ML20199G112
| ML20199G112 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/20/1998 |
| From: | Diaz N, Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199F987 | List: |
| References | |
| SECY-97-244-C, NUDOCS 9802040217 | |
| Download: ML20199G112 (2) | |
Text
Sa nse e
UNITED STATES
[
NUCLEAR REGULATORY COMMISSION g
CAsHCOToN, D.C. s0888 l
couuissioNER January 20, 1998 MEMORANDUM TO:
John C. Hoyle Secretary FROM:
Edward McG n Jr. b.b Nils J. Diaz
SUBJECT:
ADDITIONAL VIEWS ON THE PROPOSAL TO DISPOSE OF THE TROJAN REACTOR VESSEL - SECY 97 244 Based on a revkw of several concems raised in Chairman Jackson's vote on SECY 97 244, we feel compelled to augment the voting record to make it clear that we considered such issues in voting on SECY 97 244, and do not consider them to conflict with the staffs proposed approach for resolving issues associated with the proposed method of disposal of the Trojan reactor vessel. Thus, we determined that it would be wholly appropriate to proceed with further action and analyses of the proposal at thlo time, in particular-1)
We do not share the concem about the State's authority in this case. The State of Washington has the authority to make a determination as to the proper waste classification to be applied and to approve the request for disposal of radioactive waste not greater than Class C (GTCC) under the regulations without concurrence by the Commission.'
2)
This action will not set a precedent for other existing or proposed disposal sites. Rather, the State of Washington will make a determination specific to conditions at the proposed site and specific to the Trojan reactor vessel. Conditions at other disposal sites differ markedly from those in Washington and reactor vessels vary in radionuclide content and components. The staff recognizes these particularities and states in the subject paper that it will require future appilcants to submit case specific analyses and will accept waste classification averaging approaches where the disposalimpacts are consistent with the performance objectives in Part 61, indeed, it can be argued that only the Commission's insettlon of itself in this case would lead to this being considered a national precedent.
3)
Each Agreement State under its compatible regulations for land disposal of low level waste will determine whether it will permit a reactor vessel with intamals intact to be
' The NRC's role in this case is to ensure that the applicant property classifies its waste in accordance with 10 CFR 61.55 for the purpose of ensuring that applicable transportation requirements are met. NRC's determination is independent of that performed by the State for the purpose of ensuring that the wastes are suitable for disposal at the Hanford site.
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CORRESPONDENCE PDR
2 disposed of at its site. The very fact that the request has been made by Portland General Electric fer the Trojan vessel will likely make this a contention in the siting process at other locations, irrespective of the ultimate decision by the State of Washington on the meds of this asse.
. 4)
As to the issue of the method of disposal of GTCC waste, the question for the State of Washington is whether this waste should be classified as Class C or GTCC after everaging the radionuclide content of vessel components, if it is not GTCC weste, then '
the concem about the method of disposal of GTCC waste doe 9 not apply. If it is, Washington may not grant the exemption or authartre disposal of the intact reactor vessel since the disposal of GTCC is reserved to the Federal govemment. We are not aware of any information indicating that the State is seeking authorization for disposal of GTCC.
5)
The use of institutional controls is entirely appropriata at the US Ecology commercial site at Hanford. At the DOE low 4evel waste site adjacent to the commercial site, over 30 million Curies have been disposed of, including naval reactor vessels with intomals intact. Institutional controls will need to (.e maintained at the Hanford site for a very long time. Again, the site specific history and characteristics cet this site apart from other sites and proposals, oc:
Chairman Jackson Commissioner Dieus OGC EDO C
7 G
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'g UNITED STATES 8
NUCLEAR REGULATORY COMMISSION
{
WASHINGTON, D.C. 20684-4001 January 22, 1998 CFFict OF THE StCRETARY MEMORANDUM TO:
L Joseph Cal'an Ive De ector for Operations FROM:
C.
oy,
tary
SUBJECT:
STAFF REQUIREMENTS SECY 97 244 WASTE CLASSIFICATION OF THE TROJAN REACTOR VESSEL The Commission has approved the staffs proposed response to the State of Washington requesting additional information and analysis for the Trojan reactor vessel subject to incorporation of the changes indicated in the attr sent.
(EDO)
(SECY Suspense:
1/30/98)
Attachment:
As stated cc:
Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan OGC
)g[k'T CIO CFO gv OCA OlG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mall)
? :8,,
tMO SECY NOTE:
THIS SRM, SECY-97 244, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERC WILI.
BE MADE PUBLICLY AVAILABLE AFTER THE LETTER IS SIGNED AND DISPATCHED.
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Mr. John L. Erickson, DirectL Division of Radiation Protection Department of Health Airdustrial Center Building #5 P.O. Box 47827 Olympia, WA 98504 7827
Dear Mr. Erickson:
On March 31,1997 Portland General Electric Company (PGE) requested the U.S. Nuclear Regulatory Commission to issue a Type B Cortl6cate of Compliance under our transportation regulations to allow a one time shipment of the Trojan Nuclear Plant's reactor vessel with hs intemals for disposal at the U.S. Ecology site in Hanford, Washington, Prior to beginning a full review of this transportation package application, it is our intent to address the waste classification of the waste shipment ud mi = ;' b :f2:M ';; i;::::. Under the 10 i
CFR 20 waste manifesting requirements, a waste generator must classify wastes in accordance with 10 CFR 61.55. It is our goal to ensure that the waste shipment is property classified.
On June 18,1997 PGE submitted responses to several of our questions relating to the classification of the waste shipment (Attachment 1). PGE acimowledges that some of the
- intemals are Greater-Than-Class C (GTCC), but is proposing to ciactify the wastes by averaging the reactor intomals with the pressure vessel. The core baffle plates, the core former plates, and the lower core plate substantially exceed the recommended ratios for classifying activated metals given in Section 3.3 of the Bianch Technical Position (BTP) on Concentration Averaging and Encapsulation dated January 17,1995. However, FGE indicated that the one-piece shipment of the RV with the intomals would allow conted handling of the shipment, would result in 39 to 44 fewer waste cans requiring storage until a GTCC waste disposal site is -
developed, would reduce contamination control problems, would reduce occupational exposures from 134 to 154 person-rom to 67 persN-rom (out of 591 person rom estimated for-the entire Trojan decommissioning), and would reduce waste shipments from 44 to 1.
PGE also provided a pathway analysis performed by U.S. Ecology, which was previously submitted to the State of Washington. This pathway analysis addresses groundwater impads
. and doses from dired exposure. Other intruder pathways such as construction and resident-farmer noenarios are not addressed, nor is there a justifmation for assuming that the package will remain inted over the hazard lifetime of the nuclides that are critical to the waste classification: C-14, Ni-59, Ni 63, and Nb-94.
The NRC staff will consider attemative approaches to waste nuclide averaging if k can be shown that the wastes will meet the performance objectives in 10 CFR Part 61 (see 10 CFR o
81.58 and Sedion 3.9 of the :7.2. Tdf n' F:2:;; BTP on Concentration Averaging and Encapsulation). The evaluation should include a comprehensive _and defensible pathway analysis that includes all relevant pathways. The draft : nc. Tcf x: F:2:;; BTP on a Performance Assessment Methodology for Low-Level Radioactive Weste Disposal Facilities could be used as guidance for this analysis. Ehe draft BTP has been made available for public 5
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comment and review and does not reposent a nnal agency poskion.
We request that your staff ask U.S. Ecology, in coordination with PGE, to perform a comprehensive and defensible pathways analysis to demonstrate the suitability of the proposed wastes for disposal at the Hanford disposal she. Specifically, the analysis should be based on intruder construdion and intruder resident-farmer scenarios carried out for ; 1^,^^^ p; pdd the smetrame pmposed in thesTP.
If the weste package is assumed to be intact for a period greater than 500 years, justification needs to be provided. The draft */ leoneh4eekniesH%eWen BTP on a Performance Assessment Methodology for Low-Level Radiondive Waste Disposal Facilities * (zumuld be used as guidance.- Sections 3.2.2,3.2.3,3.3A, and 3.3.5 of this Breneh4eehnieeH%eWon BTP provide guidance on the time frames for the performance assessment, use of engineered barriers, and evaluation of waste forms for the performance assessment.
After your review of this information, if you conclude that the reactor vessel with intemals is suitable for dicposal under the State of Washington's regulations, we will consider allowing the shipment to be classified under the attomative averaging provisions of the Beeneh4eeknieel Poeiken BTP on Concentration Averaging and Encapsulation. We are also willing to provide any technical assistance you may desire for the review of the submitted pathway analyses.
Sincerely, Richard L Bangart, Director Office of State Programn 9
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