ML20199G156

Staff Requirements Memo Re SECY-97-244, Waste Classification of Plant Reactor Vessel

ML20199G156
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/22/1998
From:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
To:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
REF-10CFR9.7 SECY-97-244-C, NUDOCS 9802040229
Download: ML20199G156 (3)

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                                                                                                                                  *******a n,,,,                                       January 22, 1998 OFFICE OF THE SECRETARY MEMORANDUM TO:                 L. Joseph Callan Ex utive Director for Operations FROM:                                C.      ,       tary

SUBJECT:

STAFF REQUIREMENTS - SECY-97-244 - WASTE CLASSIFICATION OF THE TROJAN REACTOR VESSEL The Commission has approved the staff's 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 attachment. (EDO) (SECY Suspense: 1/30/98)

Attachment:

As stated - cc: Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan OGC CIO ' CFO 1 D OCA p# ~, ' OlG Office Dirc: tors, Regions, ACRS, ACNW, ASLBP (via E-Mail) PDR 9 0,1 d e 3(EXh SECY NOTE: THIS SP,M, SECY-97-244, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE AFTER THE LETTER IS SIGNED AND DISPATCHED. 9802040229 980122 PDR 10CFR 1

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       . Mr. John Lf Erickson, Director 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. Nuear Regulatory Commission to issue a Type B Certificate of Compliance under our transportation regulations to allow a one-time shipment of the Trojan Nuclear Plant's reactor vessel with its 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 ad r .:': w : Of h att:: j f;r d:;-;-x:L Underthe 10 CFR 20 waste manifesting requirements, a waste generator must classify wastes in accordance          p with 10 CFR 61.55, it is our goal to ensure that the waste shipment is properly classified.        ?

On June 18,1997, PGE submitted responses to several of our questions relating to the classification of the waste shipment (Attachment 1). PGE ackncdedges that some of the intemals are Greater-Than-Class C (GTCC), but is proposing to classify the wastes by , l averaging the reactor intemals with the pressure vessel. The core baffle plates, the core former I. . plates, and the lower core plate substantially exceed the recommended ratios for classifying activated metals given in Section 3.3 of the Branch Technical Position (BTP) on Concentration Averaging and Encapsulation dated January 17,1995. However, PGE indicated that the one-piece shipment of the RV with the intemals would allow contact handling of the shipment, would - result in 30 to 44 fewer waste cans requiring storage until a GTCC waste disposal site is developed, would reduce ,ontamination control problems, would reduce occupational exposures from 134 to 154 person-rem to 67 person-rem (out of 591 person-rem 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 impacts              ,

and doses from direct exposure. Other intruder pathways such as construction and resident-farmer scenados are not addressed, nor is there a justification for assuming that the package will remain iritect 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 nucide averaging if it can be

         'shown that the wastes will meet the performance objectives in.10 CFR Part 61 (see 10 CFR 61.58 and Section 3.9 of the Ornch T;;hnl;;l Psh:m BTP_ on Concentration Averaging and Encapsulation). The evaluation should include a comprehensive and defensible pathway analysis that includes all relevant pathways. The draft St=ch Tshn =l Pan:a BTP on a Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities could be used as guidance for this analysis. The draft BTP has been made available for public

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3- comment and review and does not represent a final agency position. We request that your staff ask U.S. Ecology, in coordination with PGE, to perform a comprehensive and defensible pathways analytis to demonstrate the suitability of the proposed wastes for disposal at the Hanford disposal site. Specifically, the analysis should be based on

   - intruder-construction and intruder resident-farmer scenarios carried out foi ; 10,000 y;;r perled the timeframe proposed in the BTP.

If the waste package is assumed to be intact for a period greater than 500 years, justification needs to be provided. The draft *0r:n;S T;;hn;;;l re;n en BTP on a Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities

• ehcould be used as guidance. Sw.:tions 3.2.2,3.2.3,3.34. and 3.3.5 of this Or;n:h T;;hnl;;; I;;M:;n BTP provide guidance on the time frames for the performance assessment, use of engineered barriers, and evalJation of Wdste forms for the p6Tformance assessment.

After your revi3w of this information, if you conclude that the reactor vessel with intemals is suitable for disposal under the State of Washington's regulations, we will consider allowing the shipment to be classified under the attemative averaging provisions of the Or;nch T;;hn;;;; Peedoen 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, l Richard L. Bangart, Director Office of State Programs 1

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