ML20042G446

Sixth Progress Rept,Reporting Period Oct 1987 - Sept 1989 Implementation of Federal Guidelines for Dam Safety

ML20042G446
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Issue date:	03/31/1990
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l SIXTH PROGRESS REPORT REPORTING PERIOD - OCTOBER 1987 TO SEPTEMBER 1989 l'4PLEMENTAT10N OF " FEDERAL GUIDELINES FOR DAM SAFETY" U.S. NUCLEAR REGULATORY COMMIS$10N MARCH 1990

'I.

INTRODUCTION The U. S. Nuclear Regulatory Commission was created as an independent agency authorized to regulate the design, construction, and operation of nuclear plants and other uses of nuclear materials. The Commission does not plan, design, construct, or operate such facilities, nor does it own or control the land on which the facilities are constructed. To date, the Commission's regulatory program with respect to dams has addressed only dams whose failure could result in a radiological risk to the public health and safety. The legal authority for the Comission in the area of dam safety is derived from the Atomic Energy Act of 1954, the Energy Reorganization Act of 1974, and the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA).

NRC's current regulatory requirements for dams associated with reactors whose failure could increase a radiological risk are considered essentially equivalent to the " Federal Guidelines for Dam Safety" (FGDS), with the possible exception of the specialized area of emergency action plans and the operation and maintenance procedures. The NRC has not included the dams that do not involve radiological hazards within its scope or regulatory overview.

Resources have been devoted to these dams on a.Very limited basis since information available indicated that other agencies were involved in their regulation.

It should be noted that, based on a survey conducted by the staff in June and July of 1989, all reactor site dams of the type that have no radiological impact are under the jurisdiction of State and local authorities.

are inspected'at intervals ~no greater than 5 years, and have an established

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evacuation plan in place.

For uranium mill tailings, NRC has explicit authority over both the radio-logical and nonradiological hazards. NRC's regulations in Appendix A to 10 CFR Part 40 include several provisions related to the stability and safety of the impoundments used to manage these wastes.

As a result of recent discussions, the staff will develop a new program plan for dam safety by October 1990. Mr. John Greeves, Deputy Director of NRC's Low-level Waste Management and Decommissioning Division, will be responsible for the development of this plan. He also will serve as NRC's Dam Safety Officer. This program plan will clearly describe how the NRC will implement the Federal Guidelines on Dam Safety. We believe that certcin elements of what will become part of the plan are already in use by the NRC in the fonn of 9003140243 900430 REh EE PDC

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design and construction criteria for dams and regulations addressing mill tailings impoundments. These elements are currently reflected in a number of our regulations and our Regulatory Guide documents. The program plan will integrate existing regulatory requirements and guidance, and identify those areas of the Federal Guidelines that need to be more fully addressed by the NRC.

The organization of this Sixth Progress Report follows the fonnat proposed by the Interagency Committee on Dam Safety (10005) for the 1989 Progress Report totheFederalEmergencyManagementAgency(FEMA).

II.

PROGRAM ACTIONS SINCE THE LAST REPORT 1.

Guideline Provisions Not Implemented The NRC has not imposed the Federal Guidelines directly onto its licensees by adoption, but to date has relied on existing regulatory requirements, procedures, and internal staff policies within the NRC to implement the general intent of a dam safety program as outlined in the federal Guidelines. The focus has been on design and construction of dams at reactor sites since most NRC-regulated facilities are relatively new when compared to most dams in the power generation field. Until such time as a specific dam safety program is developed and implemented, this approach will be continued. NRC needs to concentrate on the management organization and the operations / maintenance aspects of the Federal Guidelines and their implementation. These topical areas will be reviewad in detail during the development of a new program plan.

2.

Actions Taken in Response to the General and S)ecific Coments and Recommendations Contained in " Conclusions and Recommendations of the National Dam Safety Program - 1986 and 1987; A Progress Report" FEMA Comment:

NRC has not exercised its regulatory ~ function over

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dams that do~ not~ involve radiolo~gical' hazards.

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NRC Response:

The NRC has focused its regulatory overview on dams that may pose radiological hazards. NRC has to date deferred to the States the regulation of dams that pose no radiological risk because all States, except Alabama, that have dams associated with NRC-licensed facilities implement a regulatory program for dam safety.

It should be noted that the dam located in Alabama may pose radiological risks and is therefore subject to the NRC criteria and generally meets the intent of the " Federal Guidelines on Dam Safety."

For mill tailings, both the radiological and nonradiological hazards are addressed by the regulatory program in place.

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FEMA Consnent: NRC's practices regarding dam inspections and requirements for emergency action plans do not meet the requirements of the Federal Guidelines.

NRC Response: The current NRC practice provides reasonable assurance that dams associated with radiological safety at reactor facilities meet NRC criteria equivalent to the " Federal Guidelines on Dam Safety," including periodic inspections and certain aspects of '

emergency action plans.

Dams not associated with radiological safety at these facilities are regulated by State and local authorities with established safety inspection programs that are also equivalent to the FGDS. Once the new program plan has been established, our current practices may require modification.

For dams associated with the retention of uranium mill tailings, the NRC staff performs annual inspections and checks the adequacy of the licensee's emergency action plan. Criterion 8A of Appendix A to 10 CFR Part 40 requires daily inspections of impoundments by licensees.

i This requirement is enforced for all impoundments containing liquids, but not for impoundments being closed. The NRC staff plans to make a comparison between the NRC practice for these dams and the FGDS recommendations. This topic will be addressed in the next biennial report to FEMA.

3.

Agency Changes in The Reporting Period l

Legislation: None Policy: The staff will devilop a new program plan for dam safety defining the NRC implementstion procedures for the various elements of the Federal Guidelines. The purpose of this new plan will be to improve our effectiveness in accomplishing' dam safety program activities.

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Budget: - For'FY 90 there are approx ~imately 1.5 FTE that will be allocated to the dam safety program. As in the past, these are embedded in other safety-related budget items and are not itemized separately. This procedure will be revised in the future as a result of the'rew program plan.

Organization: The position of the NRC Dam Safety Officer is now the responsibility of Mr. John T. Greeves. He can be contacted at i

(301)492-3344.

Ill. Implementation Progress 1.

Administering Dam Safety Responsibilities at NRC NRC verifies that the radiological safety concerns related to dam safety are properly addressed and evaluated and that reasonable margins of safety for the dam structures do exist. However, the NRC

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1 efforts are currently restricted by limited staff resources in certain areas concerned with dam safety, particularly with_ respect to E

the completeness and adequacy of periodic inspections. Consequently, NRC is unable to verify that dams associated with NRC-licensed

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facilities.are in full compliance with all aspects of the FGDS.

This-issue will be evaulated in the development and implementation of'the new program plan.

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Training Related to Dam Safety Dam _ safety training needs were not identified during the reporting

. period, and no specific training oriented toward dam safety was

' offered..

3.

Status of Independent Review of Design, Construction, and Operation of Dams o

s The NRC does not plan, design, construct, or operate dams. During I

the current reporting period, ~the NRC did not perform any review of-C the design, construction, or operation of dams at any of its licensed nuclear reactor facilities. No external consultant services have been used'to review dams at facilities during the reporting period.

Table 1 is provided to update the information provided in NUREG-0965,

" Inventory of Dams," dated January 1983. -There are now 19 dams on t

nuclear reactor power plant sites. During June and July 1989, the; NRCistaff performed surveys of the dams at sites posing no

. radiological risk and determined that they are under State and local programs that maintain a surveillance interval of no longer than five years and have an emergency action plan in place.

At lekst one annual-inspection was conducted by NRC personnel during the current reporting period at each of the dam sites associated with

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uranium mills.

In addition, as.no_ted earli.er, Criterion _ 8A requires diily inspections-of' tailings' dam; by an experienced professional

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retained by the licensee _ to evaluate the operational adequacy of the dams.

Criterion 8A'also requires imr.:ediate notification of dam 1

failure or conditions that could lead to failure.

In addition, Pegnlatory Guide 3.11 requires annual inspections of tailings dams to esaluate their-structural stability. The results of the inspections must be documented, and records must be retained in the licensee's files.

Table 2 is provided-to update-the information in NUREG-0965 for dams

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associated with the retention of uranium mill tailings that are inspected by the NRC staff. The changes in. inventory reflect the slowdown in uranium milling activities and the reclamation of tailings impoundments. Eight dams were deleted from the list l

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5 because of these changes, and two were added as the result of New Mexico deciding not to exercise State controls over the activity.

Most of. the facilities contained in the list have emergency actions 3

plans-that ere ap. proved and inspected by the NRC. A comparison between the FGDS criteria and NRC criteria has not yet been made for these dams. The NRC plans to assess the consistency of its regulatory program with the criteria is Twell as to assess the scope -

and activity of State dem safety programs. Additionally, the NRC-will determine if any water retention structores associated with licensed fuel cycle facilities should Jbe coasidered as dams under the Federal Guidelines., These assessments are expected to be completed during the next biennial period.

4.

Dams That Were Rehabilitated for Safett None.

5.

Management Effectiveness Reviews None.-

6.

Dam Failures or incidents a..

None.

7.-

Emergency Action Planning Program For nuclear power reactor sites, the NRC has an established program for emergency planning regarding radiological' safety of the public.

-Uranium milling sites:are typically constructed in locations remote from population centers and do not pose significant flocaing risk to the-public._ The status of emergency planning for dams at licensed facilities other'than.pover reactors is being assessed and will j_

.be. reported on for the next. biennial: period._

8.

Adoption of Technical Guidance Developed by ICODS 3-a.

Emergency Action Plan (EAP)-Guidelines for Dams:

There are currently no plans for the-NRC to adopt these guidelines, but this will be considered during the development u

of a new program plan.

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Federal Guidelines for Earth' quake Analysis and Design of Dams:

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NRC's criteria for seismic design of safetyerelated structures at'puclear power reactor sites, which include dams involving radiological safet Review Plan" (SRP)y, are incorporated in NUREG-0800, " Standard

, Sections 2.5, 3.7, and 3.8, and Reguletory i,

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1 Guide 1.127.

The NRC staff has concluded that these guidance documents meet the intent of the Federal Guidelines for power reactors. Regulatory Guide 3.11 for mill tailings also addresses seismic issues and implements the seismic siting requirements for impoundments in Criterion 4(e) of Appendix A to 10 CFR Part 40. These criteria are quite comprehensive and should produce safe-seismic designs, Federal Guidelines for Selecting and Accommodating c.

c Inflow Design Floods for Dams:

NRC's criteria for selecting and acenmmodating the design flow are embodied in Section 2.4 of the $tandard Review V

Plan (NUREG-0800) for nuclear power reactor sites and

" Standard Review Plan for UMTRCA Title I. Mill Tailings Remedial Action Plans" for inactive tailings embankments.

These criteria are quite conservative and are consistent

'with the Federal Guidelines. Regulatory Guide 3.11 also addresses upstream catchment requirements of Criterion 4(a) for UMTRCA Title II-sites.

D.

Initie,tives To Improve the Dam Safety Program Generic Issue 103, " Design For Probable Maximum Precipitation", its companion generic letter to all licensees and construction permit i

holders, and the revised SRP Section 2.4 all adopted the probable maximum precipitation estimates for power reactor sites recomended L

by the National Oceanic and Atmospheric Administration in its

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"Hydrometeorological Report No. 52."

The adoption of this current inethod of assessing probable maximum precipitation should provide-L

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more conservative design for future dams.

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10. Authority to Enforce Compliance with " Federal Guidelines

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for Dam Safety"_ _

I The NRC derives its authority for enforcement from the Atomic Energy Act of 1954 and the Reorganization Act of 1974.

NRC has not sought H

explicit regulatory authority for enforcement of compliance with

" Federal Guidelines for. Dam Safety." Additional regulatory authority 'to enforce compliance with " Federal Guidelines for Dam 3.

i Safety" does not appear necessary.

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.IV.

Tabular Data Inforraation requested by FEMA in a tabular format is attached as i

Table 3, which indicates that the NRC now considers twenty-seven (27) d&ms to be within the dam safety program.

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.Tablen1 NRC'Dans for Inclusion in Dam' Safety Program Nuclear' Power Plant Sites

- (19 Dams)

Plant.

-State ~

Name of Dam Cat.I Area Volume Hei ht I

2 Len th Rema rks:

TYes/No)

TKcre)

TAcre-ft)

TT T-TT!T-Farley.

At Holding Pond Yes 100 1,570(n).

55 3,900 Embankment 2,370(m)

Braidwood IL Cooling-Pond Portion

'2,475 22,300(n) 20_

63,300 35,000(m)

.Clinton IL Main Dam No' 4,895' 74,200(n) 65 3,000 250,000(m)-

'Dresden IL Cooling Pond No 1,275 8,100(n) 17 15,000 Failed'once Embankment 12,250(m)

(foundation)

Lasalle IL Cooling Pond No 2,058 31,706(n) 40 37,942 i

Embankment 44,167(m)

'Welf Creek KS Main Dam No 111,280(n) 100 12,260

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5 Saddle Dams McGuire NC Standby Nuclear Yes 35 578(n) 60 1.260 Service Water McGuire NC Was-tewater No 32 190 Collection Basin Dam Shearon MC Main Dam Yes Harris

'70,000(n) 108 1,550 270,000(m) e

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de Table 1 (Contd)~

NRC Dams for Inclusion in Dam Safety Program Nuclear Power Plant Sites-(19 Dams)

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' Plant State Name of Dam Cat.I Area Volume Hei ht ten Remarks (Yes/Ro)

TKcre):

TAcre -f t)

TT!T-TTkh Comanche TX Squaw Creek N.

152,000(n) 150 4,360

. Peak Dam South TX Cooling Pond

' Portion 7,000 200,000(n) 40 64,300 Texas Embankment

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North VA North Anna Dam No

.05,000(n) 95 5,000 Anns 373,000(m)

North VA 2 Saddle Dams Yes 88(n) 2t?

4,250 (3800. ft. & 450 FT.)--

Anna 4

I Category I indicates those facilit'ies where the dam or embankment serves to retain water necessary for radiological safety such as an ultimate heat sink for a reactor system.

Volumes listed that reflect normal! pool voldme are noted by "(n)" and those that reflect the maximum volume are noted by "(m)".

NOTE:

The following dams at power reactor sites that were originally listed in the NRC inventory of dams, NUREG-0965, have been deleted-from the list of as a result of project cancellation or termination of the classification of the dam:

Catawba (1), Midland (1), Oconee(1),'and Summer (3).

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Table 2-NRC Dams for Inclusion.in the Dam Sa fety L Program

. Uranium Mills--(8. DAMS)

Licensee Mill State-

'Name of Dam.I - Area yglume H e'i g h t -

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- Remarks 4

2 3

Max (Acre)~

(Acre-ft)

Tft)~~

~OTJ Rio Algom Lisbon UT

' Lower Pond 16 20~

75 1,600 Mining Corp.

Pathfinder.

Lucky Mc WY f4 Dam 1

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72 2,200

Minas Corporation Atlas Moab UT None 25 170

.100 7,600 c

Minerals Pathfinder Shirley WY-

1. 5 Dam 48 52 60

- 6,000 Mines Basin Corpora t ion

. Plateau Shootaring UT None Roscurces Canyon 118 1,000 Limited k

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Table'2'(Contd)'

NRC~ Dams for Inclusion in the Dam Safety Program Uranium M'111s (8 Dams) f 2'

3 Max L_icensee-Mill State Name_of Dam Area Volume Height length Remarks (Acre)

( Acre--f t )

(ft)

(ft)

UMETC0 White Mesa UT Cell 3 Dike 50 730 42 2,500 Minerals Corp.

I Quivira Mining Ambrosia None 4

Company Lake NM 90 16,000 Homestake Grants NM Mining 4

. None 60 60 90 12,000 Company l

I In cases wh-e dams were constructed in a series so that flow from an upstream failure would be retained by a downstream dam, only the name of the most critical (farthest) downstream dam currently being utilized has been' included.

This is the case at the Lisbon.Mine and filll, The Lucky Mc Gas Hills Mill,-the Pathfinder Shirley Basin Mill, and the White Mesa Uranium Mill.

The areas and volumes shown,-however, are totals for all dams in the series.

l Areas as of May 1989.

Volumes reflect water storage ca acity as of May 1989.

4 Uranium mill dams placed under NRC~ license.s.ince the data reported in NUREG-0965 were assembled.

NOTE:- Mill sites deleted-since the last repo.-t are Bear Creek, Fed. Amer. Partners 7TIf, Gas Hills, Highland, Sweetwater, Split Rock, and an un-named dam a t Shirley Basin.

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..1 Ast t 3 siscARY Of DAI A fos halloNAL DAM SAf t f f P90 CRAM (INDIC4f(

tur@t e Of CAMS)

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' Pit!(DlC 14SPfCittst$ CONDUCIED DAMS Ou0th itAttmER dan SAFElf MCCIFICAt!Oss

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^ DEPA41sE!I e42Aa0 CLAS$1fICATI'Ju SleCE LAST #fPott CapetETES SimCE Ostet uYL T COMPLETED SimCE CUsetettf

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. tu Pe0CWiss (A$f t!P0tf le P90GAESS AGENCY TOTAL.

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LOW TOTAL FORMAL Im!E RRE".a d fE DURInG

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het 19 mot C1assified According 5

none under mane mone bene' mane ~

mone mane to Downtreas NAlards Construction estiS 8

mot Classified According 28

+ 10 mane (Jnder to Downstream aerords

. kone mone mane none 1C Construction to be essessed d sing neat 2 year Intervet

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' 13 mone mone su mone mone wane four (4) inspections were conducted for State authorities and 1 for met tur BRC licensees, e i

!+ Litt tallings dams et four (4) sites receivect a totet of to inspections ter ec ticensees and ef tl tellinge dans et the eight (8) sites received n

8 totIt of 18 Inspections try the sat dsing the period. All eight (S) dess were inspected at teost twice during the bienniet pertad.

• • Period af Doder 1.1987 thrwsfi september 30, 1999.

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