ML20136D679
| ML20136D679 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Salem, Sequoyah, North Anna  |
| Issue date: | 06/09/1980 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Lainas G, Novak T, Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| GL-80-51, NUDOCS 8009040052 | |
| Download: ML20136D679 (11) | |
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JUN 9 1980 MEMORANDUM FOR: T. Novak, Assistant Director for Operating Reactors, DL R. Tedesco, Assistant Director for Licensing, DL G. Lainas, Assistant Director for Safety Assessment, DL
, FROM: D. G. Eisenhut. Director. Division of Licensing l
SUBJECT:
LETTER TO LICENSEES CONCERNING ON-SITE STORAGE OF l
LOW-LEVEL WASTE n l
The attached letter, which has concurrence from the appropriate organizational entities in the new NRR organization, should be sent to all power reattors by each Operating Reactors Branch and the Licensing Branches for Sequoya.h.
Salem 2. and North Anna 2 within the next five working days. ,
Orts]e *fg', s e entr D. G. Eisenhut. Director Division of Licensing
Enclosure:
As stated cc w/ enclosure:
B. Snyder H. Denton V. Stello } ,
E. Case ,
R. Minogue D. Ross (d'y3 , ?
T. Murphy B. Grines j \
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- %c, . ',gghf'fR -'*-? ', . - lJUN 9 1930 MEMORANDUM FOR: T. Novak, Assistant Director for Operating Reactors, DL R. Tedesco, Assistant Director for Licensing DL G. Lainas, Assistant Director for Safety Assessment, D!.
FROM: D. G. Eisenhut, Director, Division of Licensing
SUBJECT:
LETTER TO LICENSEES CONCERNING ON-SITE STORAGE OF LOW-LEVEL WASTE The attached letter, which has concurrence from the appropriate organizational entities in the new NRR organization, shnold be sent to all power reactors by each Operating Reactors Branch and the Licensing Branches for Sequoyah, Salem 2, and North Anna 2 within the ext five working days, o
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Division of Licensing
Enclosure:
as stated cc w/ enclosure:
B. Snyder H. Denton V. Stello E. Case R. Minogue D. Ross T. Murphy
- 3. Grimes V. Mala feew R. Bangart 00L SCs R. Weller S. Bland G. Bidinger J. Martin P. hmas R. Browning P. Wagner D. Smith B. Singer R. Ryin kntact: P. Grant, X23C66
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i UNITED STATES NUCLE AR REGULATORY COMMISSION l'
",, g " ,I j WASHINGTON. D. C. 20555 Q 1~ , j s., ..- p LETTER T0: ALL F0WER REACTOR LICENSEES
SUBJECT:
TEMPORARY ON SITE STORAGE OF LOW LEVEL RADI0 ACTIVE WASTE l Recent restrictions and reduced allocations at comercial burial sites j have caused nunerous Licensees to actively consider increased on-site storage. Several Licensees are currently storing waste on a temporary j basis and proposing to establish new facilities for longer term storage.
3 If :n-site storage is necessary, the Licensee must assure that the design 9
and coeration of the proposed facilities are adequate to maintain public 4 hedI!h and safety, minimal risk to operating personnel, and present 'a
- mini.r.al environmental impact, ,
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-ny decision to incorporate on-site storage requires a 10 CFR 50.59 safety review of the areas of (1) Radioactive Material and Effluent Control, i (2) Radiation Dose Control for both on-site and off-site individuals, and j (3) Accident Prevention and Control. Enclosed is a draft NRC Licensing j Position for " Safety Considerations for Temporary On-Site Storage." This draf t is forwarded for your information and use in evaluating low-level waste (LLW) storage criteria. ,
l l The NRC is presently evaluating both temporary and long term on-site
! storage and its implications. Currently, 10 CFR 50.59 requires that i you furnish a report containing a brief description and summary of the ;
! safety evaluation for each 10 CFR 50.59 change to your facility. The
) proposed model Appendix ! generic technical specifications (NUREG 0472 4
and 0473) contained guidance on the desired detail necessary in that i report for radwaste systems. In the interim, until Appendix 1 technical j specifications are incorporated in your operating license, you are requested i
to ir.clude reviews for on-site storage additions in the monthly operating report following the period in which the evaluation was completed. This
- report should detail the major additions / changes and contain a summary i of tr.e safety evaluation. This summary should include as a minimum your i evaluation of each of the safety review areas described herein, including 2 consideration of the guidance crovided in the enclosed draf t Licensing ;
j Position, man-rem impacts, anticipated radiological release assessments, j final disposition of waste, and final conclusion of the 50.59 evaluation.
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.. . =<M No formal response is required concerning this letter unless waste storage facilities are modified. Coments, however, are invited concerning the enclosed draft Licensing position.
Branch Chief Operating Reactors Branch !
Division of Licensing
Enclosure:
As stated
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i SAFETY CONSIDERATIONS FOR TEMPORARY Off-SITE STORAGE OF LOW LEVEL RADIOACTIVE WASTE
- 1. Introduction The objective of this technical position is to provide guidance to the Licensees considering additional on-site low level radioactive waste stor-age capabilities. The duration of the intended storage, the type and form of waste, and the magnitude of radionuclides present will dictate the safe-guards and the level of complexity required to assure public health and safety, and minimal risk to operating personnel . The longer the intended storage period, the greater the degree of controls that will be required for radiation protection and accident prevention. For purposes of this document, the duration of temporary material storage is to be up to four (4) years. The magnitude of the on-site storage safety hazard is predi-cated on the type of waste being stored, the amount of radionuclides pres-ent, and how readily they might be transportcd into the environment. In general, it is preferable to store radioactive material in solid form.
Under some circumstances, however, temporary storage in a liquid form may be desirable or required. The specific design and operation of any storage facility will be significantly influenced by the various waste forms, consequently, this document addresses wet waste, solidified wet waste and dry low level radioactive waste.
II. General Information Prior to any implementation of additional on-site storage, 'substantial safety reviews and environmental analysis need to be conducted to assure '
l adequate public health and safety, and minimal environmental impact. The acceptance criteria and perfornance objectives of any proposed storage facility, or area, will need to meet minimal requirements in areas of l design considerations, operational considerations, safety considerations and policy considerations. For purposes of this branch position the major emphasis will be on safety considerations in the storing, handling and eventual disposition of the radioactive waste. Design and operational acceptability will be based on minimal requirements which are defined in existing SRP's, Regulatory Guides, and industry standards for proper management of radioactive waste. Policy considerations for waste min-imization and volume reduction will also have to oe integrated into the waste manegement plan and the on-site storage alternative. Additional considerations for ALARA, decontamination, and decommissioning of the temporary storage facility also need to be integrated into the design and operation of the proposed wiste storage facility. Integration of waste
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volume reduction and eventual disposal should be performed as early as possible because future requirements for waste forms may make stored wastes unacceptable for final disposition.
!!!. Wet Radioactive Waste Storage (a) Wet radioactive waste will be defined as any liquid or liquid / solid slurry. For storage considerations, wet waste is further defined as
! any waste which does not meet January 1,1981 burial requirements for solidified
< l.0 gallon waste (i.e., < 0.5%
per container free water whichever is by) lessvolume
. of container or l (b) The facility, supporting structure and tanks should be designed to
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] prevent uncontrolled releases of radioactive materials due to spil-lage or accident conditions.
) (c) The following design objectives and criteria are applicable for wet radioactive waste facilities.
] (1) Structures that house liquid radwaste storage tanks
- should be designed to seismic criteria as defined in Standard Review Plan (NUREG 75/087 - Section 11.2).
1 Foundations and walls shall also be designed and fabricated to contain the liquid inventory which mignt be released during a container / tank failure.
, (2) All tanks or containers should be designed to withstand the corrosive nature of the wet waste stored. The I duration of storage under which the corrosive condi-1 tions exist shall also be considered in the design.
I (3) All storage structures should have curbs or elevated thresholds with floor drains and sumps to safely ecl- .
lect wet waste assuming the failure of all tanks or con- l tainers. Provisions should be incorporated to route I spilled wet waste to the radwaste treatment systems.
(4) All tanks and containers shall have provisions to monitor liquid levels and to alarm potential overflow conditions. ;
(5) The quantity of radioactive material allowed and the .
shielding configurations will be dictated by the dose ,
' l rate criteria for both the site boundary and unrestrict-ed areas on-site. The 40 CFR 190 limits will restrict ;
the annual d0se from direct radiation and effluent re- l lease to the Public (individual) to less than 25 mrem per year to the whole body from all sources of the Ura-nium fuel cycle; therefore, off-site doses from on-site
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storage must be sufficiently low to account for other 1 sources (e.g. , < 1 mrem / year). On-site dose limits as-sociated with temporary storage will be controlled per :(j; 10 CFR Part 20 including the ALARA principle of 10 CFR h 20.1.
(6) All potential release pathways of radionuclides (e.g.,
evolved gases, breach of container, etc.) shall be con-trolled and monitored as per 10 CFR 50 Appendix A ,
(General Design Criteria 60 and 64). Surveillance pro-grams should incorporate adequate methods for monitor-ing breach of container integrity or accidental releases.
(7) All temporarily stored wet waste will require additional I reprocessing prior to shipment off-site; therefore, pr ;- i vision should be established to integrate the required treatment with the waste processing and solidification 9 systems. The interface and associated systems should h be designed and tested in accordance with the codes and Qi standards described in NUREG-75/087 Section 11. {l
- j IV. Solidified Radioactive Waste Storage 1
(a) Solidified radwaste for storage purposes shall be defined as that i waste which meets January 1,1981 burial site solidified waste o criteria. Therefore, solidified radwaste will be identified as wet waste (e.g., evaporation bottoms, resins, and sludge) which is ,
solidified and contains < 0.St free water (by container volume) or j 1.0 gallon of liquid (in the container), whichever is less. For '
purposes of this document resins or filter sludges dewatered to the '
above criteria will be defined under this waste classification /
criteria. .(
r (b) Dewatered resins and filter media with radioactivity levels above L i uCi/cc (>5 yr, half-life) which are disposed of af ter July 1,1981, will be required to be solidified or stored in high integrity containers (e.g., reinforced concrete).
Any storage plans should address container protection as 3 well as any reorocessing requirements for eventual ship- !
ment and burial.
(c) Casks, tanks, and liners containing solidified radioactive waste should be designed with good engineering judgment to preclude or reduce the occurrence of uncontrolled releases of radioactive caterials due to handling, transporting or storage. Accident miti-gation and control for design basis events (e.g., fire, flooding, tornadoes, etc.) must be evaluated and protected against unless l otherwise justified.
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DRAd (c) Tr.e following design objectives and criteria are applicable for solidified waste storage conteiners and facilities:
(1) All solidified radwaste should be located in restrict-ed areas where effective material control account-ability can be maintained. While structures are not required to meet seismic criteria, protection should be afforded to insure the radioactivity is contained safely by use of good engineering judgment, such as the use of curbs and drains to contain spil*is of dewatered resins or sludges.
(2) Container material selection should conform to require-ments established in NUREG-75/087 (Section 11). If liquids nist which are corrosive, proven provisions should A made to protect the container (i.e., special liners or coatings) and, or neutralize the excess lig- r uids. If deemed appropriate and necessary, highly non-corrosive materials (e.g., stainless steel) should be -
used. Potential corrosion between the solid waste forms and the container should also be considered. In the case of dewatered resins, highly corrosive acids and bases can be generated which will significantly reduce the longevity of the container. The Process Control Program (PCP), should implement steps to assure the above does not occur, and provisions on container materi-al selection and precoating should be made to insure that container breach does not occur during temporary storage periods.
(3) Potential release pathways of all radionuclides present in the solidified waste form shall be monitored as per 10 CFR 50 Appendix A. Surveillance programs shall in-corporate adequate methods for detecting failure or con-tainer integrity and measuring releases to the environ-ment. For outside storage, periodic direct radiation and surface contamination monitoring shall be conducted to in-sure that levels are below limits specified in 10 CFR 20.202, 20.205, and 49 CFR 173.397. All containers should be decontaminated to these levels or below before storage.
(a) Provision should be made for additional reprocessing or repackaging due to container failure and/or, as required for final transporting and burial as per 00T and burial site criteria. Contamination isolation and decontamina-tion capabilities should be developed. Whereby signifi-cant handling and personnel exposure can be anticipated, A1. ARA methodology should be incorporated as per Regulatory Guides S.8 and 8.10.
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(5) Procedures should be developed and implemented for early detection, prevention and mitigation of acci- <
dents' (e.g. ... fires) . Storage areas and facility de-signs should incorporate good engineering features and contingencies so as to handle accidents and provide safe- J guard systems such as fire detectors and suppression systems. (e.g., smoke detector and sprinklers), person-
. nel training and administrative procedures to insure . '
both control of radioactive materials and minimum ;Hl personnel exposures. Fire suppression devices may not be necessary if combustible materials are minimal in the area.
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II (5) Provisions should be incorporated for collecing liquid drainage including provisions for sampling all col-j e, lected liquids. Routing of the collected liquids should be to radwaste systems if contamination is detected or ,
to normal discharge pathways if the water innress was I
from external sources and remained uncontaminated. '
l (7) Low level solidified waste stored in outside areas i i should be held securely by installed hold down systems. j i The hold down system should secure all containers dur- di ing severe environmental conditions up to and includ- y ing the design basis event for this waste storage facility. $gj
- 19) Container integrity should be assured against cor-rosion from the external environment; external weather protection should be included where necessary and prac- :
tical. Storage containers should be raised off storage /i pads where water accumulation can be expected to cause external cor osion and possible degradation of container i integrity. j 2
d (9) The quantity of radioactive material allowed and the shielding configurations will be dictated by the dose-rate criteria for both the site boundary and unrestrict- ~
ed area on-site. The 40 CFR 190 limits will restrict the annual dose from direct radiation and effluent re-leases to the Pubite (individual) to less than 25 mrem per year to the whole body from all sources of the Ura-niun fuel cycle; therefore, off-site doses from on- ;
site storage must be sufficiently low to account for other sourt.es (e.g. , < 1 mrem /yesr). On-site dose limits as-sociated to temporary stort.ge will be controlled per 10 CFR Part 20 including the ALARA principle of 10 CFR 20.1.
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- (10) Total curie limits should be established based on the l design of the storage area and the safety features l provided.
(11) Inventory records of waste types, contents, dates of j storage, shipment, etc., should be maintained.
i l l V. Low Level Dry Waste Storace_ .
l (a) Low level dry waste is classified as contaminated material (e.g., l paper, trash, air filters) which contains sources of radioactive l material that is dispersed in small concentrations throughout ,
large volumes of indrt material which contain no free water. I Generally, this consists of dry material such as rags, clothing, j contaminated materials and small equipment (i.e., tools and in-struments) which cannot be easily decontaminated.
(b) Licensees should implement controls to segregate and minimize the 1 generation of Low Level Dry Waste to lessen the impact on waste ,
storage. Integration of Volume Reduction (VR! hardware should be i considered to minimize the need for additional waste storage fa- I cilities.
(c) The following design objectives and criteria are applicable for low '
level dry waste storage containers and facilities. l (1) All dry or compacted radwaste should be located in re- i stricted areas where effective material control and accountability can be maintained. While structures are ; i not required to meet seismic criteria, protection should
- l' be afforded to insure the radioactivity is contained safe- ,
ly by use of good engineering judgment. i 1
(2) The waste container should be designed to insure radio- l active material containment during normal and abnormal occurrences. The waste container materials should not support combustion. The packaged material should not cause fires through, spontaneous chemical reactions, re-tained heat, etc.
(3) Potential release pathways of all radionuclides present in the solidified waste form shall be monitored as per 10 CFR 50 Appendix A. Surveillance programs shall in-corporate adequate methods for detecting failure of con-tainer integrity and measuring releases to the environ-ment. For outside storage periodic direct radiation and l
surface contamination monitoring shall be conducted to in-sure that levels are below limits specific in 10 CFR l 20.202, 20.205, and 49 CFR 173.397. All containers should l
l be decontaminated to these levels or below before storage. .
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(4) Containers should generally comply with the criteria l
of 10 CFR 71 and 49 CFR 170 to minimize the need for !
repackaging for shipment. ,
(5) Increased container handling and personnel exposure f can be anticipated, consequently, all ALARA meth-odology should be incorporated per Regulatory Guide 8.8 i and 8.10. !
'. 6 ) The quantity of radioactive material allowed and the shielding configurations will be dictated by the dose-rate criteria for both the site boundary and unre- l stricted areas on-site. The 40.CFR 190 limits will re- l strict the annual dose from direct radiation and ef- )
fluent release to the Public (individual) to less than j 25 mrem per year to the whole body from all sources of 1 the Uranium fuel cycle; therefore, off-site doses from on-site storage most be sufficiently low to account for other sourcec t e.g. , < 1 mrem / year) . On-site dose limits associats' .o temporary storage will be control- f led per 10 CFR Part 20 including the ALARA principle !
of 10 CFR 20.1. l (7) Total curie limits should be established based on the design of the storage area and the safety features provided.
(3) Provisions should be incorporated for collecting lig- , !
uid drainage including provisions for sampling all cv -
lected liquids. Routing of the collected liquids should be to radwaste systems if contamination is detected or to normal discharge pathways if the water ingress was from external sources (e.g., rain water or moisture) and !
remained uncontaminated. j (3) Low-level waste stored in outside areas should be held securely by installed hold down systems. The hold down l system should secure all containers during severe en-vironmental conditions up to and including the design basis event for this waste storage facility.
(10) Container corrcsion should be assured against from both the internal and external environment. Special internal !
liners and external weather pro ection should be in- <
ciuded where necessary and practical. Storage conta'ners should be raised off storage pads where water accumula- i tion can cause external corrosion and resultant loss of container integrity.
(11) Inventory records of waste types, contents, dates of storage, shipment, etc., should be maintained.
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