ML20056A312
| ML20056A312 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1990 |
| From: | Dunkelman M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Joseph Austin, Bangart R, Greeves J NRC, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9008060363 | |
| Download: ML20056A312 (7) | |
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MD/ ECOL /7/20 1-JUL 311990 MEl10RANDUM FOR: Those on Attached List Fr.0M:
Maxine Dunkelman, Project Manager Operations Dranch Division of low-Level Weste Management and Decomissionirg, HMSS i
SUBJECT:
SlM ARY OF DISCUSSIONS WITH U.S. ECOLOGY Enclosed is a sumary of the discussions between the U.S. Nuclear Regulatory Commission (NRC) staff and U.S. Ecology staff involved in low-level waste disposal in California. Also enclosed is a list of attendees. The telephone conference was held on July 11, 1990.
The purpose of the r,cnference was to discuss coments that U.S. Ecology might have on NRC regulatory guidance documents including the Stano3rd Format and Content Guide (NUREG.1199) and the StandardReviewPlan(NUREG.1200).
Any comments or questions on the attached uceting summary may be directed to Maxihe Dunkelman at (301) 492 0580.
ORIGINAL SlGUED BY Maxine Dunkelman, Project Manager Operations Branch Division of Low. Level Waste Management and Decomissioning, HMSS
Enclosures:
1.
Sumary of Telephone Conference July 11, 1990 2.
List of Attendees Record note: Enclosure I was reviewed and edited by R. Rittenberg of US Ecology.
His changes have been incorporated.
Distribution: e CentralLFile T ( d NMSS r/f LLOB r/f PDR YES X
PDR NO Category:
Proprietary or CF Only
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f Addressees - Memorandum Dated 07/20/90 R. Bangart LLWM J. Greeves LLWM i
J. Austin LLRB P. Lohaus LLOB J. Surneier LLTB M. Tokar LLTB J. Starner LLTB J. Kennedy LLOB A. Huffert LLRB M. Blackford HLGP T. Johnson LLOB M. Cunkelman LLOB J. Shaffner LLOB J. Kane LLTD K. $chneider OSP D. Michaels OGC D. Sollenberger OSP F. Ross LLTB L. Deering LLTB L. Bykoski LLRB L. Pittiglio LLRB K. McDaniel IMNS l
B. Jagannath LLTB S. Romano US Ecology l
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4 ENCLOSURE 1
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SUMMARY
OF TELEPHONE CONFERENCE BETWEEN NRC STAFF AND US ECOLOGY, INC.
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At the invitation of NRC staff, Steve Roamano, Robert Rittenberg, and Tom Hanrahan of US Ecology, Inc's California office presented to NRC staff their co w nts and suggestions for improvement of NRC guidance. We specifically discussed theStandardFormatandContentGuide(SF&C)(NUREG1199)andtheStandard Review Plan (SRP) (NUREG 1200).
The following topics were raised by US Ecology:
1)
Integration of NUREGs 1199 and 1200.
US Ecology suggested that these two documents be more closely integrated, perhaps even made into one document. Currently, there are some discrepancies between the two documents. US Ecology used NUREG-1200, the Standard Review Plan (SRP), more than NUREG-1199, the Standard Fonnat and Coatent Guide (SFAC). US Ecology used the SRP for their quality assurance check to make sure that they had covered all areas that they needed to.
1 Steve Romano said US Ecology was glad that the two documents existed and that although they were not perfect, one could never expect them to be perfect.
He continued that US Ecology would have had a much more difficult time if the guidance was not available and that it was better for the guidance to l
ask for too much rather than too little or else the applicant would have to respond to numerous requests from the regulator after the application is submitted.
He concluded this subject by saying that t1e two guidance documents were very valuable, but if they remain as separate documents, NRC should verify that all items mentioned in NUREG-1200 are in NUREG-1199.
2)
Areas of Repetition.
US Ecology pointed out that the certain topics are discussed in the guidance in multiple places but under different contexts.
For example, site characterization is discussed under both its own section and under geotechnical information. The buffer zone is an example of another topic for which different sections repetitively ask for the justification for the size chosen.
Design information and surface water information are two other areas that are repeated.
US Ecology suggested these topics and others be consolidated where possible or cross-referenced..US Ecology summarized that the documents are workable as they are now, but the repetition within the guidance documents leads to a large degree of repetition in the application thus requiring additional reviews by the applicant to ensure that their application is internally consistent.
3)
Areas Beyond the Scope of 10 CFR Part 61 Health and Safety issues.
US Ecology indicated that some topics described in the guidance documents were more logically topics for environmental impact statements (EIS) or environmental assessments (EA) rather than topics addressing 10 CFR Part 61 health and safety issues. US Ecology pointed out that this comment l
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j does not reflect a big problem because the work has to be done anyway; i
however, each Agreement State has its own EIS/EA requirements. Topics that US Ecology identified are: details of utilities, i.e., how utilities l
are to be buried and laid; details within the biological sectior, other than those dealing with facility performance concerns such as root depth l
or burrowing; facility construction scheduling including critical l
paths and resource levels; and details of facility decontamination and decomissioning.
NRC stated that the guidance documents only requested information on utilities where their failure could adversely impact health and safety.
US Ecology felt that parties involved in licensdng may assume NRC desires more detail to be provided for disposal facility decontamination and decomissioning than NRC intends US Ecology Stated that it was not necessary or fruitful to discusc 1 eta 11s of decontamination and decomissioning for closure at the time of a license application because so many things could change over the operating lifetime of a facility.
It was noted that a separate licensing decision regarding closure is required. Specifically, they suggested that detailed pathway analysis and source estimates were not needed prior to the initial license to construct and operate the facility.
US Ecology pointed out that in general it is a good policy not to put anything extra in an application that is not needed to license a site.
4)
Findings Required by 10 CFR Part 61.23.
US Ecology recomended that the guidance documents provide a succinct summary of what the reviewer should do to show that each finding listed in 10 CFR Part 61.23 is met.
US Ecology feels that it is important l
for the public to be able to easily understand that all of 10 CFR 61.23 has been met, i.e., that the "
Safety Evaluation Report (SER) job has been done." NRC responded that the l
fills this role NRC will review the l
introduction to NUREG-1200 to ensure that the role of the SER is clearly explained.
5)
Flexibility on Addressing Operational Topics.
US Ecology would like to see the guidance documents allow more flexibility on how to address operations. US Ecology's operations do not make a distinct difference betveen waste handling and waste disposal because most of their waste handling activities merely precede and are integral to disposal.
However, NRC's guidance documents divide operations into separate sections on waste handling and disposal.
US Ecology did describe these two functions as two distinct topics in their application.
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6)
Flexibility in Sections on Operator Qualifications for Agreement States.
Although these sections would be necessary for NRC's review of a license pp11 cation, US Ecology pointed out that they may not be salient for a license application for an Agreement State because the operator's qualifications are generally examined and formally documented in great detail at the time of operator selection.
Earlier documentation as to operator selection and qualification is gemane and should be relied upon, thus avoiding repetitive work, 7)
Financial Assurance Guidance is not Relevant for Agreement States.
US Ecology poi 6ted out that the financial assurance sections may not be directly applicable to some license applications because specific State regulations apply.
8)
Inclusion of Guidance Documents Originally Intended for Other Types of Facilities.
US Ecology stated that NUREG-1200 would be enhanced if a distinction was made between the various referenced guidance documents as to their importance. Perhaps, a broad statement should be included that guidance specific to low-level waste was to be used thoroughly, but guidance written for uranium mill tailings, high-level waste repositories, or nuclear power plants be used for specific guidance. NRC should be specific as to what guidance should be gotten from these referenced guidance documents. Otherwise, unnecessary costs can result from detailed reviews of non-germane guidance by multiple staff and contractors.
US Ecology assumed that less weight would be given to NUREG/CR reports, that is NRC reports that are written by contractors, than to NUREG reports written in-house by NRC. NRC stated that this is not true for the US Corps of Engineer reports, NUREG/CR-5041, " Recommendations to the NRC for Review Criteria for Alternative Methods of Low-Level Radioactive Waste Disposal." Because alternative methods are not proposed in California, this was not an issue.
After US Ecology discussed all the points they wanted to make, NRC raised a few issues that had been raised by others:
1)
Use of Part 50 References.
US Ecology was not particularly troubled by the SRP referring to Part 50 as a requirement insteed of guidance as this was satisfactorily resolved in pre-licensing consultations with the Agreement State licensing agency.
2)
Procedures for Evaluating Seismicity and Tectonics.
US Ecology did not have any difficulties with these sections of the guidance documents. They found the sections to be ?dequate and exercised judgement, where necessary, in consultation with the Agreement State licensing agency.
3)
Seismic Design Procedures.
US Ecology did not find seismic design procedures to be an issue in California, but suggested we talk to those 'qvolved in their $ebraska facility as that facility has more engineered components.
4)
Flood Plain Evaluation Procedures.
US Ecology did not find this area to be of concern because they already had to deal with flood plain evaluation in much more detail during the candidate sites selection phase of their licensing process. They did suggest however that perhaps more could be said on how FEMA requirements are believed to apply.
5)
Erosion Protection.
US Ecology did not have problems in this area either. They stated that the detail needed was dictated by site characteristics and was essentially resolved through pre-licensing consultations with the Agreement State agency.
After review of these issues, NRC asked how US Ecology decidee on how much detail to put into the license application. US Ecology responded that the State regulators stated during prelicensing consultations that they wanted to see much of the raw data (which were included as appendices) and that these appendices made up much of the bulk of the application. They continued that it is easier for both the applicant and regulatory agency reviewers to have all of the information available with the first submittal then to have to supply information later upon request in piecemeal fashion.
In addition, US Ecology stated that this matter is not one on which they would have made any critical comments and that it is probably not realistic to expect that a sufficiently complete license application and supporting documentation could be significantly condensed from what US Ecology submitted.
At the conclusion of the meeting, US Ecology said that they found the guidance to be very helpful.
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1 ENCLOSURE 2 ATTENDEES - JULY 11, 1990 t
1H CAllFORNIA Rob Rittenberg U.S. Ecology Steve Romano U.S.. Ecology Tom Hanrahan U.S. Ecology E ROCKVILLE.
Maxine Dunkelman LLWM, NRC Jim Shaffner LLWM, NRC Dorothy Michaels OGC, NRC John Greeves LLWM, NRC Michael Tokar LLWM, NRC Joseph Kane LLWM, NRC Fred Ross LLWM, NRC Tony Huffert LLWM, NRC Kathleen Schneider GPA, NRC 1
Michael Blackford HLGP,'NRC
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