ML20044H037
| ML20044H037 | |
| Person / Time | |
|---|---|
| Issue date: | 03/29/1990 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20044H034 | List: |
| References | |
| HPPOS-264, IEIN-90-009, IEIN-90-9, NUDOCS 9306070258 | |
| Download: ML20044H037 (3) | |
Text
o f* M%
i'g UNITED STATES
,8 Yg"c r c
NUCLEAR REGULATORY COMMISSION
&. N { [p.,s WASHING TON. D. C. 20555 5
MAR 2 91990 4,
MEMORANDUM FOR:
Regional Directors Division of Radiation Safety and Safeguards Branch Chiefs Division of Industrial and Medical huclear Safety, NMSS FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
POLICY AND GUIDANCE DIRECTIVE FC 90- 3 ; LICENSING 0F LOW-LEVEL RADI0 ACTIVE WASTE STORAGE BY MATERIALS AND FUEL CYCLE LICENSEES This directive provides guidance for the review of amendment requests for extended interim storage of low-level radioactive waste (LLW) by materials and fuel cycle licensees.
Information Notice 90-09 (enclosed) contains general guidance for licensees on the information needed in such requests ano should be used to determine completeness of an amendment request..The guidance contained in this directive generally tracks the content of IN 90-09.
In a memorandum dated February 14, 1990, the' Comission informed the staff that "...the Commission will not look favorably upon long-term on-site storage beyond January 1,1996." That date is the final milestone of the Low-Level Radioactive Waste Policy Amendments Act of 1985. States which, either acting alone or as part of a Regional LLW Compact, are unable to provide for LLW disposal by that date must take title to and possession of LLW generated in their State as well as be liable for any direct or indirect damages for failing to do so promptly. Any amendment requests received for on-site LLW storage to extend beyond January 1,1996 should be coordinated with Headquarters.
If you have questions concerning this directive, please contact George Pangburn at FTS 492-0628.
/)b & 0 Richard E. Cunningham, Director Division of Industrial and Medical huclear Safety, NMSS
Enclosures:
1.
Guidance for Review of Amendment 2.
Information Notice 90-09 9306070258 900329 PDR ORG NRRB PDR g
t GUIDANCE FOR REVIEW 0F AMENDMENT REQUESTS FOR EXTENDED INTERIN STORAGE OF LOW-LEVEL RADI0 ACTIVE WASTE 1.
Review the amendment request for general completeness against the guidance contained in Information Notice 90-09, "Exterded Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees."
2.
Are the current possession limits adequate for the waste to be stored?
If not, has the licensee requested appropriate changes to those limits to cover the amount of waste to be stored?
3.
Consider the characteristics of the waste as identified by the licensee:
primary radionuclides, waste classification, physical form and, if applicable, specific non-radiological properties. Are there any characteristics which could pose a potential health and safety problem in the proposed storage area? Has the licer.see recognized and attempted to mitigate these problems?
4.
What changes, if any, in type or amount of waste processing on-site have been proposed?
5.
Are additional permits / approvals from other agencies necessary for on-site storage or additional waste processing? has the licensee clearly indicated status of other approvals?
6.
Review the licensee's information/ plans for final disposal of stored LLW.
It should be clear as to where the waste will be shipped for disposal, when that facility will be available and when the inventory of waste will be entirely moved out.
Licensees should not plan to store waste beyona January 1,1996. Any amendment request which proposes to store LLW beyond this date should be coordinated with Headquarters.
7.
Review the licensee's physical description of the storage area. Does the storage area appear large enough to accommodate the projected waste volume? Will placement of the waste allow ready visual inspection of containers and access, if necessary? How will the waste be secured against unauthorized removal?
8.
Has licensee shown that waste will be sheltered from the elements as well as from extremes of temperature and humidity? Whenever possible, waste containers should be stored indoors.
9.
Review the ventilation system for the storage area. Does it appear adequate to prevent buildup of gas from waste decomposition that may occur?
- 10. What measures have been proposed to minimize the likelihood of a fire occurring? What equipment / systems will be in place to extinguish a fire, if one does occur?
- 11. Review the licensee's information on packaging and container integrity.
Does the waste form or conditions of storage present a hazard to the containers? Has the licensee committed to quarW rly (minimum) direct cr remote visual inspections of containers? What contingency plans are proposed for dealing with repackaging damaged or leaking containers?
ENCLOSURE 1
- 12. Review the licensee's program for placement of waste in storage.
SpecMi ally, assure that stacking of containers will result in a stable configuration and will not result in container deferraation. Waste being stored for decay should be segregated from waste being stored for disposal at a LLW disposal facility.
In addition, higher activity waste containers should be surrounded with lower activity waste containers whenever possible tc maximize shielding.
13.
Review the licensee's radiation protection program'for the storage area, including ALARA measures, radiation surveys, posting, air sampling ano personnel monitoring and effluent samplir.g.
Is it adequate for the scope and duration of storage?.
14 Review the licensee's training program, specifically as it relates to storage of waste.
Is the program adequate from the standpoints of content, frequency, documentation and personnel?
- 15. Do requested possession limits exceed those of applicable Sections 30.35, 40.36, or 70.25?
If so, is decommissioning funding plan or certification of financial assurance included? Review against criteria in NUREG-1337 for decommissioning financial assurances and verify that cost estimates-include reasonable amounts for handling, transport and disposal of all LLW on-site.
16.
Do req)uested p(j) session limits exceed those of applicable Sections 30.32 os (i)(1, 40.31 (1)or70.22(i)(3)? If so, has licensee incorporated a demonstration that an emergency plan is not needed or has licensee committed to develop and prepare a plan that meets the emergency planning requirements of the applicable sections?
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C.
20555 February 5,1990 NRC INFORMATION NOTICE NO. 90-09:
EXTENDED INTERIM STORAGE OF LOW-LEVEL RADI0 ACTIVE WASTE BY FUEL CYCLE AND MATERIALS LICENSEES Addressees:
All holders of NRC materials licenses.
Purpose:
This information notice provides guidance to fuel cycle and materials licensees on information needed in license amendment requests to authorize extended interim storage of low-level radioactive waste (LLW) 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 below, need to store their LLW for periods longer than in the past.
It is expected that recipients will review this information notice, distribute it to management and staff involved with licensed activities, including responsible radiation safety staff, and consider actions, as appropriate, to assure compliance with NRC re-quirements.
No specific written response to this information notice is required.
Description of Circumstances:
The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA) estab-lished a series of milestones, penalties and incentives to ensure that States or Regional Compacts make adequate progress toward being able to manage their LLW by 1993. On January 1, 1993, the existing LLW disposal sites are expected to either close or to stop receiving LLW from outside their Regional Compacts.
What this means to licensees who generate LLW is that, unless their State or Regional Compact either has a disposal facility operational on January 1,1993 or has made other arrangements for storage or disposal, such licensees may have to store their LLW onsite until disposal capacity is available.
Storage of LLW in accordance with NRC requirements may be necessary for anywhere_from several months to several years.
Discussion:
Not all licensees who will need to store LLW onsite will need amendments to their licenses to do so. However, if the possession limits specified in a license need to be increased to allow storage, or if the terms and conditions of a license
~9001300424 -
ENCLOSURE 2
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-to this notice identifies information which licensees will This information may also ment.
need to provide to NRC in such amendment requests.
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-Regional disposal The following considerations are central to extended capacity is available.
storage, and are the basis of the information included in Attachment 1.
Other than storage for radio-Storage is not a substitute for disposal.
active decay, LLW should be stored only when disposal capacity is 1.
Licensee planning unavailable and for no longer than is necessary.
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 form ready for transport and disposal at the end of the storage period, 2.
and clearly labeled in accordance with 10 CFR Subsection 20.203(f) and Section 20.311. Adequacy of the waste form or package may have to be reassessed before disposal.
To ensure integrity of packaging and maintenance of waste form, stored waste should be shielded from the elements and from extremes of temperature and 3.
humidity.
Waste should be stored in an atea which allows for ready visual (direct 4.
or remote) inspection on a routine basis. Licensees should' plan to conduct and document such inspections at least quarterly.
Depending on the specific waste involved, licensees may need to have 5.
procedures and equipment in place or readily available to repackage the waste, should the need arise.
Decomposition and chemical reaction of incompatible waste materials over 6.
time can result in as generation or other reaction products. Licensees should evaluate w'... 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.
For most waste forms, storage of waste in containers suitable for disposal 7.
will not represent a significant increment of direct radiation exposure However, licensees should consider their specific potential to workers.
waste and storage plans and determine if additional shielding or other actions are warranted to keep exposures as low as is reasonably achievable (ALARA).
Stored waste should be located in a restricted area and secured (e.g.,
8.
j in a locked room) against unauthorized removal for the term of storage,
i IN 90-09 February 5,1990 Page 3 of 3 i
NRC does not advocate extended storage of LLW, as long as disposal capacity is available to licensees.
However, NRC recognizes that storage is allowed for, 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 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 licenues will need to store LLW which also contains hazardous waste as specified under the Resource Conservation and Recovery Act, as amended (RCRA).
These mixed wastes, as they are called, are 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.
Questions on your specific license or general procedures for license amendments ana 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.
[
d eg Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical Centact:
George Pangburn, NMSS (301) 492-0628 Attachments:
1.
Infonnation Needed in an Amendment Request to Authorize Extended Interim Storage of LLW.
2.
Regional Compacts and Unaffiliated States.
3.
List of Recently Issued NMSS Information Notices.
a.
List of Recently Issued NRC Information Notices.
l 4
IN 90-09 February 5, 1990 Page 1 of 3 INFORMATION NEEDED IN AN AMENDMENT REQUEST TO AUT EXTENCED INTERIM STORAGE OF LOW-LEVEL RADI0 ACTIVE W The following paragraphs icentify the information which NRC conside in an amendment request from a naterials or fuel cycle licensee to authorize extended interim storage of low-level radioactive waste (LLW).
1.
Identification of Waste to be Stored Specify any possession limit increases needed for extended interim 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 LLW to be stored:
c.
(1) Volume 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.
(i.e., EPA hazardous waste permit, State or lo e.
and the status of each required approval.
2.
Plans for Final Disposal a.
and onsite storage will begin.Specify when disposal capacity w b.
disposal of your LLW and when that facility is sc accepting LLW.
be able to provide this information if you do not have it.You Specify when you will begin shipping LLW to that f c.
out.
IN 90-09 February 5, 1990 Page 2 of 3 3.
Physical Description of Storage Area Identify the location and provide a diagram of the LLW storage area a.
which demonstrates where packages will be stored and how packages will be accessible for inspection purposes.
Include the locations of i
waste processing equipment (if applicable), air sampling stations, effluent filters and any sources of flammable or explosive material.
i b.
Specify the maximum volume of LLW that can be stored in the proposed waste storage area and relate this to annual volume of waste generated.
Specify the type of building / structure in which the waste will be c.
stored and demonstrate that the waste will be protected from weather at all times.
i l
d.
Describe the measures to control access to the LLW storage area and thereby ensure security of the waste.
i Describe the ventilation system and how it will assure adequate e.
ventilation of the storage area.
l f.
Describe the fire protection and suppression system to minimize the likelihood and extent of fire.
1 g.
Describe how the adverse effects of extremes lof temperature and humidity on waste and waste containers will be avoided, l
h.
Describe vulnerability to other hazards such as tornado, hurricane, j
flood, industrial accident, etc.
4.
Packaging and Container Integrity a.
Describe the packages or containers to be used for storage of LLW, 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.
c.
Describe your program and equipnent (if applicable) for remote handling ana/or repackaging damaged or leaking waste containers.
5.
Radiation Protection a.
Describe your program for safe placement and inspection of waste in storage anc maintaining occupational exposures as low as is reasonably achievable (ALARA).
This program should include periodic raciation and contamination surveys of individual packages and the storage area in general, as well as posting the storage area in accordance with 10 CFR Section 20.203.
IN 90-09 February 5, 1990 Page 3 of 3 b.
Describe projected exposure rates, needs for shielding (i any changes in personnel monitoring which will be require ano of waste storage, Describe your procedures for responding to emergencies c.
notification of and coordination with local fire, police and med
, including departments, d.
Describe your system for maintaining accurate records of wa storage licensees () to assure accountability.
including any waste receipts or transfers from or to other n
i 6.
Training Describe your program for training personnel in procedures for a.
response for LLW storage. packaging, handling, placeme 7.
Financial Assurance assurance for decommissioning. Review the relevant se a.
nancial limits exceed the limits specified in SectionsIf your proposed maximum submit with your amendment request a 30.35, 40 36 or 70 25 certification of financial assurance, decommissioning funding plan or, this submittal should demonstrate that financial resourcesIn eithe as appropriate.
be in place not only to decommission the licensed operation are or will to provide for the estimated costs of handling
, but also disposal of all LLW stored onsite.
, transport and ultimate 8.
Emergency Preparedness Review the relevant sections of Parts 30, 40 and 70 regardi a.
preparedness.
limits specified in Subsections 30.32 (t)(1), 40.31(j) ng emergency you will be required to either demonstrate t or 70.22 (i)(3),
s of the aforementioned sections.
ns
~
IN 90-09 February 5, 1990 Page 1 of 4 REGIONAL COMPACTS AND UNAFFILIATED STATES The following is a list of the existing Regional LLW Compacts and unaffiliated 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
- 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 Pennsylvania Lhost 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 1
Atlanta, GA 30326 404/261-7114 (Member States are Nebraska [ host State], Arkansas, Kansas, Louisiana, and Oklahoma.)
Central Midwest Compact Clark Bullard Chair, Central Midwest Compact Commission Director, Office of Energy Research University of Illinois 901 South Hatthews Urbana, IL 61801 217/333-7734 (Membe; States are Illinois [ host State] and Kentucky.)
Midwest Compact Gregg Larson Executive Director Midwest Low-Level Radioactive Waste Compact Commission 350 IJorth Robert, Room 588 St. Paul, MN 55101 i
612/293-0126
~
IN-90-09 o-February 5, 1990 Page 2 of 4 (Member States are Michigan [ host Statej, Iowa, Indiana, Minnesota, Missouri, Ohio and Wisconsin.)
Northeast Compact Denise Drace Executive Director Northeast Interstate Radioactive Waste Compact Coninission 195 Nassau Street, 2nd Floor 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 (Member States are California [ host State], Arizona, North Dakota and South Dakota.)
- 2. Sited Regional Compacts **
Northwest Compact Elaine Carlin Executive Director Northwest Compact Commission 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 80202 303/825-1912 (Member States are Nevada [ current host State], Colorado, New Mexico and Wyoming.)
l
Attachment'2
)
+
IN 90-09 February 5,1990 Page 3 of 4 Southeast Compact Kathy Visocki Executive Director Southeast Compact Commission 3901 Barrett Drive, Suite 100 Raleigh, NC 27609 919/781-7152 (Member States are South Carolina
[ current host State], Alabama, Florida, Georgia, Mississippi North-Carolina, Tennessee and Virginia.)
3.
Unaffiliated States ***
District of Columbia Frances Bowie Administrator Service Facility Regulation Administration Department of Consumer and Regulatory Affairs District of Columbia 614 H Street, NW, #1014 Washington, D.C.
20001 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 Low-Level Radioactive Waste Management Board Commonwealth of Massachusetts 100 Cambridge, 20th Floor Boston, MA 02202 617/727-9800 1
New Hampshire Bryan Stromh Deputy Director Public Health Services Division Department of Environmental Services State of New Hampshire 6 hazen Drive Concord, NH 03301 603/271-3503
~'
~
IN 90-09 i
February 5, 1990 Page 4 of 4 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 Island 9 Hayes Street Providence, RI 02908 401/277-3434 Vermont Jonathan Lash Secretary-Agency of Natural Resources
.i State of Vermont 103 South Main Waterbury, VT 05676 802/244-7347 Texas Lawrence R. Jacobi 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 not currently have an operational LLW disposal facility.
Sited Regional Compacts are those Compacts of States approved by Congress l
that do have an~ operational LLW disposal facility.
MAR 2 9 1990
~
MEMORANDUM FOR: Regional Directors Division of Radiation Safety ana Safeguards Branch Chiefs Division of Industrial anc Meaical Nuclear Safety, NMSS FROM:
Richard E. Cunningham, Director Division of Industrial and Nedical Nuclear Safety, hMSS
SUBJECT:
POLICY AhD GUIDANCE DIRECTIVE FC 90-03 ; LICENSING OF LOW-LEVEL RADI0 ACTIVE WASTE STORAGE BY MATERIALS AND FUEL CYCLE LICENSEES This directive provides guidance for the review of ameno' ment requests for extended interim storage of low-level radioactive waste (LLW) by materials and fuel cycle licensees.
Information hotice 90-09 (enclosed) contains general guidance for licensees on the information needed in such requests and should be used to determine completeness of an amendment request. The guidance contained in this directive generally tracks the content of IN 90-09.
In a memorandum dated February 14, 1990, the Comission informed the staff that
"...the Commission will not look favorably upon long-term on-site storage beyond January 1,1996." That date is the final milestone of the Low-Level Radioactive Waste Policy Amendments Act of 1985. States which, either acting alone or as part of a Regional LLW Compact, are unable to provide for LLW disposal by that date must take title to and possession of LLW generated in their State as well as be liable for any direct or indirect damages for failing to do so promptly. Any amendment requests received for on-site LLW storage to extend beyond January 1,1996 shculd be coordinated with Headquarters.
If you have questions concerning this directive, please contact George Pangburn at FTS 492-0628.
Richard E. Cunningham, Director Division of Industrial and Medical Nu' lear Safety, NMSS
Enclosures:
1.
Guidance for Review of Amendment 2.
Information Notice 90-09 DISTRIBUTION hRC Center File IMNS Central File NMSS r/f IM0B r/f GPangburn CTrottier JHickey RLBangart GSjoblom WCline, RII MShanbacky, RI GMcCann, RIII VMiller GBidinger JSwift NLMcElroy BMallett, RIII JKinneman, RI CCain, RIY JRoberts CHaughney WFisher, RIV JWhite, RI RThomas, RV MLamastra MMoriarty LBettenhausen, RI RPate, RV CHosey RII DPowers, RIV JGlenn CVillarreal (orig & copy + copy,of 5520 call-sheet)
DF~
ih0
- lPD y
- IMDB
- LLW g
- RLh(ngart
+.,f f
- MN5 e
MAN. :GPangburn/ ll:CTrottier
- JHiMey
- G 'cblom
- RECunningham:
6A?E I537fi790-~~iD37/3790""?5375 795" ?037V790~"id37 795-~iD375 795-
?--------
UrrALAA1. Mr.LUnD LUFT
_=
-.. ~.
,r Document flame:
l
~
PG/ LICENSING LLW Requestor's ID:
LOPEZ Author's Naire:
GPANGBURN Document Comments:
PG LLW STURACE BY MATERIALS & FUEL CYCLE LICENSEES h
P s
I i
i
.