ML20043C790
| ML20043C790 | |
| Person / Time | |
|---|---|
| Issue date: | 05/25/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20043C753 | List: |
| References | |
| REF-WM-3 NUDOCS 9006060179 | |
| Download: ML20043C790 (4) | |
Text
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LOW-LEVEL WASTE:
NRC VIEWS
]
Richard L. Bangart, Director Division of Low-Levei Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards United States Nuclear Regulatory Commission INTRODUCTION I welcome the op>ortunity to discuss some Nuclear Regulatory Connitsion (NPC) i program initiatives t1st will be of interest to the Conference.
I will sunenarize three current NRC activities in the areas of Standard Review iMan re-evaluation, technical support and assistance to Agreement States regulating current or future l
low-level waste disposal facilities, and solidification system vendor topical report reviews. These activities are synbolic of NRC's commitment to coordinate low-level waste management program activities with Agreement States and to be responsive to
' issues and concerns identified by Agreement States and others.
CURRENT ACTIVITIES Let me first address our efforts to re-evaluate the standard review plan for low-level waste disposal facility license application review.
In support of its regulations, the NRC issues guidance that clarifies regulation intent, identifies acceptable methods f or satisfying requirements, and facilitates the regulatory process. Two specific companion documents used to f acilitate the licensing review of an application for a low-level radioactive waste disposal facility are:
l NUREG-1199, Standard Format and Content of a License Asp 11 cation for a Low-Level Radioactive Waste Disposal Facility (SF&C), whic1 describes the information that should be provided in a Safety Analysis Report (SAR? and establishes a uniform format for the presentation of information necessely to
- 1) ensure the SAR contains the information required by 10 CFR ! guidan fulfill the requirements in 10 CFR Part 61. The objectives of the art 61; to:
- 2) aid the applicant and the NRC staff in ensuring the infomacion is corplete; i
- 3) aid readers in locating information in the SAR; and 4) shorten the time for the review process; and i
NUREG-1200 Standard Review Plan (SRP) for the Review of a License Application for a Low ievel Radioactive Waste Disposal facility, which provides guidance to NRC staff performing safety reviews of disposal facility applications. The SRP ensures quality and unifomity of review by specifying the areas of review, the requirements and acceptance criteria for the review, and sample evaluation findings.
Several apprc~
cely coincident events culminated in the decision to review noth of these docr
.ts and identify areas where revisions are necessary. The first event was es' leticn of the reviews of two Prototype License Application Safety Analysis Rep rts, or PLASARs. These were DOE-sponsored prototype license applications for engineered disposal facilities. The results of the licensing review l
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of these documents should facilitate the preparation of actual low-level waste disposal appitcations by developers, provide experience for NRC in the review of applications, serve as a reference for Agreement State low-level waste regulatory authorities, and identify areas in NUREGs-1199 and -1200 where improvements are necessary.
Importantly, at the request of the State of Pennsylvania, two reviewers participated in the review of the second PLASAR by working in the NRC offices with the review staff. This proved to be a valuable ex>erience. The NRC staff benefited by gaining the additional technical review of the )LASAR and a better appreciation of a State regulator's roles and responsibilities and the environment in which the State regulator must work. We in NRC are hopeful that the reviewers from Pennsylvania gained additional insight as to the intent of some of the NRC's regulations and guidance and as to how HRC plans to conduct reviews of an application for a low-level radioactive waste disposal facility. This PLASAR review effort identified areas in the Standard Review Plan that are in need of revision, primarily, Chapter 6 on Safety Assesment and Chapter 7 on Occupational Radiation Protection.
The second event was the receipt of two letters one from the California Radioactive Materials Management Forum, an organizatlon representing waste generators in California and the Southwest Compact, and the other from the Texas Low-Level Radioactive Waste Disposal Authority.
Both letters suggested the view that some parts of the Standard Review Plan contained guidance in technical areas that went beyond the requirements in Part 61.
In short, the concern was that guidance did not comport one-for-one with requirements and thus was excessive in some areas. The guidance in Standard Review Plan 2.3.2. Seismic Investigation, was the example given by both organizations. Erroneously, that SRP does refer to 10 CFR 50, Appendix A,
" General Design Criteria for Nuclear Power Plants' and 10 CFR 100, Appendix A,
" Seismic and Geologic Criteria for Nuclear Power Plants," as requirements.
The third event leading to the decision to re-evaluate the SRP was the experience to date gained by California, the Southwest Compact, and their site developer, U.S. Ecology, in using the SF&C and SRP in preparing the license application for the California site.
It was surprising to the NRC that use of the guidance resulted in an initial application that was approximately 7000 pages in length and that would likely grow in volume as questions and responses follow.
We have abtained a copy of the application and will be using it as a reference document in our review of the SF&C and SRP.
Our review of the SFAC and SRP is scheduled for completion by September of this yerr. That review will incorporate the views of Agreement States and others as part of the approach that will be used. First, we already are aware of views on the SRP that were shared with us as a result of the Pennsylvania staff review of the second PLASAR. Secondly, a staff member from NRC's Office of State Programs will be a menber of the review team. Third, the review team will meet with and solicit views and input from regulators in selected States and through them the views of low-level waste disposal f acility operators and developers.
A second example which symbolizes NRC's commitment to coordination with Agreement States is the broad NRC effort to provide technical support and assistance, and to exchange information about ongoing NRC and State activities in the low-level l
waste program. Toward this end, we in the low-level waste program have been strongly supportive of our Office of State Programs efforts to conduct LLW workshops for l
Agreement State regulators twice each year. The previous workshop was held September 7 and 8,1989, the next workshop is scheduled for June 19-21, 1990, and we are hopeful that a low-level waste disposal facility site performance assessment workshop
4 can be scheduled for later this year. We also are supporting the Office of State Programs in the conduct of Agreement State low-level radwaste program reviews. We have recently participated as members of review teams for reviews of Utah South Carolina, Illinois, California, and Texas low-level waste regulatory programs and participated in a visit to North Carolina. We have also recently worked with the States of South Carolina and Washington regulatory authorities on approaches to administer our respective regulatory and licensing responsibilities at the Barnwell and Hanford disposal facilities. NRC licenses s)ecial nuclear material (SNM) disposal at each of these sites. At these sites, NRC's limited regulatory role is secondary to that of the States and we are following approaches which will reduce or eliminate the need for independent review of areas where the state exercises primary regulatory control. Such areas include operating procedures, monitoring and facility design. NRC's review would be limited to the criticality and security aspects unique to the receipt, possession and disposal of larger quantities of SNM.
The review of vendor solidification system topical reports is a third low-level waste program area where extensive coordination between Agreement States and the NRC occurs. NRC regulations require a waste generator to properly classify a waste and attest to the stability of any Class B or C waste before disposal. Class B and C wastes are required to be stable for 300 years. The stability requirement for wet wastes can be satisfied by processing the waste with a solidification medium to produce a stable waste form, or the waste can be dewatered and placed in containers that will maintain integrity for 300 years. Alternatively, the stability requirement can be satisfied by the use of an engineered structure at the disposal facility that would provide the required stability. One method by which a waste generator can provide the assurance of stability is to use a solidification medium or high integt :ty container that has been found acceptably stable by the NRC as a result of a technical review of a vendor's topical report.
In 1983 the NRC and regulatory authorittes in the Agreement States of South Carolina, Nevada and Washington agreed that a centralized review and approval of such vendor topical reports by the NRC would be the most efficient process and that wastes processed and stabilized in accordance with an NRC-approved topical report could be accepted for disposal at Barnwell, Beatty, or Hanford without further independent review by the respective Agreement State.
In the course of the NRC review of a vendor topical report the current disposal facility host State regulatory authorities are integrally involved.
The topical reports are submitted to three States for reference and concurrent review. Questions or concerns developed by Agreement States are submitted to the vendor for response. Copies of correspondence between the vendors and the NRC are provided to the Agreement States, and Agreement State representatives are informed of meetings between the vendors and NRC and invited to attend.
We have also contacted regulatory authorities in all Agreement States in which new disposal facilities are likely to be located and requested their position on whether waste form stability will be required, even though planned engineered dispsal facility structures may alone be sufficient to provide the required stability.
To date approximately thirty-four topical reports have been submitted to NRC for review. Seven of these solidification media and processes or high integrity containers have been approved. Fourteen have been withdrawn, not approved, or the review discontinued. Thirteen are currently under review. Many of those topical reports under current review describe cement solidification systems.
Industry experience has shown that successful cement solidificaticn of certain waste streams,
such as bead resins and decontamination solutions, can be difficult and that certain problem chemicals in waste streams can lead to process upsets. Because of the complexity of some of these technical issues, no cement topical reports have been approved to date. During this period of review, however the NRC, South Carolina, NevadaandWashingtonheveagreedthatcontinueddisposalofcement-solidifiedwaste forms is acceptable. Even though the cement solidification review process has continued over the period of several years, it is not likely that tie most complex of the technical issues will be resolved in the near term. Given this fact, the NRC currently plans to approve the use of cement for those individual waste streams for which there are no outstanding unresolved issues and to continue review of those other streams with associated technical concerns. We will be discussing with the three Agreement States whether the " grandfathered' use of cement for solidification of question se. ^ste streams should be continued. This decision.
making process upon which we wil
,e embarking with the Agreement States will be important, since cement s111dif.ation is widely used in this country.
SU W RY
! use the above examples to underscore the fact that it is vitally important for Agreement State low-level waste regulatory authorities and the NRC to coordinate in the establishment and implement 6 tion of our programs, to share experiences and issues, and benefit froia the lessons learned by others. As we know, assuring safe low-level radioactive waste disposal is of national importance. Because of the public concern about new f acilities, litigation that may be filed on low-level waste issues, and media attention that is drawn to low-level waste, it is in the interest of all regulators to assure that each licensing decision that is made provides the demonstrable reasonable assurance of safety required by our respective regulations.
Acting consistently throughout the country in terms of technical rigor of review and application of acceptance criteria for requirements will promote credibility in all of our actions. I welcome your support in furthering the goal of cooperation and coordination among all low-level radioactive waste management regulatory authorities.
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