolution.

QEcX5-The licensing staff must determine whether engineered facility designs and MM M operational plans proposed by DOE will comply with paragraph 60.130(b)(9).

Mince there are no existing repository facilities for HLW, neither the NRC EM NN nor DOE has operational experience.

Thus,(someresearchlwillberequired h*d I*

Mf6MM&lT to make NRC regulation experience with other licensed activities applicable q w yu, b e **Vt MW to the evaluation of the adequacy of DOE plans for operational safety es-

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& ':c!' 2c 00E p!:nc fer ccT.pliance 'fith the c deral Mine Safety and Health e

(W.1 l

Act of 1977-E. dowp\\t ance w th M E_P A R.ewiv ewe w'is Analytical methodology for evaluating the licens 3e's environmental reports to assess compliance with 10 CFR Part 51 and NEPa, to be used for assesstng DOE's final environmental impact staterient (FY 1988).

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11/01/82 13-2 LRRP SEC 13 1984 NNOI

Justification NEPA and 10 CFR Part 51 require that the licensee submit an environmental report' (ER) that will predict the impact of repository siting and operation on the environment.

NRC must develop analytical methodology tc, be able to evaluate the licensee's ER.

Existing data and experience do not provide reliable technical bases or methods to enable NRC to evaluate predictions of environmental impacts resulting from the unique character-istics of an HLW repository.

For example, the presence of substantial f

ge%Agfc mineral or petroleum resources at a potential repository site is considered M Y N& an unfavorable characteristic. Future exploration and development of en 9, ped e i.

resources at the site could compromise the integrity of a repository sited

-tu 56. 9 h there.

Present methods for exploring and characterizing the presence and 16 F I f extent of mineral or petroleum resources at a location typically involve extensive drilling.

Extensive drilling, even for exploration and charac-

"Ib W M a terization of a potential repository site, might compromise the ability be h u of that site to isolate wastes.

Hence, alternative methods to extensive uit c la r borehole drilling need to be investigated so that resources can be identified and characterized wit.h minimum possible disturbance to the site.

(In addition, methods need to be developed to allow the licensing process to deal with the uncertainties associated with predicting future changes in water supply and quality that might result from impacts of land use or long-term geomorphic and climatole'ical changes on the repository.

'a. IEomtovskr aweL Rebev4( d WasTc. keKg-carburg Ccitccia for assessing whether waste package, HLW facility design, and 3

operational plans will ensure that waste packages will be monitored t-e-ccepli 2~ a wi+h oncura

+he tag 3t;-"cr"- and can be retrieved, if neces-sary, in compliance with paragraph 60.111(b), te be =ed for assa:,:,iny the applicatier te cc= truct u.c Ti, at ::LU repetitcry (FY 102).-

Justification The proposed performance objectives of the technical rule for HLW disposal i

l (paragraph 60.lll(b)) would require that the repository be designed not to -

11/01/82 13-3 LRRP SEC 13 1984

Fowc los e.

2110t-the option of retrieval of any or all of the emplaced waste.

Spe-cifically, the design must ensure that the retrieval option is preserved use foranadequat.etimetojpermitanycorrectiveactinne chowntohonocos-)h" Ia additien, 2 dec i;;r ="e + 21:0 0110t1 fe" "epzir Or "ep! "a-aa+ -ni W

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-t. ho Ng feu"y "nic+ert and change: and "aplera-aa+ cf becP"M.

Finally, the h

E" N 7 design must be compatible with a monitoring program capable of measuring h

gelevantparametersandconditionsbyconfirmedmethods.

Researcil is needs wavt needed not only to enable the NRC to determine if the DOE's performance 4

confirmation program is capable of demonstrating whether the repository

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rt<,Tcw w T of will perform according to 10 CFR Part 60 and the EPA standard, but also to

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  • ts w ee.(.c-C provide the NRC with the analytical methodology in engineering and rock mechanics for evaluating the DOE's proposed retrievability plans to ensure Jhattheoptiontoretrieveispreserved.

4, W sTe M e,k.q x. Gow h h e M Methodology for assessing whether HLW package designs proposed by DOE will comply witt, long-term radionuclide containment requirements defined in S 60.113,.te-bewsed-for-assessing-the-app 14 cation-to-constrrct the "rst

-HtW-repos-i tory-(FY-1988):

Justification of The potential hazard posed by HLW will last se.ers thousand years.

The 5

Commission must haie confidence that the wastes will remain effectively b %. eict a re we e.4 by A s. e A 5 %d ue(

j selated fer-cuch len, pericd cf tims.J 51nce the performance of engi- -

og fiIeered systems, notably the waste form and waste package, are intended 5,cm t wlc.

to contribute substantially to that confidence, there must be assurance that the waste package arid waste form will initially contain and thereaf ter j (cor. trol the release of radionuclides over the period of hazard. flaboratory and field tests and experiments, even those lasting for decades, are of short duration compared to the long time at issue.

Hence, techniques are needed to allow extrapolation of the short-term observation so that expected performance over the long term can be predicted with confidence..

The licensing staff must assess the capability of DOE's proposed waste package designs to contain the wastes over long periods of time.

Research is needed to study and understand mechanisms of waste package degradation 11/01/82 13-4 LRRP SEC 13 1984

and failure.

Methods of examination and testing of waste package perform-ance that will allow scaling of short-term laboratory results to predict expected waste package life need to be established.

In particular, there is an~immediate need.to improve understanding of the phenomena affecting corrosion and fatigue of proposed metal containers in thermally perturbed geochemical environments under extreme physical stress conditions to reduce uncertainty in predicting waste package lifetimes.

NRC also needs the ability to assess and use models to make a licensing finding on the DOE design for compliance with the 1000 year postclosure containment criterion.

Licensing review will also include an assessment of the leaching charac-teristics of the waste form.

Since there will be no opportunity to observe actual leaching of radionuclides for a waste form over very long periods, the results of short-term tests will have to be extrapolated to thousands of years.

Further, the actual waste form will have undergone a thermal cycling lasting several hundred years before the leaching process isexpectedtobegin.hthodsofexperimentandtestingwillneedtobe Pnmovil j A

pd verparilMfdesigned to allow confident scaling of laboratory tests to these long 7

periods.[Thisisoneoftheperformanceareaswhereanindependent A d *"*4 judgment by the Commission will be critical to adequate confidence in the wax % k<-

,g,, g g expectad performance of the DOE proposed waste form.

g a egets ed.

5, Rok nu (& Re(cou hRe-_

N ibor assessing whether the engineered facility designs proposed by DOE will comply with the release rate criterion of.i 60,113 by providing backup retention of radionuclides that may be discharged from waste packages that fail, to be u d fcr essessirig the applicaticr. to cor.struct

-the first llLk' repssitary (I'.' 1000).

Justification The NRC must assess the licensee's engineered facility designs to ensure.

compliance with the release rate criterion of Part 60, i.e., following loss of containment the release rate of radionuclides must not exceed one part in 10 5 per year of the inventory present 1000 years after permanent closure.

NRC needs the capability to be able to ecdel the phenomena-that eo Lh m e.% -L~.t pre 4ci 11/01/82 13-5 LRRP SEC 13 1984

control the rate of radionuclide release from the facility, including contributions by waste form, waste container, overpack, and backfill.

Release rates involve large unresolved uncertainties as a result of the f

impact of thermal perturbations, geochemical environmental parameters, and o

very-near-field hydrological flow conditions on the performance of engi-.k neered systems.

There is a high priority need to resolve uncertainties ho concerning the solubility and leachability of waste forms at elevated 6

J temperatures and the anticipated geochemical and hydrological conditions k 3 of a closed repository. There is also a need to confirm the capability of Qg proposed backfills to control influx of water and sorption of radionu-clides released.

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4. l'ev [wma-ec. An etcwed i

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5 Cr..cria for assessing the reliability of the HLW facility designs

j proposed by DOE in conjunction with the natural geologic parameters of the sites proposed for the facilities to comply with the long-term specific radionuclide limits set by EPA (40 CFR Part 191), tc be used-fer ccresting

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the applic2 tier te conctruct the "rct HLY repccitory (FY 1038).

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Justification

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-b NRC must assess whether the proposed site and facilities will comply with

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e...a limits set by the EPA for cumulative releases of specific radioelements to A

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the accessible environment over a period of 10,000 years.

In order to f

establish a capability to predict radionuclide transport and to assess the I s.b licensee's transport models, the NRC must understand the geochemical-df hydrological interactions that control radionuclide transport in k

repository environments.

This % hen 4 4 Iwves uve.k<cecuvy q 3

requires development and verification of g

N v m.4 pg coupled gccchemicel-hydrological radionuclide transport models and models tr yg to predict t'he flow of water through fractured and porous zones in both 3

saturated and unsaturated rock.

Research will also be required to assess eMects the impact of the thermal Murbctica of the waste, site tectonics, stracteral geology, and rock mechanics on preexisting flow paths.

11/01/82 13-6 LRRP SEC 13 1984

13.1.2 Research Program Description a.(evst..d@ q L oc. pk.w em nei aw J poeecaer d Nato $ e *1

  • ait The strategy of the HLW research program is to develop 4a technical basis for

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assessing DOE license submittals for construction and operation of HLW

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repositories so that the NRC can ensure that long-term performance objectives of 10 CFR Part 60 and 40 CFR Part 191 are met.

Coordinated program efforts of laboratory and field experimentation, theoretical studies, and model develop-ment will provide an understanding of the processes and conditions that control the long-term performance of the system.

Relevant research sponsored by DOE, EPRI, DOI, OECD Nuclear Energy Agency, and foreign governments is being factored into NRC waste management research program planning in order to 4ved Aalimiete unnecessary duplication and to maximize research effectiveness.

ki M The research focuses ans dentifying and resolvin uncertainties pertaining to waste package and engineered system perfor e,

eochemical interactions with respecttoradionuclidemigration, ground-watertransportofradionuclides,7) effects on geological stability and isolation due to perturbation from excava-tion and impacts from emplaced wastes,)overall system performance modeling, 4

r) and long-term postclosure risks.

Thi's program also addresses monitoring g gc, methods for instrumentation reliability and plans for retrieving and repackag-n.ce.ua4 ing emplaced waste packages that fail or for other reasons require remedial actions before closure of the repository.

The major research products will be:

fo Prediction model for degradation of borosilicate glass waste forms based on surface kinetics (1984).

Final report establishing the relationship between quality conUol of o

container-manufacturing technolcgy and container characteristics (1985).

Model for predicting long-term performance of waste packages o

(including waste form, container, and overpack) (1988)

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11/01/82 13-7 LRRP SEC 13 1984

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l Final report on effects of oxidation state on radionuclide mobility o

(1985).

1 Hydrogeochemical model for assessing radionuclide transport processes o

I (1986).

l Report on field verification studies of radionuclide transport model 0

[1988)[

W Confirmation of the DOE prediction of radionuclide source term o

(composition and flux) released from proposed waste-packages 1988)}

O Methods for evaluating the long-term performance of backfill systems o

proposed by DOE K Final reports on methods for evaluating the effectiveness of borehole o

plugging and sealing (1984) and shaft sealing techniques (1987).

I Assessment of techniques f~r determining ground-water flow rates o

o (1984).

13.2 Low-Level Waste Low-level-waste (LLW) management regulation includes occupational radiation protection and protection of the general population from releases of radio-activity.

LLW must be disposed of in compliance with the NRC 10 CFR Part 61.

States are either writing compacts to establish new shallow-land burial sites that will serve regional LLW disposal needs or are planning in-state sites.

The NRC will be required to assess the compliance of license applications from non-Agreement States with NRC regulatory requirements.

The NRC will provide assistance to Agreement States so that they can manage and regulate land burial of low-levet wastes in accordance with NRC regulations.

In order to determine ~

compliance with radicactivity release limits, the NRC must model the phenomena and processes that affect the mobility of radionuclides.

The uncertainties in the compliance assessment determinations must be sufficiently small to make the 11/01/82 13-8 LRRP SEC 13 1984

,e Final report on effects of oxidation state on radionuclide mobility o

(1985).

hdrogeochemical model for assessing radionuclide transport proces o.

(1986).

Report on field verification studies of radionuclide transport model o

(1988).

o Confirmation of the C',

prediction of radionuclide source term (composition and flux) released from proposed waste packages (1988).

Methods for evaluating the long-term performance of backfill systems o

proposed by DOE (1988).

Final' reports on methods for evaluating the effectiveness of borehole o

plugging and sealing (1984) and shaft sealing techniques (1987).

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Assessment of techniques for determining ground-water flow rates o

(1984).

13.2 Low-Level Waste Low-level-waste (LLW) management regulation inciudes occupational radiation protection and protection of the general oopulation from releases of radio-C

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m c i e: s m.ct<,ntcn 1 ru m.. n< Is..J m.

...I e tw um ^ w cm activity.

-LEW-mustJ1e_Iiisposed UfTrtogrHance with the NRC 10 CFR Part 61,. {

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States are either writing compacts to establish new shallow-land burial sites g 6 :, j that will serve regional LLW disposal needs or are planning in state sites.

s, o f The NRC will be required to assess the compliance of license applications from

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non-Agreement States with NRC regulatory requirements.

The NRC will provide

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assistance to Agreement States so that they can manage and regulate land burial.' 3,,,

o of low-levet wastes in accordance with NRC regulations.

In order to determine _

compliance with radioactivity release limits, the NRC must model the phenomena and processes that affect the mobility of radionuclides.

The uncertainties in the compliance assessment determinations must be sufficiently small to -

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11/01/82 13-8 LRRP SEC 13 1984

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@ confident that release criteria are met.

Although the packaging require-A, ments of Part 61 are intanded to reduce the significance of the variety of characteristics and forms of LLW, nonetheless continuing development of chemical decontamination agents and water chemistry control :aethods causes the chemical characteristics of power plant wastes and the characteristics of subsequent solidification products to vary significantly from waste stream to waste stream as well as from batch to batch.

Thus, solidification materials (waste form) such as hydraulic cement, bitur.ien, and vinyl ester styrene need to be evaluated for these variations in specific characteristics with respect to solidificat~.'n effectiveness and product performance.

Further, the NRC must establish adeouate methods and procedures to cetermine compliance with criteria specifir.d in 10 CFR Part 61, or imposed on generation of wastes through license conditions, on waste classification, waste stability, site selection, facility design,e operational and postclosure monitoring,anrf nrctecti - cf the.nouvercent.'

Q W.

Finally, NRC.nust be able to determine compliance with 10 CFR M

Part 20 criteria on occupational radiation protection, as well as to accommocate the constraints imposed by transportation safety on waste form and waste r;

packaging.

13.2.1 Maior Reculatorv Needs and Their Justifications 1.

Evaluation of.the applicability of NRC's existing data bases for determin-ing whether land disposal facility designs and operational practicos proposed by the applicant will provide adequate protection from radiation (FY 1986).

Justification The licensing staff must determine whether engineered facility designs and operational practices proposed by applicants will provide radiolo ical v'

MP:d in accordance with the requirements of 10 CFR Part 2 A

ough the NRC has extensive experience in licensing, inspecting, and enforcing.

ridiation health protection for-reactors 2nd fuel c3cb fm.iiii.ivt, the criteria proposed in S 61.52 may necessitate NRC assessment of ee ntohhg ncd handling and disposal techniques for LLW with regard to operational M

radiation health and safety.

'M Thus, a limited amount of operational safety 11/01/82 13-9 LRRP SEC 13 1984

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research will be needed te arsess tn n pelicabilii.y vi existing uoto L a:, m "to improve NRC's capability to evaluate the adequacy of the applicant's plans.,

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2.

Analytical methods for evaluating environmental reports from licensees to determine compliance with 10 CFR Part 51 and NEPA (FY 1986).

Justification NEPA and 10 CFR Part 51 require the licensee to submit an environmental report that will predict the impact of land disposal facility. siting ano operation on the environment.

NRC must develop analytical methods to be able to adequately evaluate the licensee's environmental report. -0;t md avnarience indicate that existing mepods to enable NPr te cvahete pram cti er.: cf cna renment;l impac* *acnitirc # cr land Luiiol ;ites may be %2dequit; for--hen.iu sites i rrthe-Ee s + a rn -United Statc;.

Tii1Giest "all y, "=cy M att, and-Sheffield cites haue had Ori;b givbiems Inat led te pr:matue: c i te c+os ure-3.

Methods and procedures for determining the classification of LLW, to be fg used in evaluating applicants' classifications (FY 1986).

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Justification pf0dp9' g u,'b '

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N') c $g Section61.55dividesLLWintothreeclassesdependingontheradio] isotopes

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present and their activity.

The regulationii; :::t_i" g:ncial terms,and pre-cr <,> b M rep o w ns75 i r c/cre te for_elch b O M I does not provide detai' led guidance to staff or applicants #

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_ example, in O

p a ra g r a p h 61. 55 ( a ) ( 8 ),gt$};..:n...

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,e reguht'ic-i=

=t explain how indirect methods may be employed to estimate radionuclide concentrations in LLW or the i, M e<c e mvel of confidence expected by the NRC.

Therefore, research is needed u

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(1) to provide 7 guidance to applicants on meeting the requirements of Q

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7s 661.55and(2)toprovidfnicguidance for staff evaluation of applicants' Y [- {

ethods for waste classification.

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15/01/82 13-10

'p LRRP SEC 13 1984

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-1 4[# phods and procedures for determining the stability of packaged low-level I,'

waste to be used in evaluating applicants' methods for ensuring stability p

ds (FY 1987).

Justification e

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Section 61.56 specifies a series of minimum requirements to ensure LLW Ystability. --Thw uietion -is-writterw s

wi-el Wrms-and d e ui.~ N Ag

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"'/ provid" detailed gu idance -i.o-~ staff or appMeants.

One example of where o

'\\b C more detailed guidance is desirable is found in paragr3ph 61.56(b)(2),

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.I' T which is concerned with the reduction of liquid in waste packages.

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g this requirement immte applyr.s; For a

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g example, chemical degradation of the waste package after sealing may w<

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,ti-C\\,d produce liquids.

Acceptable methods for removing the liquid or methoas

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' for stabilizing the waste so that free liquids do not originate from wcuNwd WcMC M l y

\\ degradation of the package,.,,.e <.- a,.,e indicated.

Also,,the level of

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/ confidence required in the demonstration of this criterion sho id-be:c' s ( c ju i

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s;x:':d buf M tit"; 'J4 i} ;hal&be. -ebi v

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.Y Y,g Therefore, research is needed (1) to provid guidance to applicants on 3

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'n vcl *.on l ipi meeting the requirements of S 61.56 and (2) to provid guidance for staff W 'JA

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evaluation of applicants' methods for ensuring waste stability.

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5.

Criteria for assessing the suitability of sites for land disposal of LLW pug 4

to ensure protection of public health and safety, to be the basis for g n j.,.,. y".,,,./ determining compliance with 9 61.50 of 10 CFR Part 61 (FY 1986).

Justification For near surface isposal of LLW, S 61.50 cifies a series of

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characteristics-tha site must a e.

However, the regulation does not f

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provide detailed guidanc (1) how an applicant is to demonstrate that 4.,'

thep al'e met, (2 e NRC 1ssto evaluate whether or not they are met, b'>.s and (3) th 1 of confidence required to demonstrate protection of public health and safety.

Researchisneeledtoprovidethisguidance.

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11/01/82 13-11 j

LRRP SEC 13 1984

6.

Criteria for assessing the acceptability of facility designs for land disposal of LLW, to be the basis for determining compliance with S 61.51 of 10 CFR Part 61 (FY 1986).

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Justification Ler.d L. i al.'o e i l i t, um. 3m hc; pre >cd g^^^"*" 4"'h a"=+o fnr hunid

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d t:: '- th: S:t:r-Urited Ctaten y

~Research at Maxey Flats, Kentucky, 4

showed that water entered trenches through the trench caps.

Trench cap l

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subsidence has resulted from degradation and compaction of waste packages, inadequate waste burial procedures, and inadequate trench cap designs gg[

Futurelicenseeswillneedtouseimproveddesigns.hhe RC must condu t' (eg esearch on' evaluating faci ty design to ablegdete

'ne c&mpliance %

with criteria in 6 61.51, as Well as to se,ek further in1provemen in Ne safetb of designs.

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7.

Criteria for assessing the acceptability of environmental monitoring plans for the preoperational, operational, and postoperational periods and for evaluating the data, results, an'd conclusions from the monitoring programs, to be the basis for determining compliance with applicable regulations (iY 1986).

Justification Although the NRC has developed monitoring criteria for reactor sites and fuel cycle facilities, the pathways from land burial facilities are sufficiently different from the pathways at other~ nuclear facilities th-t different monitoring strategies and procedures may be needed.

In particular, monitoring will be needed to detect radionuclide migration through unsaturated and saturated soil.

Research on statistically valid ground water monitoring is needed so that NRC will be able to ensure compliance wi;h applicable regulations.

8.

Methods for the design, operation, and closure of a land tohmuL.

disposal facility t at will ene see the protection of any individual l

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11/01/82 13-12 i

c LRRP SEC 13 1984 k9 3

inadvertently intruding into the disposal ' site, to be the basis for

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developing regulatory guides (FY 1988).

Justification l

The NRC has limited experience at prote: ting inadvertent intruders..The

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criteria in S 61.42 do not specify how the inadvertent intruder is to be protected.

Sections 61.55 and 61.56 establish several criteria relevant to inadver. eat intruders, but these criteria are not sufficient in themselves to ensure the protection of an inadvertent intruder.

Researcn needs to be conducted to identify methods and requirements appropriate for protecting an inadvertent intruder.

9.

Methodology for determining the concentrations of radioactive material that may be released from a land burial site to the general environment will meet the criteria in S 61.41 of 10 CFR Part 61, to be useo.in evaluating applications (FY 1986).

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Justification In order to determine whether the criteria in S 61.41 are met, the NRC needs to establish methodology for predicting radionuclide transport and assessing the licensee's transport models.

The NRC must understand the geochemical-hydrological interactions that control radionuclide transport in land burial sites.

This requires development and verification of coupled geochemical-hydrological radionuclide transport models to predict 3bl/

transport through both saturated and unsaturated assah The NRC must also be able to assess the geochemical and hydrological parameters used in the applicant's transport models in order to have confidence in the model's output.

10.

CriterTa for assessing alternatives to shallcw-land burial of low-level wastes, especially for wastes that have higher concentrations than are acceptable for Class C wastes, to be the basis for rulemaking, developing i

regulatory guides, and evaluating applications (FY 1988).

11/01/82 13-13 LRRP SEC 13 1984

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Justification Et

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)%Cf c 4; h *j Part 61 does not yet address the site spitability requirements for land

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di.sposal other thab near surface.

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% ;t disposal, deep-w? k disposal, and. m' c

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' "greatcr ca.Jinemeni facMity for 01 cc: C ard C waster.

ResearcY

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eeded (1) to determine site suitability requirements for such alternative methods of LLW disposal, (2) to provide guidance to applicants on accept-c

  • I hablemethodsofdemonstratingsitesuitability,and(3)todevelopmeans

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for staff evalution of site suitability.

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Research Procram Descriotion

.v'I The strategy for research is to use field data and laboratory experiments to model the phenomena that determine the performance of LLW disposal facilities.

This will be usefu' in providing guidance to disposers of LLW and assessing compliance with NRC requirements and in evaluating the resulting level of protection achieved relative to public health and safety.

While the LLW research program is primarily directed towards shallow-land burial, i.e., to support the regulatory requirements of 10 CFR Part 61, it also includes research related to alternatives to shallow-land burial which is w s,+v 9 c s ccea n he b u,.

V particularly relevant to the disposal of Class C low-level wastes. t >

The program also studies the problems identified through experience with existing LLW disposal facilities in order to evaluate and resolve the important uncertainties.

In particular, the LLW research program is developing information that can be used to establish criteria for long-term trench cap stability, water infiltra-tion through trench caps, ai d waste form degradation (which will reduce trenc failure).

It will identify means for meeting the criteria and for minimizing uncertainties associated witn.he release of radionuclides into the unrestr environment.

In addition, it is determining (1) the chemical changes that occur when radioactive wastes interact with soils, (2) the species of radio-nuclides that migrate through soils, and (3) the nonradiologic hazardous

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chemicals that are contained in or accompany low-level wastes.

It will both 11/01/82 13-14

' LRRP SEC 13 1984 I

I L

test the chemical composition of wastes and develop data on materials that could be added to disposal trenches to fix or retard the movement of radio-nuclides..,The research will develop and test geochemical / hydrological transport

)

models for predicting water movement and radionuclide attenuation in this-water -

for the various media through which it may pass.

Effectiveness and reliability of methods for monitoring releases of radioactivity to the unrestricted environ-ment are important elements being tested.

Information is being developed to i

f provide technical bases for establishing eiltep.t levels of radionuclides in(

,o#}/ c s wastes below which regulatory action wo + e., vn q cru a & cg c m hc e.

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uld not be necessary.

An assessment ~of { go existing information, input from the research cited above, and studies of (MF existing facilities will be used to develop criteria for decommissioning LLW A'.

mCA disposal facilities.

Major research products will include:

Evaluation of the radionuclide containment characteristics of and o

criteria for volume reduced wastes (1986).

Assessment of alternatives to shallow-land buriai of LLW (1988).

o Assessment of the interaction of radionuclides with soils to predict o

LLW disposal facility performance (1985).

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  • t,dM ~ c: r Coupled geochemical /hydrologica,l transport mod is 'f'. --

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o or predicting A

subsurface migration of radionuclides from shallow-land burial facilities (1985).

7 Do ament providing technical basis for establishing exempt levels of o

radioactivity in LLW (1986).

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a Assessment of nonradiologic hazardous chemicals that are contained

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o in or accompany LLW (1984).

r Assessment of methods to ensure trench cap stability (1984).

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13.3 Uranium Recovery Uranium recovery operations involve the extraction of aranium from ores by both conventiondl and in situ solution mining techniques.

These operations result in the generation of large quantities of liquid and solid wastes that contain naturally occurring radionuclides and toxic chemicals. These wastes must be disposed of in compliance with regulations established by EPA and NRC (40 CFR Parts 190 and 192 and 10 CFR Parts 20 and 40, respectively).

In licensing uranium recovery operations, the NRC must assess whether an app'i; ant's proposed treatment and disposal of such wastes will comply with the above regulations.

NRC's assessment requires the technical capability-to analyze relevant phenomena and processes in a manner that minimizes uncertainties that might lead to excessive and unreasonable costs and restrictio~ns.,ut. L 'ats

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xp... - n m n 13.3.1 Maior Reculatory Needs and Their Justifications 1.

Criteria for evaluating the long-term stability of waste tailings retention systems following the, closing of mills arid the deco.,missioning of mill sites, to be used as a basis for updating a regulato.v luide (FY 1985).

Justification.

NRC and EPA regulations -(10 CFR Part 40 and 40 CFR Part 192, respectively)

^

require waste tailings generated from uranium recovery operations to be s

stabilized for long periods of time E r d:T, 7 following milling operations.

Present engineering capabilities do not include methods for predicting the long-term stability of riprapped earthen structures without significant maintenance.

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. v Criteria for eval,uating more accurately and cost effectively the quantities

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i ed A,./s and impacts of airborne effluents from uranium recovery operations and methods for minimizing such effluents, to be used as a basis for regula-

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tory guides on interim methods for stabilizing tailings piles (FY 1984)

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and on atnospheric dispersion data acquisitior., reduction analysis, and-reporting requireme_nts_(FY 1985).

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Justification NRC regulations require airborne effluents from active uranium recovery operations to meet the requirements of 10 CFR Part 20 and EPA's 40 CFR Part 190.

Such releases must also be evaluated as to quantity and environmental impact in accordance with the provisions of NEPA.

ffe Criteria for better evaluating the. seepage and underground migration of j

waste liquids from conventional uranium milling operations and the liquid leaching solutions used during in situ mining activities, to be used as bases for regulatory guides on methods, data, essumptions, and models for predicting ground-water transport of toxic or radioactive materials (FY 1983) and on methods and requirements for designing, constructing, testing, monitoring, and closing wells at in situ uranium solution mining sites (FY 1984).

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Justification The seepage and migration of such liq" ids and solutions must be minimized and controlled so as to meet the requ rements in NRC and EPA regulations (10 CFR Part 20 and 40 CFR Part 190, espectively).

The environmental impact from such seepage and migrat'on must also be analyzed in accordance with NEPA requirements. '> mE 4 > /i M J4 wu 'J; J b 4"*e i

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4.

Criteria for more efficiently and cost effectively measuring residual concentrations of radioactive constituents following reclamation and decommissioning of uranium recovery sites, to be used as a basis for a regulatory guide (FY 1985).

Justification NRC regulations require compliance with environmental cleanup standards to be contained in EPA's 40 CFR Part 192.

11/01/82 13-17 LRRP SEC 13 1984

13.3.2 Research Prooram Descriotion The strategy for the research is to reduce the uncertai ti models currently used in regulatory assessments to analyze (1) t es in methods and n

stability of reclaimed uranium tailings piles, (2) seepage f he long-term systems, (3) migration of liquids used for in situ solution mi irom active ta (4) environmental impacts from airborne radioactive n ng, and

.A effluents from uranium recovery operations.

testing analytical methods, and developing predictiveThis

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to expedite and i.:1 prove the efficiency of licensing models,that can be used to reduce conservatismsi reviews and assessments and I

better environmental impact assessments relating to ura I. 7" are provided.

n um recovery operations 6

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This research program develops methods for analyzing th U

of riprap for the long-term mitigation of wind and water ere design and appli of stabilized uranium mill tailings piles.

osion of the covers being developed to predict the underground migration a d iIn addition both conventional tailings disposal operations and in mpact of seepage from

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n Finally, improved monitoring methods and equipment fositu so operations.

releases of radioactive and toxic materials from nranium r assessing are being developed and tested.

recovery operations guidance on monitoring requirements and strategies for ev with EPA and NRC standards.

ng compliance to be completed by 1988 unless unforeseen needs or eMost of meantime.

vents develop in the The major research products are:

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Engineering guidelines for installation of riprap covers (198 ;

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,.r Procedures for measuring yellowcake emissions from ventil ti o

a on systems to be develop \\

ed and tested (1984).

I Measurement techniques and UMTRCA remedial action (1984) o t

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11/01/82 13-18 LRRP SEC 13 1984

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.r Sampling techniques for detecting contamination of surface and ground o

waters by tailings leachate (1985).

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47c./,rfes (cr Vlins'an//,)' $4s 3 /lw/etier hrsud, EidJ rcpf. + nn Hauete ring-techniques-(498+)-

o Final report on field studies on candidate interim stabilization o

techniques (1985).

Models for predicting the subsurface migration of liquid wastes from o

uranium recovery operations to be developed and tested (1988).

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