ML20059F855
| ML20059F855 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1993 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Combs F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9311050126 | |
| Download: ML20059F855 (6) | |
Text
'0018 B L3 MEMORANDUM FOR:
Frederick C. Combs Chief o
Operations Branch Division of Industrial and Medical Nuclear Safety, Office of Nuclear Material Safety and Safeguards FROM:
Michael J. Bell, Chief Low-Level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
SUBJECT:
NMSS NEWSLETTER TO INCLUDE ARTICLE ON LLW STORAGE QUESTIONS AND ANSWERS Enclosed is an article written for publication in the NMSS Newsletter. As part of this article,13 frequently asked questions concerning a variety of LLW storage licensing issues are addressed. The questions and their answers will provide materials licensees with important information about LLW storage, amendments to licenses to store LLW, decay-in-storage, Information Notice 90-09 guidance, and other information concerning LLW and its management.
I These questions have previously been reviewed both by Regional management and Headquarter's management, including your division, and comments received have been incorporated into this final document. We ask that you review this document and submit it for publication in tne NMSS Newsletter.
If you have comments or questions about. the information contained in this document, please contact Richard Turtil at 504-3447.
DMMEi 5%TE0 BY Michael J. Bell, Chief Low-Level Waste Management Branch Division of Low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards i
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SUBJECT ABSTRACT: NMSS NEWSLETTER INCORPORATING QS AND AS ON LLW STORAGE
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NMSS Newsletter Submittal Page 1 of 9 NRC RESPONDS TO FRE0VENTLY ASKED OVESTIONS ABOUT LLW STORAGE Under the low-Level Radioactive Waste Policy Amendments Act of 1985, compacts i
with operating low-level waste (LLW) disposal sites can deny access to their sites. This authority became effective on January 1, 1993. The two compacts with operating disposal sites have elected to deny access to some States outside of their region. As of this date, generators of LLW in the States of Michigan, Rhode Island, and New Hampshire, and the Commonwealth of Puerto Rico, are not eligible for access to either of the two LLW disposal facilities at Barnwell, South Carolina, and Hanford, Washington. On June 30, 1994, the Southeast Compact, which regulates LLW shipments into the Barnwell facility, expects to deny access to all States located outside the Southeast compact.
Some 28 additio ial States, and the District of Columbia, will then have no access to any operating LLW disposal site.
Licensees are encouraged to monitor the status of current siting and disposal developments in their LLW compacts or States, and to anticipate potential needs for storage of LLW.
NRC recognizes the need for interim storage of LLW while new LLW disposal capacity is developed. However, NRC does not look i
favorably upon long-term, on-site storage of LLW, and NRC's preference is that LLW be permanently disposed of as soon as possible after it is generated.
NRC staff previously has developed the following guidance concerning the storage of LLW:
1.
Extended Interim Storage of Low-level Radioactive Waste by Fuel Cycle and Materials Licensees.
2.
Alternative Waste Management Procedures in Case of Denial of Access to Low-level Waste Disposal Sites.
3.
Generic Letter 85-14:
Commercial Storage at Power Reactors of Low-Level Radioactive Waste Not Generated by the Utility.
4.
Generic Letter 81-38:
Storage of Low-level Radioactive Waste at Power Reactors.
The following additional information answers various technical and licensing questions, about LLW storage, that generators have identified, and is meant to assist generators in meeting needs for interim storage of LLW.
If you have i
I additional questions about this information, please check with a technical contact listed below.
Region I:
Betsy Ullrich (215) 337-5040 Region II: John Potter (404) 331-5571 Region III: Loren Hueter (708) 790-5632 Region IV: Jack Whitten (817) 860-8197 Enclosure i
9 NMSS Newsletter Submittal Page 3 of 9 2.
What level of detail is required to fulfill criteria identified in Information Notice 90-09?
Each of the areas in Attachment 1 of Information Notice 90-09 should be explicitly addressed in the application. The information should be sufficiently detailed so that the NRC reviewer can conclude that the stored waste is unlikely to create a radiation hazard to surrounding areas, any significant release in excess of Part 20 limits, or expose facility personnel to doses in excess of those prescribed in Part 20.
The level of detail should reflect the magnitude of potential health and safety impacts associated with characteristics of the specific wastes, waste forms, and other circumstances of the proposed storage operation.
3.
Decav-In-Storace:
3a. Will NRC consider applications by non-medical licensees for decay-in-storage of short-lived, low-activity radioactive materials for unrestricted release?
NRC will accept and consider applications from non-medical materials licensees for authorization to include decay-in-storage as a disposal method. The licensee should address the following areas in its amendment request:
a.
Survey procedures to be used during storage and before disposal in ordinary trash. The procedures should describe the type of instrument to be used for surveys, a statement of the minimum detectable activity, and a commitment that the final survey will be performed in a low radiation background area, with all shielding removed.
b.
Procedures for segregating and tracking waste from placement in storage to final disposal. The procedures would include: (1) how waste will be segregated to ensure that decay-in-storage isotopes are separately identified from interim storage wastes; (2) how waste containers will be labeled; and (3) how records are maintained, such as date placed in storage, date removed, and survey results.
c.
A comitment that waste will be held for a minimum of 10 half-i lives, before performing the final radiation survey described in Paragraph a, above.
d.
The decayed radioactive waste will not be disposed of as ordinary trash unless the final survey results are indistinguishable from background radiation, using the survey procedures discussed in Paragraph a, above, and radiation labels are obliterated or removed.
Before disposal, the licensee should monitor the radioactive material in the container at the container surface, to determine that its radioactivity cannot be distinguished from background radiation levels. The licensee shall retain a record of each disposal concerning decay-in-storage materials for 3 years. The
1 NMSS Newsletter Submittal Page 5 of 9 5.
What licensing conditions must be in place to enable one licensee to i
send LLW to another licensee, for use of the latter licensee's waste compactor, or other waste processing facilities?
If licensees wish to share or make available waste processing services to other licensees, authorization must be explicitly approved and authorized in the license.
License conditions governing this activity will be determined on a case-by-case basis. Licensees interested in obtaining authorization involving these activities should contact the appropriate NRC Regional, or Headquarters, Office, to determine the information needed in a license amendment request of this type, since the type of information will vary depending upon the scope of proposed activities.
6.
At the end of the interim storage period, when waste disposal
=
capacity becomes available, what length of time will generators be granted to empty their facilities of stored LLW?
NRC has not identified a specific length of time for shipment of LLW from interim storage to a LLW disposal facility. This will vary from licensee to licensee, but we expect that wastes would be shipped within a reasonable period of time (i.e., within a few months, up to 1 year).
Several factors will affect the time required to ship LLW to final disposal including:
The emptying of storage facilities and loading of transport vehicles with LLW for shipment to disposal facilities.
Logistics and operations involving coordination of multiple shipments from individual licensee storage facilities to a limited number of disposal sites.
Coordination of legal and financial contracts, agreements, and licenses among the various participants.
Review of waste form and waste packaging requirements and inspection of packaged waste against transportation and disposal criteria.
7.
Why does Commission guidance identify five years as the interim storage period?
The Commission believes that extended on-site storage would be contrary to tt mitiond policy, in the Low-Level Radioactive Waste Policy AmenGLwnts Act of 1985, to accomplish the overall objective of permanent disposal of LLW. As stated in Information Notice 90-09, "In the interest of public health and safety, as well as maintaining exposures ALARA (as low as reasonably achievable), the length of time LLW is placed in storage should be kept to a minimum. Accordingly, NRC's approval of requests by materials licensees for interim extended storage will generally be for a period of time no greater than five years." The 5 year storage period is meant to help ensure that storage does not
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i NMSS Newsletter Submittal l
Page 7 of 9 by the operating license or construction permit, and which may divert l
the attention of licensee management from its primary task of safe operation or construction of the power reactor. Accordingly, interim i
storage of LLW within the exclusion area of a reactor site, as defined in 10 CFR 100.3(a), will be subject to NRC jurisdiction regardless of l
whether or not the reactor is located in an Agreement State, pursuant to j
the regulatory policy expressed in 10 CFR 150.15(a)(1).
As per Generic Letter 85-14, "Comercial Storage at Power Reactor Sites l
of Low-Level Radioactive Waste Not Generated by the Utility," for NRC to consider any proposal for commercial storage at a reactor site, a
including comercial storage in existing LLW storage facilities, NRC must be convinced that no significant environmental impact will result 3
and that the commercial storage activities will be consistent with, and not compromise, safe operation of the licensee's activities. A Part 30 license is required for commercial LLW storage and a Part 50 license j
amendment may also be required. The office of Nuclear Reactor Regulation (NRR) will conduct an environmental review and review the application to determine whether the low-level waste commercial storage
~
activities on a reactor site impact the safe operation of the reactor.
7 Following NRR review, the licensing authority for comercial stcrage on i
a reactor site under NRC jurisdiction (all locations in non-Agreement
[
States and locations within reactor exclusion areas in Agreement States) is the Office of Nuclear Material Safety and Safeguards. NRC will assess environmental impact and will issue an environmental impact l
statement, if appropriate. NRC will provide notice in the Federal Recister of receipt and availability of any application received for l
comercial storage activities. The public notice will also indicate the staff's intent regarding preparation of an environmental assessment and i
its circulation for public review and coment. An environmental impact statement will most likely be needed, based on the environmental l
assessment.
l
- 10. What radioactive waste management options are available to licensees who possess greater-than-Class-C (GTCC) waste, or GTCC. sealed l
sources, and who wish to terminate their licenses?
i i
Waste management options for licensees possessing GTCC waste or sources are limited for the following reasons:
- 1. 10 CFR 61.55 states that GTCC waste is generally not acceptable for near-surface disposal and must be disposed of in a geologic repository, pursuant to Part 60, l
unless another disposal method is approved by NRC. No geologic l
repository is currently available.
- 2. The LLRWPAA designates the l
Federal Government as responsible for disposal of GTCC wastes, and l
Congress has designated the U.S. Department of Energy (DOE) as the j
responsible agency for disposal of GTCC waste. While DOE estimates that an interim storage facility may be available for GTCC wastes by the end j
of 1997, further delays in meeting this schedule may occur.
Until disposal capacity becomes available for GTCC waste, licensees may l
l i
t
NMSS Newsletter Submittal Page 9 of 9 agreement has been developed to facilitate access to treatment / processing facilities for generators and to offer assurances to States in which processing facilities are located that they will not be burdened with the responsibility of disposing of LLW generated from outside their borders. The agreement is a legally binding contract.
A-of July,1993, signatories to the Interregional Access Agreement include the Appalachian, Central, Midwest, Northeast, Northwest, Rocky Mountain, and Southwestern Compacts, and the States of Maine, Massachusetts, Michigan, New York, Texas, and Vermont.
Licensees should contact their State or Compact LLW officials for details on the implementation of the Interregional Access Agreement.
- 13. Must a waste processor or broker amend its license to return treated waste back to a generator?
Most licenses governing waste processor and broker activities normally do not contain restrictions to whom the waste processor can send processed waste. However, some broker / processor licenses may authorize
... receipt, storage, and possession... in packaged waste... incident to transfer to licensed waste disposal facilities," (emphasis added.)
In this example, the broker / processor may want to amend its license to ensure the license includes special authorization to ship waste back to LLW generators.
In general, any materials licensee may transfer licensed material to another licensee under the provisions of 10 CFR Parts 30.41, 40.51, and 70.42.