ML20151Q496

Forwards Comment on HR 8119,proposed Response to Congressman Ashley & Classification of Waste for Near Surface Disposal

ML20151Q496
Person / Time
Issue date:	12/05/1980
From:	Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Ahearne NRC COMMISSION (OCM)
References
TASK-TF, TASK-URFO NUDOCS 9808250154
Download: ML20151Q496 (7)

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WMPI r M jec/f t File: Bills HR8119 DEC 5W WM r/f WJDircks

- NMSS r/f ABentley JJSunneler NGill' MEMORANDUM'FOR:

Chairman Ahearne RDSmith' SECY J0 Bunting OPE THRU-William J. Dircks (Signed) William J.Dir$

s REBrowning ED0 r/f Executive Director for Operations JBMartin OGC JGDavis FR0H:

- John G; Duis, Director -

< 0ffice' cf Nuclear Material" Safety and Safeguards

SUBJECT:

COMMENTS ON*H.R.18119-

' - We have reviewed the options for commenting on the bill'.in the not'efdated October 29,1980,4 from the Office of the Secretary to Tom Rehm. Accordingly, we have decided that the only option consistent with.our position is to.

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. delete the second, paragraph of the progosed draft letter from you to -

Congressman Ashley. "High-level waste is defined in Section.3(j) of

.the Marine Protection, Research, and Sanctuaries' Act (MPRSA) of 1972 to be

reprocessed waste. Since H.R. 8119.is an amendment to MPRSA' there is no need,1therefore, to provide clarifying language,as to the meaning of "high-level-waste.". The. amended draft with the language deleted is

' appended to this memorandum as Enclosure 1..

' discusses the approach we are taking -to;" classify" radioactive waste.for near surface earth disposal. We have undertaken no studies for concentration. limits for= ocean disposal since the Environmental Protection

Agency has statutory responsibility for ~ ocean. disposal under MPRSA.

(Signed) John G. Davis.

Dri JohiG. Davis, Director' T,f.

Office of Nuclear Material Safety and Safeguards

Enclosures:

1.

Proposed Response to Congressman Ashley 2.

Classification of Waste for:Near. Surface Disposal cc w/encls:-

Commissioner Gilinsky Commissioner Hendrie-

, Commissioner Bradford 9808250154 801205 PDR COMMS NRCC CORRESPONDENCE PDR

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PROPOSED RESPONSE The Honorable Thomas L. Ashley l

Acting Chairman Committee on Merchant Marine &

Fisheries United States House of Representatives Washington, DC 20515

Dear Mr. Chairman:

This is in response to the Committee's request for the Nuclear Regulatory Commission's (NRC) views of H.R. 8119, a bill to require the Secretary of Commerce to undertake a study to determine the effects of certain past (3,

ocean dumping of radioactive wastes.

Section 203(f)(2) would direct the Secretary to review all reenrds of the ocean disposal of radioactive waste.

The NRC will be glad to assist the Secretary's review of old records rdlated to ocean disposal licensed by our predecessor agency, the Atomic Energy Commission (AEC). Those records are not complete, however, because the Department of Energy (00E) possesses the records of ocean disposal by unlicensed AEC contractors. Accordingly, the NRC recommends that Section 20i'f)(2) be amended to include 00E.

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Thank you for this opportunity to provide the Commission's views on this matter.

Sincerely, John F. Ahearne Chainaan

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' Classification of Waste for Near Surface Disposal Through the.new regulation,10 CFR Part 61, the staff will set out overall ' performance objectives and establish minimum technical requirements for the near surface disposal of waste.

Near surface disposal encompasses the. range in disposal technology that can be applied near-surface including such means as shallow-burial, engineered structures and deeper burial.

Deep mines an'd deep intermediate burial would be excluded.

Collectively, the Part 61 requirements will provide 'a " classification" of waste.

O They will define those wastes which are acceptable for near surface disposal, they will establish the minimum technical requirements for.

disposal of the waste and they will define wastes which are not acceptable for near surface disposal. The staff is not developing an omnibus waste classification system. Waste determined not to be acceptable for near surface disposal will be addressed in other rulemaking actions.

The attached chart.shows how the requirements being developed and approach followed lead to a classification of waste.

Based on two principal long-term performance objectives (protection of a potential inadvertent intruder and protection of the ground water) waste will either be acceptable or not acceptable for near surface disposal.

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Waste acceptable for near surface disposal would fall into 3 broad categories:

a) Wastes which would be required to be placed in a solid form which j

has structural stability and does not easily degrade; j

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b) Wastes which would have few or no requirements on waste stability; and c) Wastes which require special consideration due to high concentrations of particular radionculides or other (e.g. non-radiological) considerations.

At tne disposal site, " structurally stable" waste would be segregated from waste having no waste form stability requirements to eliminate the trench subsidence difficulties experienced at the exirting ',ites.

Structurally stable waste would include the higher activity waste streams and would require stability and segregated disposal to minimize the potential O

for migration end to eliminate the need for ect4ve s4te maintenence over the icog-term.

Unless the waste and disposal site are stable over time, there is no way to predict the long-term radiological impacts of disposa1, or the extent of maintenance activities and associated costs required to maintain potential impacts to low levels. 'laste having no special waste form requirements would include the lower activity waste streams, (e.g. trash)'

which would present little or no concern from the standpoint of long-term migration and would be likely candidates for de minimus.

Any de minimus O

candidate waste streams would be evalu ted and.such a determination made on a case-by-case basis as has been done for liquid scintillation and animal carcass waste containing low concentrations of tritium and carbon-14.

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Some of the higher activity structurally stable wastes may also require additional special consideration.

These considerations would involve placi.ng additional controls on potential intrusion (e.g. requiring that the waste be disposed of with an additional natural or engineering barrier toanintruder) and placing additional controls on wastes having special radiological and non-radiological properties to minimize potential migration.

Additional detail is set out in the following paragraphs.

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With respect to intrusion, there are two principal means of controlling potential exposures to an intruder--use of institutional controls and use of natural or engineered barriers which would make it more difficult for a potent al intruder to contact the waste.

Although we have not' completed our final analyses we expect to allow reliance on active institutional controls (physically controlling access to the site) to prevent intrusion for about 100 years.

This will mean that certain wastes (e.g., those with short half-lives) will not present an undue risk to an intr":er wnen active institutional controls are removed (no intruder barriers required).

The active controls will be followed by several

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hundred additional years of passive controls.

(e.g. government land ownership and records).

Passive controls, although certainly minimizing potential for inadvertent intrusion may not be completely effective in preventing it.

For wastes which would continue to present an undue risk to an intruder when active controls are removed would require additional measures to reduce this risk.

This can be done by introducing an additional barrier to intrusion, (intruder

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barrier), such as deeper burial or engineered ~ barriers.

These additional measures will iio~t be relied on for more than 500 pars; thus wastes which

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could potentially result in an exposure to an intruder greater than the 500 mrem /yr. intruder performance objective after 500 years is not acceptable for near surface disposal.

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Finally certain nuclides, concentrations of nuclides or waste forms may l

i also require individual consideration from the standpoint of migration.

This might include, for example, a large one-time-shipment of a very mobile radionuclide (special consideration-radiological) or a large quantity l

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... + z of: chelating agent in a single shipment.

(Special Consideration Non-Radio-logical)- Some wastes may not be' acceptable fcr near surface disposal due to consideration of migration potential.

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WASTE DE MINIMUS ACCEPTABLE NOT ACCEPTABLE O

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1 SPECIAL WASTE FORM SPECIAL CONSIDERATION -

NO SPECIAL WASTE CONSIDERATIONS: PUT NON-RADIOLOGICAL FORM CONSIDERATIONS INTO STABLE FORM Ol l

l INTRUDER BARRIER NO INTRUDER SPECIAL CONSIDERATION BARRIER RADIOLOGICAL 6

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