ML20035C326
| ML20035C326 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1993 |
| From: | Uleck R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9304070057 | |
| Download: ML20035C326 (8) | |
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4 UNITED STATES 7
NUCLEAR REGULATORY COMMISSION 8
.E WASmNGTON, D. C. 20555
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MAR 311993 MEMORANDUM FOR:
Paul H. Lohaus, Chief Low-level Waste Management Branch Division of Low-Level Waste Management and Decomissioning, NMSS THRU:
James E. Kennedy, Section Leader Licensing and Coordination Section Low-level Waste Management Branch 1
Division of low-Level Waste Management and Decommissioning, NMSS FROM:
Ronald B. Uleck, Project Manager Licensing and Coordination Section Low-Level Waste Management Branch Division of Low-Level Waste Management and Decomissioning, NMSS
SUBJECT:
MEETING WITH MAINE LOW-LEVEL RADI0 ACTIVE WASTE AUTHORITY OFFICIALS The Nuclear Regulatory Comission staff met with representatives of the Maine Low-level Radioactive Waste Authority (Authority) oi December 1,1992, at NRC Headquarters, in Rockville, Maryland. Meeting participants and attendees are listed on the enclosed sign-up sheet.
The purpose of the meeting was to discuss the applicability of NRC regulations in 10 CFR Part 61 to an above-ground vault (AGV) disposal facility, the choice of the State of Maine. NRC staff had provided written coments in a letter dated September 14, 1992, to the Authority on Maine's Conceptual Design Report, Revision 1, April 1992, which describes four conceptual designs for a LLW disposal facility in Maine. Following the NRC staff review of the Maine design report, John Williams, Executive Director of the Authority, in a letter dated November 3, 1992, to NRC, responded to NRC's review and requested further discussion on the AGV concept and its conformance with Part 61 requirements.
Mr. Williams then briefly described the status of the State's site selection process and the State's need for additional guidance on Part 61 and the AGV design concept.
He said that the Authority has identified 12 potential sites for a low-level radioactive waste (LLW) disposal facility. As part of the site screening process early in 1993, the Authority will use certain site characteristics, facility design and operations concepts, and other criteria to further reduce the number of potential sites for more detailed Jk 'k '
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consideration.
The Authority requested feedback from NRC. staff on whether an f
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AGV concept was worthy of future consideration or whether the Part 61 compliance issues were so significant that further consideration of the AGV i
concept was not warranted. The various issues-and NRC's' feedback on them are discussed below.
j Mr. Williams and other Authority officials noted that the State banned the shallow land burial method, largely because of high water tables and shallow glacial-soils that pervade the State. The Authority, Mr Williams said, has.
looked at the Canadian experience in managing LLW and feels that some of the -
methodology used there may also be applicable to Maine because of the similarities in environmental conditions between Maine and Canada. Authority officials also stated that there is strong public concern about siting an LLW disposal facility in Maine and that an AGV concept mitigates some of these concerns.
t The Authority officials then identified the following issues related to AGVs which were raised in the NRC staff's review of the Maine Conceptual Design Report:
long-term maintenance and institutional control; theft and intrusion; modeling; monitoring; waste stream in Maine; and retrievability. Discussions between Authority officials and NRC staff on these issues are summarized in.
the following paragraphs.
In discussing long-term maintenance and the institutional control period, Authority officials said that Maine plans to use certain types of maintenance-activities beyond 100 years after facility closure.. NRC staff commented that l
if Maine wanted to use custodial or active maintenance activities for periods longer than 100 years following transfer of control of the disposal ~ site to the owner jtnd take credit for such care or maintenance in a license 5'
application, then Maine would'need to apply'for-an exemption from 10 CFR 61.59(b), which-requires that institutional controls, which would be required if any activities are planned or scheduled for the facility, may not be relied -
upon for more than 100 years following transfer of ownership.
In addition, if
. ongoing. active maintenance activities were proposed for the post-closure l
period,- Maine would also'need to apply'for an exemption from 561.44 and 161.51(a)(1), which-require the elimination of.the need for ongoing active maintenance following site closure.
NRC staff cautioned that, although Maine may apply for an exemption from any of the requirements of 10 CFR Part 61, the granting of an exemption depends upon the merits of.the exemption and is not an automatic NRC procedure.
If a license applicant applies for an exemption from a requirement of Part 61, NRC would review the application for the exemption and may grant the exemption if it determines that life or property or the common defense and security will.
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4 Paul H. Lohaus i not be endangered, and is otherwise in the public interest. With resr to an exemption allowing active maintenance following site closure and/o 100 years after closure, the applicant would have to demonstrate that long-term active maintenance would also not adversely affect any other licensing requirement of Part 61, including the ability of the engineered structures, the site and any other conditions of the disposal facility to meet the performance objectives of Subpart C of Part 61.
The AGV design with continued active maintenance, Authority officials noted, would limit occurrences of theft and intrusion. Further, they said that the AGV design provides the opportunity for visual inspection and monitoring of the waste, a condition that the Maine public understands and accepts. They also said that the AGV concept facilitates retrievability of the LLW for recycling or other purposes, a condition that Maine wants to incorporate into an LLW disposal facility. NRC staff noted that Part 61 does not prohibit retrievability in a disposal facility, and in a license application where retrievability is a planned activity or option, the applicant would still need to meet the disposal site closure and long-term stability requirements of Part 61.
Discussions about the waste stream in Maine and performance assessment modeling raised several key poiris about the State's LLW program.
- First, i
Authority officials stated that the relatively small source term in Maine -
about 13,000 curies - will likely help in siting, since a small site of about 5 acres could probably accomodate that amount of LLW. Additionally, they expressed the opinion that the design features of an AGV help reduce unknowns and uncertainty in modeling. NRC staff noted that all waste anticipated at an LLW disposal facility, including long-lived radionuclides, would need to be considered in the performance assessment to demonstrate that the performance objectives under Subpart C of 10 CFR Part 61 will be met. The staff also stated that a performance assessment would be needed for periods beyond 500 years, to show that dose from residual activity and potential environmental mobility from the long-lived radionuclides would not exceed the performance objectives. The staff also stated that since engineered structures degrade over time, an applicant may have difficulty taking credit for any waste isolation' capabilities of engineered barriers for periods longer than a reasonable time (e.g., greater than 300 to 500 years).
Meeting participants also briefly discussed several other areas.
NRC staff notes that the site suitability requirements in 10 CFR 61.50 would likely be generally applicable to an AGV even though these requirements were developed for near-surface disposal facilities, not AGVs. The staff recommended that the Authority, in addition to considering 661.50 site suitability requirements in the site screening process currently underway, also anticipate if additional technical criteria, such as meteorological conditions, would be important to ensure the safe performance of an AGV disposal facility.
4
Paul H. Lohaus Authority officials expressed interest in the possible use of the Maine Yankee-nuclear power station site for LLW disposal or temporary storage until a suitable disposal option is available. NRC staff commented that if the Maine Yankee site was used for an LLW disposal or temporary storage facility, the applicant would need to demonstrate that all safety and environmental requirements for both the disposal / storage facility and the nuclear power station will be met.
Authority officials said that these discussions had been useful in helping the State implement its LLW program.
OREliW. WED BY Ronald B. Uleck, Project Manager Licensing and Coordination Section Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosure:
Meeting sign-up sheet oc w/ encl:
J. Williams, Executive Director Maine Low-Level Radioactive Waste Authority DISTRIBUTION:
Central File NMSS r/f R3angart TMassey WBrach ME - LPDR JAustin TFish, R-I RSLO JSurmeier Meeting Addressees PLohaus (See Attachment)
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Paul H. Lohaus Authority officials said that these discussions have been useful in helping the State implement its LLW program. They requested a point-of-contact at NRC for continuing regulatory consultation which may be requested through John Williams of the Authority. NRC staff also felt that these discussions are s useful, and said that an NRC staff member would be assigned the point-of-
\\ contact.
[ Note: Mr. Robert Nelson, Project Manager, Division of Low-Level kaste Management and Decommissioning, is the NRC point af-contact with the Adthority. He can be reached at NRC Headquarters in P& kville, Maryland, at (301 504-2004.]
Ronald B. Uleck, Project Manager Licensing and Coordination Section Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning, HMSS
Enclosure:
'N Meeting sign-up sheht cc w/ encl:
J. Williams, Executive rector Maine Low-Level Radioacti e Waste Authority DISTRIBUTION:
Central File HMSS r/f RBangart TMassey WBrach ME - LPDR JAustin TFish, R-I RSLO JSurmeier Meeting Addressees PLohaus (See Attachment)
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Paul'-H. Lohaus. Authority officials said that these discussions have been' useful in helping
.the State implement its LLW program.. They requested a point-of-contact at NRC for. continuing regulatory consultation which may be requested through John Williams of the-Authority. NRC staff-also felt that these discussions are useful, and\\said that an NRC staff member would be assigned.the point-of.
contact. -[Nyte: Mr. Robert Nelson, Project Manager,- Division of low-Level Waste Manages %nt and Decommissioning, is the NRC point-of-contact with the.
Authority. He an be reached at NRC Headquarters in Rockville, Maryland, at (301) 504-2004. -
Ronald B. Uleck, Project Manager Licensing and Coordination Section Low-Level Waste Management Branch Division of low-Level Wasta Management -
and Decommissioning, NMSS
Enclosure:
Meeting sign-up sheet cc w/ encl:
J. Williams, Executive Direct r Maine Low-Level Radioactive Wa te Authority DISTRIBUTION:
Central File NMSS r/f RBangart TMassey WBrach ME - LPDR JAustin TFish, R-I RSLO JSurmeier-Meeting Addressees PLohaus (See Attachmenu LLWM r/f MBanerjee TFish ETrottier
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Paul H. Lohous,
requirements for both the disposal / storage facility and the nuclear power station will be met.
Authority officials said that these discussions have been useful in helping the State implement-its LLW program. They requested a point-of-contact at NRC for continuing regulatory consultation which may be requested through John s
Williams of the Authority. NRC staff also felt that these discussions are useful, and said that an NRC staff member would be assigned the point-of-contact.
[ Note: Mr. Robert Nelson, Project Manager, Division of Low-Level Waste Management and Decommissioning, is the NRC point-of-contact with the Authority. He can be reached at NRC Headquarters in Rockville, Maryland, at (301) 504-2004.]
Ronald B. Uleck, Project Manager Licensing and Coordination Section low-Level Waste Manag2 ment Branch Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosure:
Meeting sign-up sheet cc w/ encl:
N J. Williams, Executive Director Maine low-level Radioactive Waste Authority DISTRIBUTION-
's Central File
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RBangart TMassey
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YES K NO Delete file after distribution Yes No Y IG:
YES NO