ML20058M523
| ML20058M523 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1993 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Stoiber C NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| References | |
| REF-WM-3 NUDOCS 9310060079 | |
| Download: ML20058M523 (6) | |
Text
. MEMORANDUM FOR: Carlton R. Stoiber, Director Office of International Programs SEP 2 8199)
FROM:
Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
COMMENTS ON DRAFT INTERNATIONAL ATOMIC ENERGY AGENCY SAFETY FUNDAMENTALS DOCUMENT "THE PRINCIPLES OF RADI0 ACTIVE WASTE MANAGEMENT" 9445y/1993-06-30 (ED0 CONTROL 0009269)
In response to your request to James M. Taylor, Executive Director for Operations, dated August 17, 1993, I am transmitting the comments of the Office of Nuclear Material Safety and Safeguards concerning the document referenced above.
The subject document has been in preparation for more than two years and the Nuclear Regulatory Commission has been afforded several opportunities for review of earlier drafts.
It has also been suggested that this document may serve as a basis for an International Convention on Radioactive Waste Management.
Consequently, our present review has considered the response of the current document to previous NRC comments and whether its use in an International Convention on radioactive waste management would cause any conflict with NRC policies, regulations and practices.
Our review indicates that there are no matters which were raised in earlier comments which have not been addressed, at least to some degree, in this version of the draft.
Our comments are directed at resolving our remaining concerns (See Enclosure).
Thank you for offering us the opportunity to comment on this document.
Should you have any questions on our comments, please call Michael Bell, Chief of the Low-Level Waste Management Branch, on (301) 504-3785, or Jack Lentz of the Licensing and Coordination Section, on (301) 504-2038, who are both in the Division of Low-level Waste Management and Decomgog Robert M. @ @ dvd@ C9 rector r
/p Office of Nuclear Material Safety
Enclosure:
As stated and Safeguards gg g
g 0
TICKET: EDO 9269
- See Previous Concurrence 4i DISTRIBUTION: Central File LLWM r/f JSurmeier JThoma NMSS r/f CPoland t/f JTaylor EDO r/f HThompson JBlaha JKnubel SECY DMorris EDO Dir. r/f 0FC LLWB h LLWB O h
LlyB I
LLDR LLDRAk 4 m JKennedy\\
MBe[1 WLahs d
,JAukin NAME JLentz
[_DATE 9/2//93 Nh93 M 7 /1V93 U
7 /.u/93 9 /4 2/93 0FC LLUR LLUR M M LLWM Ll,W[
FCSSN NAME AMullins d
- MFliegel PLohhusA I&rkeve/
/
cu m s
TSherr DATE
(/ ////93
/ /7//93 9 [ /93 3/N93l 9 /2 //93 0FC HLWM
[
IMNS h
NMSS//,
NMS[f, i
1 NAME JHolonichbh FCombs k GArIkt EMn'eko-DATE 9/%2/93
[/2/ /93
- 8) /2 793
'C,/LP/93
/ /93 S:\\LLWMTYPE\\ KAREN \\Ep0-9269.JDL OFFICIAL RECORD COPY S:\\LLWMTYPE\\IAEAFUND.JJL In small Box on ATE" line enter: M = E-Mail Distribution Copy; H = Nard Copy PDR: YES Category:
Proprietary __ or CF Only d,,fdl/
g, e, e J
ACNW: YES fi0 Yes /
l IG: YES NO Delete file after distribution:
No _
Ornn 931006o079 93092e c
r _
i MEMORANDUM FOR:
Carlton R. Stoiber, Director Office of International Programs SEP 2 8199)
FROM:
Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
COMMENTS ON DRAFT INTERNATIONAL ATOMIC ENERGY AGENCY SAFETY FUNDAMENTALS DOCUMENT "THE PRINCIPLES OF RADI0 ACTIVE WASTE MANAGEMENT" 9445y/1993-06-30 (EDO CONTROL 0009269) l In response to your request to James M. Taylor, Executive Director for Operations,
)
dated August 17, 1993, I am transmitting the comments of the Office of Nuclear l
Material Safety and Safeguards concerning the document referenced above.
The subject document has been in preparation for more than two years and the Nuclear Regulatory Commission has been afforded several opportunities for review l
of earlier drafts.
It has also been suggested that this document may serve as a
~t basis for an International Convention on Radioactive Waste Management.
Consequently, our present review has considered the response of the current document to previous NRC comments and whether its use in an International Convention on radioactive waste management would cause any conflict with NRC policies, regulations and practices.
Our review indicates that there are no matters which were raised in earlier comments which have not been addressed, at least to some degree, in this version i
of the draft. Our comments are directed at resolving our remaining concerns (See Enclosure).
1 Thank you for offering us the opportunity to comment on this document.
Should you have any questions on our comments, please call Michael Bell, Chief of the low-Level Waste Management Branch, on (301) 504-3785, or Jack Lentz of the licensing and Coordination Section, on (301) 504-2038, who are both in the DivisionofLow-levelWasteManagementandDecog,g.jopg l
Robert M. $W/vM@0 rector r
A Office of Nuclear Material Safety
Enclosure:
As stated
/'
and Safeguards Jg Lm TICKET:
EDO 9269
- See Previous Concurrence 4i DISTRIBUTION: Central File LLWM r/f JSurmeier JThoma NMSS r/f CPoland t/f t
JTaylor EDO r/f HThompson JBlaha JKnubel SECY DMorris EDO Dir. r/f h
LLWL3 L
L LW _ a -
E LLDR LLDRM 0FC LLWB JKennhdy\\
MBe[1 WLahs d
,JAukin NAME JLentz DATE
'/ /,2//93
/k/93 Y
/ /2V93
'l 7 /.t2/93 94493 L[
0FC LLUR LLUR.[ M LLWM
- FCSS, NAME AMullins 6 "i MFliegel PLohfus heve's TSherr DATE 9/M/93
/ /;1//93 0 b /93 9 /7/)93
/
/93 h
0FC HLWM h
IMNS h[ h NMSS7/),
NMSjI/),
NAME JHolonich h FCombs k GArlokt keYo DATE
$/$/93 ef/22$/93
~8) /7 793
'C, /Ll//93 93 S:\\LLWMTYPE\\ KAREN \\E00-9269.JDL OFFICIAL RECORD CDPY S:\\LLWMTYPE\\IAEAFUND.JJL In small Box on "DATE" line enter: M = E-Mail Distribution Copy; H =_Hard Copy PDR: YES NO Category:
Proprietary or CF Only ACNW: YES NO IG: YES NO Delete file after distribution:
Yes No _
l l
Consolidated Comments of The Office of Nuclear Material Safety and Safeguards on IAEA Draft Fundamentals PRINCIPLES OF RADIOACTIVE WASTE MANAGEMENT 9445y/1993-06-30 FOREWORD First Paratraph Revise first sentence as follows:
Radioactive waste is generated from the extraction of uranium and the manufacture and processing cf nuclear fuels and materials, from the production of nuclear energy and from the use of radioactive materials in industrial applications, research and medicine.
Add the following sentence to the end of the paragraph:
The scope of the RADWASS Safety Fundamentals is limited to basic. principles
~
for management of radioactive' wastes. Companion-Safety Fundamentals-documents are being developed. to address The Safety of Nuclear Installations and Basic Radiation Protection Principles which are consistent with but broader in scope than principles for management of radioactive waste, Second Pararraph I
\\
Add the following sentence to the end of the paragraph:
RADWASS publications should be consistent with the material control and accounting requirements 'of IAEA safeguard agreements.
j Revise the following sections as shown:
10].
Research and development.in the field of nuclear science and technology j
b.e been ongoing since the beginning of the twentieth century leading to wide-scale applications in research, medicine, agriculture, industry and in the generation of electricity by nuclear fission.
" i^; ti..
rcte-Ina
- rcuit fre These uses, and the processing of raw materials that contain naturally occurring radionuclides.
I c--
ui" ctE neti iticc, t%cc prrr*f ra produce waste that requires management to ensure the
.l protection of human health and the environment, and to limit the burden on i
future generations. : Guiding ~ concepts for such management, to'the degree reasonably. achievable, fare:the minimization of,the generation of radioactive I
waste'and the minimization of radioactive releases to'the environment.
To achieve the objectives of safe radioactive waste management requires an effective and systematic approach to waste management within a legal framework in which the roles and responsibilities of all parties are defined.
105.
Fundamental safety principles for radioactive waste management have evolved through the experience of IAEA Member States and the continuing process of establishing international consensus through the preparation of Enclosure i
I l
~
j IAEA documents on radioactive waste management. The Radioactive numerous
~
Waste Safety Standards (RADWASS) series of documents;Lfor which;this Egndamentals "of" Radioactive Was te' Management provides overall; guidance, integrates this experience into a coberent set of principles, standards, guides and practices for achievir; safe radioactive waste management.
i 107.
This document presents prirciples for the management of radioactive waste from the&* its generation ta ehe&v its disposal.
Detailed matters affecting facility f operation. waste characteristics. and' classification, o
safeguards, criticality, transportation, ocean disposal, or fuel' reprocessing, among others,lare outside:the scope of1this document.
- ge - t af radi: aet he uccte hac ::
de:u.
- cr that uill p.^t::: b=
' :lth d *N
-- I rr u 't, mu and i: tFr f tcre, f r-tF ' H-t cd
=d ate" uith cuc' 109.
Annex 1 describes a generic approach to systematic management of radioactive waste to provide a common understanding of terms among users of i
RADWASS documents. -Note'that the. guiding concepts for the7 approach. to the degree reasonably achievable 'are:the minimization of both waste generation
~
and of releases of radioactivity to the environment throughout the radioactive waste management process. Th; %_et Following Annex 1 c1:.
c:
there is a glossary of terms frequently used in radioactive waste management.
s 201.
The objective of radioactive waste management is to handle, pretreat, treat, condition, transport, store and dispose of radioactive waste in a manner that protects human health'and the environment without imposing undue burdens on present or' future generations and that seeks to limit the
~
generation of radioactive waste.
304 The management of radioactive waste..such exposure is within acceptable limits and as low as reasonably achievable.
305.
Dose limitations to workers and members of the public are developed-w4+h by national. regulatory bodies taking cognizance ofiappropriate ICRP recommendations and which cre bar<d may(include the concepts of.
Principle 5:
Protection of future generations Radioactive waste shall be managed in a way that pr^dicted projected impacts on the health of future generations do not exceed levels that are acceptable today.
319.
Long ter-encge t Disposal of radioactive waste should, to the extent
-t possible, not rely on long term institutional arrangements'or on on going maintenance as a-necessary safety features. However.
326.
The principal steps of radioactive waste management are pre planning for s
disposal,' handling..
Principle 7:
Integrated Approach j
An integrated approach shall be used that:
1 e
l
i i
a) keeps generation of radioactive waste as low as reasonably achievable l,-and b) takes into account the interdependencies among waste generation and management stepsy, and t
c) keeps releases of radioactivity into the accessible environment as low as; reasonably achievable, 326.
The principal steps of radioactive waste management are pre-disposal planning, handling, pretreatment.
328.
The integrated approach includes keeping the releases from all'the various waste management steps as low as reasonable achievable...
ANNEX 1 i
GENERIC APPROACH TO SYSTEMATIC MANAGEMENT OF RADIOACTIVE WASTE First Paragraph, page 12 Effective management of radioactive waste considers the various stages in the radioactive waste management process as part of a total integrated
~
system, from the point of generation, uhir' uct ': trN
. :tc nec: :t. ' the plar
'ag, ?ac:gn
-4 eper;ti cf-arlear facility, to he-disposal.
i Guiding concepts for waste management,-to-the degree reasonably achievable, arefthe minimization of the' generation of radioactive waste.and the minimization.of-radioactive 1 releases to the environment from each step;in'the m'nagement: process,' in accordanceLvith:thefconc'ptiof'keepingiradioactive a
e exposure as. low as reasonably-achievable ~J(ALARA)- 'These goals'mustLbe taken into account'in'the. planning design, operationLand closure ofEany_ nuclear facility.
In this " integrated approach" to the management of radioactive waste (shown schematically in Fig. A.1), account is taken of the interactions between the various stages, in order to arrive at an acceptable, preferably optimized, radioactive waste management strategy r-4 t: ' cp t': ge erctir of red! ntn_
m t: *:
t'.
- I: im - rence:=bly nchi: abl^.
Because radioactive waste decisions made at one stage may foreclose certain alternatives at a subsequent stage, the RADWASS Programme emphasizes the " integrated approach" to radioactive waste management.
Second Paragraph, page 12 In order... waste management process.
The considerations are intended to
.i be general, and to apply to the management of radioactive wastes from those
]
arising in the nuclear fuel cycle, to those generated in the medical and industrial application of radioactive materials ~,/and'are intendedjto They apply to radioactive wastes generated both during the operational-peried. _
ucl!
- "" ring and the decommissioning of a facility.. and to wastesJplaced in s.torage oriinLfinalidisposal' Third Paragraph, page 12 (extends to Page 13) i i
l l
1-r r
Pretreatment of radioactive... waste streams, e.g.'for recycling within th& process or for disposal as ordinary non-radioactive waste when the quantities of radioactive materials they contain **e pose anLinsignificant riskf tol humarE1iealthTandE he environment and' are thus exemptable from t
s regulatory contcols..
First full paragraph, page 14 Disposal... dispersion.
It may, on the other hand, involve the emplacement of radioactive waste in a repository, or in a given location, without the inter ~ien possibility of retrieval (concentration / containment), if needed; untiljfinalfelo'sure;of.the facilitylisfachieved.
In either case, disposal is intended to allow society to end reliance on surveillance and the'
~
application lof?reme' dial measures;
. t nnner while still maintaining safety.
Glossary disposal.
The emplacement of waste in an approved, specified facility (e.g. near surface or geologic repository) withe *+ the irtertina possibility of retrievalis if needed.Luntil the facility has been Lpermanently closed.
7 Disposal..
s safeguards, IAEA.
A verification system within the framework of the international non-proliferation policy applied to peaceful uses of nuclear energy and entrusted to the IAEA by its Statute, orfby the Treaty on &he-Non-Proliferation of Nuclear Weapons and-dr by the Treaty for the Prohibition of Nuclear Weapons in Latin America (Tlatelolco Treaty).
1 P
a i
l t
I
)
t
.1 i
i i
I J
l