ML20042E061
| ML20042E061 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Randall J NEW YORK, STATE OF |
| References | |
| REF-WM-3 GL-81-38, GL-85-14, IEIN-89-013, IEIN-89-13, IEIN-90-009, IEIN-90-9, NUDOCS 9004190252 | |
| Download: ML20042E061 (1) | |
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. LTR JRANDALL FC APR 161990 Mr. John D. Randall
. Program Director.
-New York State Energy Research and Development Authority 2 Rockefeller Plaza Albany, NY' 12223-9998
Dear Mr. Randall:
As we. discussed on April 11, 1990, I am enclosing, for your information, copies ~-
-of NRC Generic Letters 81-38 and 85-14 and of NRC Information Notices Nos.
89-13 and 90-09. These documents discuss on-site storage of-low-level wastes at reactor sites and at fuel cycle and materials facilities sites.
If I can be of further assistance,.please call me at 301'-492-3340.
(SIGNED) RICHARD L. m Richard L.- Bangart, Director Division of Low-Level Waste Management and Decomissioning, HMSS
Enclosures:
As stated DISTRIBUTION:
4en$raVijaJ RLBangart PLohaus JJSurmeier JGreeves RBoyle FCardile HMSS r/f LLRB r/f JLepre:r/f LAltoft r/f PDR Yes: N/
PDR No: /
/
Reason: Proprietary /
/
or CF Only /
/
ACHW Yes:
/X /
No: /
/
SUBJECT ABSTRACT:
INFO RE ON-SITE STORAGE OF LL WASTES AT REACTOR. SITES l?/
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DATE:04 % /90
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[f/Wk 0FFICIAL RECORD C0W MM voo41902c2 900416 rPDR WASTE
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UNITED STATES
NUCLEAR REGULATORY. COMMISSION.
s OFFICE'0F NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON,-D.C.
20555-
. February 5, 1990.
NRC INFORMATJON NOTICE NO. 90-09:
EXTENDED INTERIM STORAGE OF LOW-LEVEL RADI0 ACTIVE WASTE 8Y FUEL CYCLE AND MATERIALS LICENSEES Addressees:
s 1
All holders of NRC materials licenses.
Purpose:
'This information notice provides guidance:to fuel cycle and materials licensees on information needed in license amendment re storage of low-level radioactive waste (LLW) quests to authorize extended interim at licensed' operations.
NRC pre-viously provided guidance on storage of LLW at nuclear power plant-sites in Generic Letters 81-38 and 85-14.
However, until now NRC has not'provided: similar =
. guidance for fuel cycle and' materials licensees who may, for reasons stated need to store their LLW for periods longer than in the past.
recipients will review this information notice, distribute it:to management andIt is ex s
staff involved with licensed activities, including responsible radiation safety-L staff, and consider actions, as appropriate, to' assure compliance with NRC re-quirements.
No specific written response to this information notice is requirea.
i Descripi.f on of Circumstances:
The Low-level ehdioactive Waste _ Policy Amendments-Act of 1985 (LLRWPAA lished a-series c' milestones, penalties and incentives to ensure that States or Regional Compact.. make adequate progress toward being able to manage th LLW by 1993.
to either close or to stop receiving LLW from outside their What this means to licensees who generate LLW is'that, unless their State or Regional Compact either has a disposal facility operational on January or has made other arrangements for storage or disposal, such licensees 1,1993 to store their LLW onsite until disposal capacity is available.
may have in accordance with NRC re Storage of LLW 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 am licenses to do so.
to be increased to allow storage, or if the terms and condition r
l 630042T ENCLOSURE 2 4
- 4 IN 90-09 February 5, 1990 Page 2 of 3
]
otherwise need to be modified, a licensee will need to apply for a license amend-Attachment I to this notice identifies information which licensees will ment.
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.
well as to persons considering applying for a license to construct a centralized storage facility to receive waste from others until State or Regival disposal capacity is available.
The following considerations are central to extended storage, and are the basis of the information included in Attachment 1.
Storage is not a substitute for disposal.
Other than storage for radio-1.
active decay, LLW should be stored only when disposal capacity is unavailable and-for no longer than is necessary.
Licensee planning should consider a specific date by which storage will end and disposal of the LLW will take place.
In general, waste should be processed before storage, packaged in a 2.
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 fonn or package may have to be reassessed before disposal.
To ensure integrity of packaging and maintenance of waste form, stored 3.
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 or remote) inspection on a routine basis.
Licensees should plan to conduct and document such inspections at-least quarterly.
l 5.
Depending on the specific waste involved, licensees may need to have procedures and equipment in place or readily available to repackage the waste, should the need crise.
6.
Decomposition and chemical-reaction of incompatible waste materials over time can result in gas generation or other reaction products. Licensees 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.
l 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 l
waste und 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.
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~ February 5.1990 j
Page 3 of-3 H
NRC does not advocate extended storage of LLW, as long as disposal capacity is
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available to licensees.
However, NRC recognizes that storage is allowed for, l
.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.
>l 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 a. mended (RCRA).
These mixed wastes, as they are called sare 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.
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 appropriate NRC regional office or, in the case of fuel cycle licensees, to the Division of Industrial and-Medical Nuclear Safety in NMSS.
l hI db.:.
g Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and-Safeguards Technical
Contact:
George Pangburn, NMSS (301) 492-0628 Attachments:
l 1.
Infonnation Needed in an Amendment Request to Authorize Extended Interim Storage of LLW.
2.
Regional' Compacts and Unaffiliated States..
i 3.-
List of Recently Issued NMSS Infonnation Notices.
l 4.
List of Recently Issued NRC'Infonnation Notices.
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'IN 90-09 February 5,1990 Page 1 of 3 INFORMATION NEEDED-IN AN AMENDMENT-REQUEST TO A EXTENDED INTERIM STORAGE OF LOW-LEVEL RADIOACTIV The following paragraphs ' identify the information which NRC considers
-in an amendment rr. quest from a materials or fuel. cycle' licensee-to auth extended interim 1torage:of low-level radioactive-waste (LLW).
'1.
Identification of Waste to be Stored Specify any possession limit increases needed for extended 11nterim a.-
storage of LLW. -
b.
Identify the estimated maximum amount of LLW to be stored,- both in terms of volume and activity, by radionuclide.
Characterize the LLWLto-be stored:
c.
- 1) Yolume of waste by Class (A, B, or C)-
- 2) Physical form 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.
Identif e.
(f.e.. y any additional permits or approvals necessary for storage EPAhazardouswastepermit.Stateor;localapprovals,etc.)
L and the status of each required approval.
2.
. Plans for Final Disposal and onsite storage will begin.Specify when disposal capacit a.
e b.
disposal of your LLW and when that facility is 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 th c.
out.
I l
' Attachinent:1 IN'90-09?
- c-FebruaryL 5 1990 Page 2.of 3-3.
Physical Description of Storage Area a..
Identify the' location and provide'a diagram-of the LLW storage' area which demonstrates where packages will be stored and'how packages will-be accessible ~for, inspection-purposes.
Include the locations of-J waste processing equipment' (if applicable), air sampling ~ stations, effluent filters and any sources of flaninable or explosive material.
b.
Specify the maximum volume!of LLW that can be' stored in the proposed L
-waste. storage area and relate this to annual volume' of waste generated.
i-c.
Specify the type of building / structure in which the waste will'be:
i stored and demonstrate that the waste'will be~ protected from weather L
at all times.-
d.
. Describe the measures to control access to the LLW storage area'and-1 thereby ensure security of the waste.
t e.
Describe the ventilation system and'how it will' assure adequate ventilation of the storage area.
4 f.
Describe the fire protection and suppression system to minimize the
' likelihood and extent of fire.
i g.
Describe how the adverse effects of-extremes of temperature and humidity on waste and waste containers will be. avoided..
h.
Describe vulnerability to other hazards such as tornado, hurricane, flood, industrial accident, etc.
4.
Packaging and Container Integrity 4
Describe the packages or containers to be used for storage of LLW, a.
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.
4 t
c.
Describe your program and equipnent (if applicable) for remote handling ano/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 pa:kages and the storage. area in general, as well as posting the storage area in accordance with 10 CFR Section 20.203.
(
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- 4 IN_90-09 February 5, 1990 Page 3 of 3
- b.
Describe' projected-exposure rates, needs for shie any changes in personnel monitoring which will be require
+
of waste s_torage, a result Describe your. procedures'for_ responding to emergencies c.
_ notification of and coordination with local fire, police
, including
~ departments.
- d..
Describe your system for
. licensees (). cluding any wa. maintaining accura storage in to assure accountability.
6.
Training Describe your program for. training personnel in a._
packaging, handling,-placement,- inspection, surv' procedures for response for_LLW storage.
eying and emergency.
- 7. - - Financial Assurance assurance for decommissioning. Review the relevan
-a.-
submit with your amendment request alimits exceed r
30 35 '40 36 or 70.25 certification of financial assurance decommissioni_ng, funding plan or, this submittal should demonstrate. that financial r as appropriate.
In-nither case, be in place not-only to decomission= the-licensed ope ources are or will>
to provide.for the estimated costs of handling,- tran ration, but also disposal of all LLW stored onsite.
e 8
Review the relevant sections-of Parts 30 3
preparedness. ~If your proposed maximum p,ossession'li i.40 an e
limits specified in Subsections 30.32 (i)(1)m ts-exceed the-you will be required to either demonstrate that an e(me)r(g
. 40.31 j 1
70.22(1)(3),
not needed or to develop and maintain a plan that meets th of the aforementioned sections.
ncy pla)) is e requirements I
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Ih 90-09' February 5,-1990 Page - 1 of 4 -
REGIONAL COMPACTS AND UNAFFILIATED' STATES The follow 4ng is a list of-the existing Regional: LLW Compacts and States.
The list includes a contact person at either the Compact or State' level, if you have questions about LLW disposal.
Compact is further divided to show its member States.In' addition, each Regional:
- 1. Non-sited Regional Compacts *'
l Appalachian Compact Mark McClellan-Deputy Secretary for Environmental _
Protection Department of Environmental Resources-Commonwealth of Pennsylvania P.O. Box 2063 Harrisburg, PA 17120 717/787-5028' (Member States are:Pennsylvanta thost l
State). Delaware. Maryland and' West
~ Virginia.)
Central Interstate Compact
-Ray Peery Executive Director Central Interstate Low-Level Radioactive Waste Compact 3384 Peachtree Road NE, Suite 260 u
Atlanta, GA 30326 404/261-7114 (Member States are Nebraska [ host State), Arkansas, Kansas, Louisiana, andOklahoma.)
Central Midwest Compact Clark Bullard-Chair, Central Midwest Compact Commission Director Office of Energy Research University of Illinois 901 South Matthews Urbana, IL 61801 217/333-7734 (Member States are Illinois [ host State] and Xentucky.)
Midwest Compact Gregg Larson Executive Director Midwest Low-Level Radioactive Waste Compact Connission 350 North Robert, Room 588 St. Paul, MN 55101 612/293-0126
- 4.
o-IN-90-09.
February 5,11990-Page 2 of 4
' (MemberStatesareMichigan[ host Statej, Iowa, Indiana, Minnesota Missouri, Ohio and Wisconsin.)
Northeast Compact Denise Drace Executive Director Northeast Interstate Radioactive
. Waste Compact Connission 195-Nassau Street, 2nd Floor 4
Princeton,.NJ 08540 609/497-1447 (Member States are Connecticut and New Jersey, both of which are host States.)
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 (MemberStatesareCalifornia[ 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,OregonandUtah.)
Rocky Mountain Compact Leonard _Slosky Executive Director Rocky Mountain Compact Commission 1675 Broadway, Suite 1400
. Denver, CO-l80202 3
L 303/825-1912 l
(Member States are Nevada [ current Wyoming.)], Colorado,NewMexicoand host State n
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IN 90-09, ~
February 5,1990 Page 3 of 4 Southeast Compact Kathy Visocki Executive Director-Southeast Compact Commission 3901 Darrett Drive, Suite 100
~
Raleigh, NC 27609-
'919/781-7152 (Member States. are South Carolina
[currenthostState),~ Alabama, Florida, Georgia, Mississippi, North Carolina, Tennessee and Virginia.)
- 3, Unaffiliated States ***
L District of Columbia Frances Bowie.
L Administrator l
Service Facility Regulation Administration' Department of Consumer and Regulatory Affairs ~
District of Columbia 614'H Street, NW, #1014 Washington, D.C.
20001 L
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 s
Low-Level Radioactive Waste Management Board i
Commonwealth of Massachusetts 100 Cambridge, 20th Floor-Boston, MA 02202 617/727-9800 New Hampshire i
Bryan Stromh Deputy Director
.Public Health ~ Services Division L
Department of Environmental Services l
State of New Hampshire L
6 Hazen Drive Concord, NH 03301 603/271-3503
, - ~. -
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-Attachment 2 IN 90 February 5,1990 Page.4:of 4 4
a t
l New York Jay Dunkelberger'-
Executive Director.
Low-level-~ Radioactive Waste Siting Commission-State-of New York 1215 Western Avenue, Suite 306 Albany, NY 12203 518/438-6130 Puerto Rico Santos Rohena Chair 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-Islanrl 9 Hayes. Street-Providence, RI 02908.
401/277-3434' Vennont Jonathan Lash Secretary:
Agency of Natural Resources State of Vermont 103 South Main 3
Waterbury, VT 05676 802/244-7347 E
Texas Lawrence R. Jacobi l
General Manager Low-Level Radioactive Waste Disposal Authority State of Texas 7701 North Lamar. Boulevard,-#300 Austin, TX 78752 512/451-5292 Non-sited Regional Compacts are.those Compacts of States approved by Congress that do ng 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.
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s UNITED STATES NUCLEAR REGULATORY _ COMMISSION' WASHINGTON, D.C. 20555 4
February' 8,1989 NRC INFORMATION NOTICE NO. 89-13: ' ALTERNATIVE WASTE MANAGEM IN CASE OF DENIAL OF ACCESS TO LOW-LEVEL-
, WASTE DISPOSAL SITES Addressees:
All holders of NRC specific ifcenses.
Purpose:
This information notice is being provided to inform addressees of important-
.recent and potential future events concerning_ restrictions on disposal of--
low-level radioactive waste,:and to suggest actionsLto minimize possible adverse consequences of these events ifelicensed' activities involve the:need to dispose of radioactive waste.
It is expected that recipients will review this information for applicability to 'their.. activities and consider action, as appropriate.
However, suggestions contained inLthis information notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Description of Circumstances:
Act) established a series of milestones,-incentives,~an assure that States and Regional Compacts without low-level radioactive waste States and Regional Compacts which do not meet the Act can be subject to penalties such as higher disposal' costs, and may even-tually be denied access:to currently operating burial-sites.
4 -
The most recent milestone under the Act was on January 1,1988. This milestone required non-sited Regional Compacts (those not affiliated with the currently-sited States of Nevada _ South Carolina, and Washington) to identify a h develop a siting plan,,and delegate legal implementing authority.
1 affiliated with a Regional Compact were required to develop a siting plan =and States not provide for delegation of authority as'well.
1 South Carolina, and Washington determined that the S Vermont were in noncompliance. On December 19, 1988, the State of Wash h 7MO g
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l February 8,1989 Page 2 of 4 i
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1 Informed the States of-New Hampshire and Vermont that effective January 1,1989,.
waste originating in those States would be denied access to-the regional disposal facility located near Richland, Washington.
Similar action is anticipated by the States of South Carolina and Nevada.
l-On January 31, 1989, the Governor of Michigan issued a letter to the members of l
the seven-State Midwest-Interstate Compact in which he stated that he was halting-the siting process for a disposal facility in Michigan.
As a result, l
the State of Washington has denied access to waste originating from the State of Michigan.
Similar action is anticipated by the States of South Carolina 1
and Nevada.
At.this time, it does not appear that any immediate action will be taken to deny (access to waste originating from the other members of the l
Midwest Compact Indiana, Iowa,- Minnesota, Missouri, Ohio, and Wisconsin).
l Discussion:
Denial of access to disposal cites could disrupt licensed operations which generate waste by preventing licensees from shipping waste from their faci-lities. This, in turn, could cause regulatory and safety problems such as-exceeding authorized possession limits due to the accumulation of waste, in-adequate waste management capability, or inadequate waste storage facilities.
)
It is suggested that licensees monitor the progress of their States or Regional l
Compacts in meeting milestones specified in the Act.
Licensees in States for which it appears milestones will not be met may need to prepare for the possi-I bility of severe restrictions on disposal of radioactive waste.
Licensees in i
New Hampshire, Vermont, and Michigan may wish to consider actions now to miti-gate the potential impact of loss of disposal capability.
Following are examples of suggested actions to be considered:
1.-
Review your current NRC license and license application, particularly possession limits and procedures and requirements for waste processing, storage, and disposal to determine if changes need to be madc for increased storage of waste.
I 2.
Determine how much of your waste goes to a licensed burial site either directly or indirectly through a " waste broker."
3.
Evaluate potential safety problems and technical difficulties which might result if radioactive waste remains in storage at your facilities for long periods of time; e.g., package deterioration, inventory control, fire hazards, etc.
4.
Review alternatives to minimize generation of waste shipped to burial grounds; for example:
a.
Carefully segregating long-lived radioactive waste from short-lived and non-radioactive waste.
b.
Stopping unnecessary work which generates waste.
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February 8,'1989 Page 3 of.4L J
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' 4-Changi.ng processes, procedures, or ra'dionuclides'to reduce volume
.c.-
of generated. waste, d.
Using volume reduction techniques ~,'such as compaction..
Revieialternative waste management and disposal methods;L for example:
5.
Transfer of-unneeded sealed sources to their respective a-manufacturers.
b.
Disposal of biomedical wastes in accordance with 10-CFR Section 20.306.
e c.
Decay-in-storage.
d.
Incineration.
Interim storage pending transfer to a licensed burial site'if access e.
is restored in the future.
6.
For waste management measures which are not currently authorized by your NRC license, consider requesting an amendment-to your license to-authorize additional waste management actions in the event of restricted access to burial grounds.
Examples would be amendments to-authorize increased pos-facilities. session limits,; decay-in storage, incineration, or use of interim storage' The above suggestions would not be a permanent solution to waste b dial restric-tions, but would better. assure that licensees have contin to avoid safety violations and to minimize disruption of gency plans in place licensed activities.
d nunter of parties have inquired about the granting of emergency access un the provisions of Section 6 of the Act.
On February 3, 1989, NRC issued a new rule, 10 CFR Part 62, in the Federe.1 Register (54 FR 5409) which establishes:
criteria and procedures to be used in determining whether emergency access
.should be granted.
These criteria and' procedures intent, view the gras; ting of emergency access as a, consistent with Congressional last resort.
Therefore, waste generators should be aware that only under the most limited and~ rare circumstances would generators be granted such access.
Questions about license requirements and license amendments should be directed to the appropriate NRC licensing office, either in one of the Regional Offices -
or in Washington, D.C.
Questions on lw-level radioactive waste policy issues i
l.
Page4of[it""
?
< should be. directed tos:
~
Paul Lohaus, Chief Operations Branch, Divis ion of.'
Low-Level Waste Management and Decommissioning; Mail Stop SE4, U.S. A Regulatory Comission, Washington. D.C. 20555, Phone:= (301) 492-334.G
- specific action or-written respons,e is required by this informatfor notice.
No-fl4Y((k==
/.e-Richard E. Cunningham, Director Division of Industrial and l
Nedical' Nuclear Safety Office of Nuclear Material' Safety
-and Safeguards
..Ross&
har es i,
rector Division.of Operational Events Assessment Office of Nuclear Reactor Regulation d
i Technical
Contact:
Paul Lohaus. NMSS i
(301)492-3345 i
1 Attachments:
j 1.
List of Recently Issued NMSS Information Notices I
2.
List of Recently Issued NRC Information Notices
-)
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('e-UNITED STATES NUCLEAR REGULATORY COMMISSION i
E
. casmwngw. o, c. rosse August 1,1985 TO ALL LICENSEES
SUBJECT:
COPNERCIAL STORAGE AT POWER REACTOR SITES OF LOW-LEVEL RADI0 ACTIVE WASTE NOT GENERATED BY THE UTILITY _ (Generic Letter 85-14)
Gentlemen:
The' Low-Level Radioactive Waste Policy Act of 1980 (P. L.96-573) assigned to
-the states the responsibility to provide for disposal of connercial low-level radioactive waste (LLW) generated within each state. The Act envisioned that all states would be capable of providing for disposal of connercial' LLW generated within their borders by 1986. Based on the current-status of state efforts and the substantial time required to establish new disposal facilities, no new sites will be available for at least several years. Due to the uncertainty of this
- l situation and statements made by:some officials of states within which currently operating disposal sites are' located, it appears possible that access to the existing sites may be restricted, While some licensees have taken steps to-temporarily store LLW generated at e
(V their sites to alleviate any impact that limiting of access to disposal capacity may have on licensed operations, provisions for storing LLW should be used only for interim contingency purposes.
It.is the policy of the NRC_ that-lick sees should continue to ship waste for disposal at existing sites to the manmum extent practicable.
In anticipation of possible curtailment of access to existing disposal facili-ties, interest-is being expressed in some states in connercial storage of LLW generated within the states. While the NRC recognizes that storage may appear desirable in states which have not resolved their low-level waste disposal i
problems, connercial storage facilities, however, should not become de-facto disposal sites. NRC will require for connercial. storage under its jWisdiction l*
that, in addition to safe siting and operation, connitments and assurances be made for eventual disposition of all waste stored at connercial storage-locations. This includes provisions for repackaging (if nectssary), transpor-tation and disposal of the waste, as well as deconnissioning of the facilities.
Some of the concepts for connercial-storage involve using nuclear power reactor sites as connercial storage locations for LLW not generated by the utility l
licensee. As a ; natter of policy, the NRC is opposed to any activity at a nuclear reactor site which is not generally supportive of activities authorized by the operating license or construction permit and which may divert the atten-tien of ifcensee management from its primary task of safe operatioff or L
construction of the power reactor. Accordingly, interim storage of LLW within the exclusion area of a reactor site, as defined in 10 CFR 100.3(a), will be
,c' subject to NRC jurisdiction regardless of whether or not the reactor is located in an Agreement State, pursuant to the regulatory policy expressed in 10CFR150.15(a)(1). Within Agreement States, for locations outside the exclusion areas, the licensing authority is in the Agreement State.
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I' In order for NRC to consider any proposal for comercial storage at a reactor site, including comercial-storage in existing low-level waste storage facili-ties, the NRC must be convinced that no significant environmental impact will l
result and that the comercial storage activities will be consistent with and not compromise safe operation of the licensee's activities, including divertin reactor management attention from the continued safety of reactor operations. g A Part 30 If:ense is required for the low-level waste storage and a Part 50 license amendment may also be required. The appitcation must include:
By the utility
. A determination by the utility licensee that the proposed low-level waste
,O comercial storage activities do not involve a safety or environmental question, and that safe operation of the reactor will not be affected.
In making this determination, the licensee shall consider:
-Direct impacts of the comercial storage operation on rea' tor c
operations during nonnel and accident conditions; Diversion of uti ity management and personnel attention from safe reactor operation;-
Con 61ned effects of onsite and offsite dose dwing nonnel and accident conditions; Influence on effectiveness of reactor emergency plar.s; Influence on effectiveness of reactor security plans; Financial liability provisions, including impact on indemnity coverage; and
^
Environmental-impact of the storage facility, including t-J f
s potential interaction with the generating station.
By the applicant (the utility or another person)
Information relating to the safety of the comercial storage operation; Infonnation relatin!1 to the environmental impact of the_ storage operation in sufficient detai' to allow staff to establish the need for preparation of an Environmental Impact Statement; Financial assurance to provide for the comercial storage operation and
. decomisioning including any necessary repackaging, transportation and disposal of the waste; and Written a disposal,greement from the jurisdiction responsible for ultimate' the State, that provisions are sufficient to assure ultimate disposal of the stored waste.
The Office of Nuclear Reactor Regulation (NRR) will conduct an environmental review and review the application to determine whether the low-level
- waste comercial storage activities on a reactor site impact the safe operation of, the reactor.
Following NRR review, the licensing authority for comercial l
storage on a reactor site under NRC; jurisdiction (all locations in.non-A States and locations within reactor exclusion areas in Agreement States)greement is the Office of Nuclear Material Safety and Safeguards. The NRC will assess l
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environmental impact snd will issue an Environmental Impact Statement,$1.25.
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appropriate, in accordance witit provisions of 10 CFR 51J0, 51.21 and As part cf the procedures, the NRC will provide notice in the FEDERAL REGISTER-of rece$pt and availability of any application received for connercial storage i
activities. The public notice will also indicate the strff's intent regarding preparation of an environmental assessment and its circulation for public review and connent.
An Environmental Impact Statement will most likely be needed based on the environmental assessment.
I Because the NRC has not yet received or reviewed en applicatio" for a centralized connercial low-level waste storage facility intended to store large amounts of LLW for five or more years, the NRC may condder applying the c"iteria described above to such connercial storage facilities whethee they be on a reactor site or not.
Interim storage of utility licensee-generated LLW will continue to be considered i
according to the provisions stated in Generic Letter 81-38, dated November 10, l,
1981.
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For additional information, please contact Frank Miraglia, Office of Nuclear Reactor Regulation, U. 5. Nuclear Regulatory Comission, Washington, D.C. 20555
[ Telephone: (301)492-7980) or Richard Cunningham, Office of Nuclear Material Safety and Safeguards,)U. 5. Nuclear Regulatory Connission, Washington. 0 20555(Telephone: (301 427-4485).
Sincerely, LL Willi J. M ecks Executive Director fcr Operetions i
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A-NUCLEARRIOULAIO 3
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-., a Novemcer 10. tio..n t
TO ALL HOLDER $ OF AND APPLICANTS FOR OPERATING LIC STCRAGE OF LOW-LEVEL RA010ACT1YE WASTES AT POWER R r
SUBJECT:
Gentlemen:
As a result of a reduction in waste disposal availability in the United States, many nuclear power reactor licensees are taking or are planning to take steps to provice for additional onsite storage of low-level radioactive These steps range from storing packaged wastes in wastas generated onsite.
unused space to construction of new f acilities for volume reduction extended storage.
are underway and how they should be reviewed and approved.
Actions on vaste storage can influence the dovetooment and implementation of final disposal plans by states, acting individuafly or on a regionalSome statts l
basis, to establisn seditional disoosal caoacity.
to NRC that utili:ation of disposal. services my nuclear power plant licensees is essential if disposal sites are to De developed 3y states or regional Thus, it is important that the NRC not take deliberate action -
tnat would hinder the estaclisnment of soditional sisposal capacity by the compacts.
states and ye*.. consistent with NRC regulatory safety requirements.
It is with
- ermt necessary operational flexibiltty ey its licensees.these po For proposed increases in storage capacity for low-level waste generated by normal reactor operation and maintenance-at power r If (1) your existing license concitions or technical of 10 CFR 50.59.
soecifications do not pronibit increased storage. (2) no unreviewed safety i
cuestion exists. and (3) the preocsed increased storage capacity dcas not exceed the generatec waste projectea for five years, the licensee 'nay I
provide the acced. capacity, cocument the 50.59 evaluation and report it to
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tne Commission annually or as specified in the license.
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Raciel:gical safety ;ut:ance has been cavale:ed ty the staff #ce the cesign ano ::eratten of interim c:ntingency low-level waste si: rage facilities. Necassary casign features ano aaministrative c:ntrols will be cictated by sucn fac rs as the waste fom, concentrations.of radioactive i
material in indivicual waste c:ntainers, total amount of radioactivity to j
te stored, and retriev&oility of wasta. A cecy of the guidance document is enclosed with this letter. This guidance shall be used in the design.
i construction anc coeration of your storage facility.
In addition, the NRC will (udge the acequacy of your 50.59 evaluation cased on your comsliance w1:n the quicance. Please note also tnat It Circular No. 8019, dated l
August 22, 1950, provices infomation on presaring 50.59 evaluations for changes to racicactive waste treatment ' systems.
If ycu catemine that an unreviewed safety cuestion exists, authority for se should be recuesten thr ugh acclication to the Office of Nuclear
?'aterial Safety anc Safeguares (NMSS) cursuant to 10 CFR 30. accomoanied by i
an envir:nmental evaluation that consicers the incremental impact as related to reac:fr c:erations. Such a:clication fer a separate Part 30 license is for the acministrative convenience of tne Comission and is not intanced to te suostantively different than an application for amendment of
- ne facility perating license. Acclication for use should also be acc:m.
- &nied by a snewing that the st
- rage provisions will not impact on the safety of reacter ocerations anc will not. foreclose alternatives for cisecsal of the wastas.
!.H55 will notice the receipt of acclication in the Federal teeister, offer an c:cortunity for :uelic hearing if significant puclic interest.s comonstrated, and will :erform an environeental assessment to catemine if the procesed activity will significantly affect the cuality of the environment.
Facility c:nstructien prier to the staff's determination woulo be carried out at the licansee's risk. Any license issued will be for a standard five-yet. term, renewacle if c:ntinued need is comonstratec inc if safety of centinued s:Lrage is estaclished. NRC licensing jurisdiction will be retained in Agreement States in ac:ordance with 10 CFR 150.15(t)(1) for storage of icw-level waste generated and stored onsite.
Incemnity coverage will be
- revided uncer and in acc:rcance with your existing incemnity agreement with the C mission.
'f it is determined that the s:crage crevisiens could imsac: on the safety of react:r oceratiens or an existing license c:n:1cion or tecnnical specifica-tien lim 1 en the amount of waste storage, a enawie Mn the concitions of the react:r facility license may be necessary.
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8 The provisions for added capacity should be used only for interim contingency e
storage, and low-level wastes should continue to be shipped to disposal sites.
to '
extent practicable.
The
- Low Level Radioactive Waste Policy Act' of
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' 60 gi s primary responsibility for the disposal of low-level waste to the itates Some states have initiated disposal plans, and we believe it is "t' ant that power reactor. licensees, as major waste generators, work with 4, ' / ovide technical assistance and other support to assist individual st. es or regions in developing new disposal sites. You are encouraged to i
take an activr. role in the development of additional disposal sites.
Some licensees are considering the installation of major volume reduction processes, e.g., incineration, dehydration, or crystallization to substantially reduce the volume of waste for disposal. You are encouraged to examine the costs and benefits of such processes for your operations..However.
l notwithstanding the use of volume reduction, you are also encouraged to take an active role in the development of additional disposal sites.
l For proposed increases in storage capacity for more than five years (long-tern), the application and review procedures will be pursuant to 10 CFR 30 with co tsideration of container integrity and retrievability, volume
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reducti in, influence on state planning for disposal, and implications of
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de facti onsite dispose). Any long-tern license issued will be for a five-ye ir, renewable ters.
If you teve any questions about these matters, please let us know.
Sincerely.
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111'fam b. Dircks Executive Director for Operations
Enclosure:
' Guidance Document i
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s Enclosure RADIOLOGICAL SAFETY Gu%NCE FOR ONSITE COWTlWGEN;Y STORAGE CAPACITY o
e 1.
Introduction The objective of this technical position is to prwide guidance to licensees considering additional onsite low level radioactive waste-storage capabilities.- While it may be prudent and/or necessary to establish additional onsite storage capability, waste should not be placed in contingency storage if the ability to dispose of waste at a licensed disposal site exists. The shipping of waste at the earliest practicable time minimizes the need for eventual waste reprocessing due to possibly changing burial ground requirements, reduces occupstional and non-occupational exposures and potential accident consequences, and in the event of burial ground closure, maximizes the amount of storage space available for use.
The duration of the intended storage, the type and fem of waste, and the amount of radioactive material present will dt. 7te the safeguards and the level of complexity required to assure pubbe health and safety, and minimal risk to operating personnel. The longer the intended
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storage period, the greater the degree of controls that will be. required
~f for radiation protection and accident prevention.
For purposes of this document, the duration of temporary waste storage is to be up to five (5) years. The magnitude of the onsite storage safety hazaro:fs pre-dicatec on the type of waste being. stored, the amount of radionuclides present, and how readily they might be transported into the ewironment, in general, it is preferable to store radioactive material in solid fom.
Under some circumstances, however, temporary storage in a liquid form may be desirable or required. The specific design and operation of any storage facility will be significantly influenced by the various waste forms, consequently, this document addresses wet waste, solidified wet waste and dry low level radioactive waste.
Guidance similar to that prwided in this enclosure' has been incor-porated in NUREG-0800, NRC/NRR Standard Review Plan, July 1981, as Appendix 11.4-A to SRP 11.4, Solid Waste Management Systems.
11.
General Information 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 obiectives of any proposed storage f acility, or area, will need to meet minimal reovire-ments in areas of design, operations, safety considerations and policy
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.t-I considerations.
For purposes of this technical position, the major emphasis will be on safety considerations in the storing, handling i
and eventual disposition of the radioactive waste. - Design and j
operational acceptability will be based on minimal reovirements which are defined in existing SRPs, Regulatory Guides, and industry standards, for proper management of radioactive waste. Considerations for waste i
minimization and volume reduction will also have to be incorporated into an overe11' site waste management plan and the onsite storage alternative. Additional waste management considerations for ALARA, i
decontamination, and decommissioning of the temporary storage facility, including disposal, should be perfomed as early as possible because future requirements for waste foms may make stored wastes unacceptabh f or final disposition.
Facility design and operation should assure that radiological conse-quences of design basis events (fire, tornado, seismic event, flood) i should not exceed a small fraction (101) of 10 CFR Part 100,,1.e., no_
more than a few rem whole body dose.
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The added capacity would typically extend storage 'to accomodate no more th6n an amount of waste generated during a nominal five-year period. In addition, waste should not be stored for a duration that exceeds five-years.
Storage of waste in excess of the quantities and duration i
described hegeln requires Part 30 licensing approval. The design capacity (f t, Ci) should be detemined from historical waste generation f
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.
l
'The five-year period is sufficient to allow licensees to design and con-struct additional volume reduction facilities (incinerators, etc.), as necessary, and then process wastes that may have been stored during con-
,struction. Regional state compacts to create additional low-level waste disposal sites, should also be established within the next five years.
III. Gene' rally Applicable Guidance (a) The quantity of radioactive material allowed and the shielding con.
figurations 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 frtn direct radiation and effluent releases from all sources of uranium fuel cycle and 10 CFR Part 20.105 limits the exposure rates in unrestricted areas. Offsite doses frcn onsite storage must be sufficiently low to account for other uranium f uel cycle sources (e.g., an additional dose of,11 mrem / year is f
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i not likely to cause the limits of to tyg ;go g, ** ***
Onsite dose limits associated with temporary storm $}'
fl ntr 11 per 10 CFR Part to incluaing the ALARA principal of 4
(b) Comcatibility of the container mataMais with the waste foms and l
with environmental conditions external to the containers is neces.
stry to prevent significant container corrosion. Cor.tainer selec.
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tion should be based on data 'which' demonstrates minimal corrosion I
from the anticipated internal and external enviroment for a period I
well in excess of the planned storage duration. Container intee af ter the peMod of storage shout d be sufficiont to-allow handl{rity ng during transportation and disposal.without container treach.
Gas generation from ottanic matarials in waste c:ntainen can also lead to container breach and potentially flammaele/ explosive con-I di tions. To minimize the numoer of potential proelses, the wasta fem gas generation rates from radiolysis, biodegradation, or enemical reaction should be evaluated with respect to container breach and the creation of flammaele/ explosive conditions. Unless storage c:ntainers are equipped wi'th special vent designs which allow ceoressuri:ation and do not pemit the migration of radio.
sctive mataMais, resins highly loaced with radioactive mateMal, such as BWR reactor water cleanuo system resins, should not se stored for a peMod in excess of approximately one year.
A pr gram cf at least peModic (cuarterly) visual inspection of
- entainer integrity (swelling, corrosion oroducts, breach) should te perfomeo. Inspection can be accomolisned by use of TV monitors; by walk throughs if storage f acility layout, shielding, and the c:ntainer storage array pemitt or by selecting waste containers that are reorosentative of the types of waste and containers stored in the facility and placing them in a location specifically cesigned for inscection purseses. All inspection crocedures I
cevelooed should minim 1:e occuoational exoosure. The use of high integMty containers (300 year lifettmo design) woule pemit an inscoction orogram of reducto scope.
(c) If possible, the oreferred location of the adoitional storage f acility is inside the plant protected area. If adeouate space in the trotected area is not availaole. the storage facility should de : laced on the olant site and both a physical security crogram 4
(fence, locken and alamed gates /coors, ceMocie oatrols) and a restricted area for esciation grotection purteses should be es taoli sned. The f acility shculo act te slaceo in a location that
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requires transportation of the waste over public roads unless no l
other feasible alternatives exist. Any transpertation mer public roads must be conducted in accordance with WRC and 00T regulations.
(d) For low level dry waste and solidified waste storage:
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Potential release pathways of all radionuclides present in the solidified waste form shall be monitored as per 10 CFR 50, l
Appendix A.
Surveillance programs shall-incorporate adequate
' methods for' detecting failure of container integrity and men-suring releases to the emironment. For outside storage.
periodic direct radiation and surface contamination monitoring l
I shall be conducted to insure that levels are below limits l
specified in 10 CFR 20.202, 20.205, and 49 CFR 173.397. All containers should be decontaminated to these levels or below before storage.
2.
Prwisions should be incorporated for collecting liquid' drain-age including prwisions for sampling all collected liquids.
Routing of the collected liquids should be to radwaste systems if contamination is detected or to nomal discharge pathways if the water ingress is from external sources and remains uncontaminated.
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3.
Waste stored in outside areas should be held securely by in-l stalled hold down systems. The hold down system should secure all containers during. severe emironmental conditions up to and including the design basis event for this vaste storage facility.
4.
Container integrity should be assured against corrosion from the external emironment; external weather protection should be included where necessary and practical. Storage containers should be raised off storage pads where water accumulation can be expected to cause external corrosion and possible degrada-tion of container integrity.
5.
Total curie limits should be established based on the design of the storage area and the safety features prwided.
6.
Inventory records of waste types, contents, dates of storage, shipment, etc., should be maintained.
1Y.
Wet Radioactive Waste Storace (a)' Wet radioactive waste will be defined as any liquid or liquid / solid sl urry.
For storage considerations, wet waste is further defined
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as any waste which contains free liquid in emounts which exceed the j
1 requirements for burial as established by the burial ground licens-ing authority.
J (b) The f acility supporting structure and tanks should be designed to
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prevent uncontrolled releases of radioactive materials due to spOlage or accident conditions.
i (c) The following design objectives and criteria are applicable for wet-radioactive waste storage. facilities:
1.
Structures that house liquid redweste storage tanks should be designed to seismic criteria as defined in Standard Review l
Plan (Section 11.2).
Foundations and walls shall also be de-signed and fabricated to contain the liquid imentory which might be released during a container / tank failure.
2.
All tanks or containers should be designed to withstand the corrosive nature of the wet waste stored. The duration of i
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storage under which the corrosive conditions exist shall also be considered in the design.
o 3.
All storage structures should have curbs or elevated thresholds with floor drains and sumps to safely collect wet waste assuming the failure of all tanks or containers.
Prwisions should be
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incomorated to remove spilled wet waste to the radweste
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treatment systems.
4.
All tanks and containers shall have prwisions-to monitor liquid levels and to alam potential werflow conditions.
I 5.
All potential release pathways of radionuclides (e.g.,~ evolved gases, breach of container, etc.) shall be controlled, if feasible, and monitored 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.
t 6.
All temporarily stored wet waste will require additional reprocessing prior to shipment offsite; therefore, prwisions should be established to integrate the required treatment with the waste processing and solidification systems. The inter-face and associated systems should be designed and tested in l.
accordifce with the codes and standards described in Standard Review Plan Section 11.
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V.
Solidified Radioactive Waste Storace (a) Solidified radweste for storage purposes shall be defined as that waste which meets burial site solidified waste criteria. For-porposes of this document, resins or filter sludges dewatered to the abwe criteria will be defined under this waste classifica-tion / 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 should be designed with good engineering judynent to preclude or reduce the probability of occurrence of uncontrolled releases of.
radioactive materials due to handling, transportation or storage.
Accident mitigation and control for design basis events.(e.g.,
fire, flooding, tornadoes, etc.) must be evaluated and protected against unless otherwise justified.
(d) The following design objectives and criteria are applicable for solidified waste storage containers and facilities:
N 1.
All solidified radwaste should be located in restricted areas j
where effective material control and accountability can be maintained. While structures are not required to meet seismic criteria, protection should be afferded to insure the. radio-activity is contained safely by use of good engineering judgment, such as the use of curbs and drains to contain spills of dewatered resins or sludges.
2.
If liquids exist which are corrosive, proven prwisions should be made to protect the container (i.e., special liners or coatings) and/or neutralize the excess liquids.
If deemed 4
appropriate and necessary, highly non-corrosive materials (e.g., stainless steel) should be used. Potential corrosion between the solid waste-fores and the container should also be.
considered.
In the cas: of dewatered resins, highly corrosive i
acids and bases can be generated which will significantly reduce the lon The Process Control Program (PCP) gevity of the container.
should implement steps to assure' the abwe does not occur; prwisions on container material selection and precoating should be made to insure that container breach does not occur during temporary storage periods.
3.
Prwision should be made for additional reprocessing or re-packaging due to container failure and/or, as required for,
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final transporting and burial as per DOT and burial site criteria.
abilities should be developed. When significant h and personnel exposure can be anticipated, ALARA methodology should be incorTorsted as per Regulatory Guides 8.8 and 8.10.
4.
Procedures should be developed and implemented for earl tection, prevention and mitigation of accidents (e.g., y de-l Storage areas and facility designs should incorporate good fires).
engineering features and capabilities for contingencies so as
' to handle accidents and provide safeguard systems such as fire detectors and suppression systems, (e.g., smoke detector and sprinklers).
should be estabished to insure both contrPersonnel training a materials and minimum personnel exposures.ol of radioactive
, Fire suppression devices may not be necessary if canbustible materials are minimal in the area.
V.
Low Level Dry Waste Storage L
(a)
Low level dry waste is classified as cantaminated material -(e.g.,
paper, trash, air filters) which contains radioactive material inert material and contains no free water. dispersed in sma Generally this consists of dry material such as rags, clothings paper, and small
, equipment (i.e., tocis and instruments) which cannot be easily i
decontaminated.
l (b)
Licensees should implement controls to segregate and minimize the generation of low level dry waste to lessen the impact on waste s torage.
considered to minimize the need for additional wast c
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facilities.
(c)
The following design objectives and criteria are applicable for low level dry waste storage containers and facilities.
1.
All dry or compacted radwaste should be located in restricted 8
be maintained. areas where effective material control and accountability ca While structures are not recuired to meet seismic criter1a, protection should be afforded to insure the radioactivity is contained safely by use of good engineering judgment.
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The waste container should be designed to insure radioactive material containment during normal and abnormal occurrences.
The waste container materials should not support combustion.
The packaged material should not cause fires through spon-
.taneous chemical reactions, retained heat, etc.
3.
Containers should penerally 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 anticipated, consequently, all ALARA methodology should be-incorporated per Regulatory Guides 8.8 and 8.10.
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