ML20202D560
| ML20202D560 | |
| Person / Time | |
|---|---|
| Issue date: | 11/26/1997 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Weiss S NRC (Affiliation Not Assigned) |
| References | |
| REF-WM-3, RTR-NUREG-GENERA TAC-M99896, NUDOCS 9712050062 | |
| Download: ML20202D560 (6) | |
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4 UNITED STATES
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j NUCLEAR REGULATORY COMMISSION C
WASHINGTON, D.C. 20WM001 5.'
,o November 26, 1997 MEMORANDUM TO: Seymour 4. Weiss, Director Non Power Reactors and Decommissioning Proj9ct Directorate Division of Reactor Program Management Office of Nuclear Reactor Ma agement sion[ing FROM:
John W. N. Hickey, Chief Low Level Waste and De Projects Branch Division of W6ste Management Office of Nucioar Meterial Safetv and Safeguards
SUBJECT:
REVIEW OF NUREG REPORT ON OUESTIONS ON DECOMMISSIONING OF POWER REACTORS (TAL NO. M99896)
Pursuant to your memorandum of November 14,1997, the Low-Level Waste and Decommissioning Projects Branch (LLDP) staff hos reviewed pages 35-37 and pages 40 41 of the draft NUREG report on," Frequently Asked Oi.estions on Decommissioning of Power Reactors," and provided our comments.
1.
On page 35, we recommend the addition of a brief description of NRC's low-level waste (LLW) classification system in response to the question,"What is meant by low-level radioactive waste? And how is it different from fuel?"
NRC regulations classify LLW based on potential hazards, such as the concentrations of short-lived and long-lived radionuclides, in accordance to 10 CFR 61.55. Thus, LLW usually, but not necessarily, includes waste with relatively low concentrations of radbnuclides. Although the classification of waste can be complex, Class A waste generally contains lower concentrations of long half-lived radioactive material than Class B and C wastes, (Referer.ce http://www/ntc/ gov /NRC/NUREGS/BR0216/part05.html)
For your information, according to the Nuclear Waste Policy Act of 1982 and the Low-Level Radioactive Waste Pol;cy Amendments Act of 1985, the definition of LLW is any radioactive waste that is not classified as high-level waste, spent nuclear fuel, transuranic waste, or uranium or thorium mill tailings.
2.
On page 35, we recommend several modifications of the response to the question,"How is the low-level radioactive waste disposed of?"
Replace the word " buried" with " disposed of" in the fi/st sentence, the sixth sentence, and the last sentence. Replace the. word " amount" (page 36) with " volume" in the lest sentence.
O/h CON'ACT: Sherry Wu, NMSS/DWM (301) 415-6619 b
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Seymour H. Weiss Deleto the second sentonce, " Waste containers are placed in long trenches that are at least 25 feet doop," because it is not necessarily correct. For your information, there are designs for LLW disposal that are below ground vaults, canh mounded concrete bunkors, and abovo-ground vaults with no carmen covers.
3.
On pago 36, we rocommend the c!arification of tho first paragraph and the inclusion of additional safety features of LLW disposalin rosponse to the question, *ls low-levo' waste disposal safe?"
Replace the first sentence with, *LLW facilities are siteo in areas that are away from surface water and whore the groundwater is located sufficiently beneath the trenches to minimizo nuclido migmfion" Modify the second sentonce 4 note that sites and the surrounding areas are monitored using a system of wolls at least for the short term, but
.9 may not necessarily for the long term or attor unrestricted release of the site.
A combination of natural sito characteristics and engineered safety features are used to assure the safe disposal of LLW. (Reference NUREG 1573 Section 1.2) In addition, iostrictions of types and amounts of wato disposed at a site at well as the analysis berformed as part of the licensing to demonstrato compliance with performance obloctivos in NRC regulations increase the safety of LLW disposal.
The natural characteristics of an LLW disposal sito aro relied on in the long term, and they should promoto disposal site stability and attenuato the transport of radionucUdes away from the disposal sito into the general environment. Sites generally must possess the following characteristics: (1) relatively simplo geology; (2) well drained soils f ree from frequent ponding or flooding; (3) lack of susceptibility to surface geological processes such as mass wasting, erosion, slumping, and landslidos; (4) a water table of sufficient depth so that ground water will not periodically intrude into the waste or c,ischarge onsite; (S) lack of susceptibility to tectonic processes; (6) no known potentially exploitable natural resources, (7) limited future population growth or development; and (8) capability of not being adversely impacted by nearby facilities nor activities Engineered barriors are man-mado structures designed to improve the site's natural ability to isolate and contain wasto, Yhey consist of var'ous engineered system 9emponents, including: (1) a layered carthon cover; (2) a disposal vault; I a drainage system; (4) waste forms and containers; (5) back fill material; and (6) an interior moisture barrior and low-permeability membrane.
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4 On page 36, we recommend several modifications on tM response to the question, "Where can low level radioactivo waste be disposed of?"
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Delete the last sentence of the first paragraph,"A fourth site in Beatty, Nevada was closed cn January 1,1993." Four sites are closed and no longer accepting wastes.
They are located in or near Sheffield, Illinois; Morehead, Kentucky; Beatty, Nevada; and West Valley, New York.
Note that there are several sites curren'ly in development for 5.LW disposal. Also note that the three currently operating commercial burial grounds are located in Agreement States and are regulated by the states.
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j Seymour H. Weiss For your information, the site in South Carolina accepts LLW from all states, except North Carolina.
5.
On pago 37, we recommend the replacement of the word "would" with "could"in the last sentonce of the msponse to the question,"What would happen if the waste site that was boing used is closod?"
6.
On pago 37, we recommend the deletion of the 'No" and the addition of a brief description of NRC's onsite burial policy for the response to the question, "Can radioactive waste be buried on site?"
LLW may be buried onsite, depending on site-specific circumstances.10 CFR 20.2002 describes the method for obtaining approval of proposed disposal procedurou, which may be olther onsite or otisite. The burial of any LLW must be included in the Decommissicning Plan and approved by NRC.
Noto that the nuclear power facility sit, may already have oM LLW burials onsite. Those burials may require examination by the NRC before the c!!s may be released.
7.
On pago 41, we recommend editorial corrections for the response to the question,"How does decommissioning ond? And who decides that the decommissioning is complete."
Replaco "than" with "then"in the eighth line of the response and the third line f rom the bottom of the page.
8.
We recommend the addition of a question in this section on LLW, entitled, "What regulations are related to radioactive low-level waste disposal?" The answer would be i0 CFR Part 61 and 10 CFR Part 20 Subpart K.
In additior', the LLDP staff has reviewed pages relevant to decommissioning of the draft NUREG report, and provided our comments.
9.
On paw 4, we suggest the deletion of the question and response to the question, *What is the difference between radioactive contamination and activation pioducts? And where are ccntaminated r. aterials and activated materials located?"
This discus'; ion on contaminated materials and activation products is very confusing.
The third paragraph states that activation products remain in the matrix of the originally nonradioactive or stable material, it is our understanding that this is incorrect because some activation products, such as Co-60. are widespread throughout the plant and are a j
major source of activity in contaminated materials.
10.
On page 10, we suggest a modification of the decommissioning status of B!g-Rock Point in the response to the question,"What NRC-regulated plants have been or are being
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decommissioned? What decommissioning alternatives have been or are being usad?"
In its PSDAR, Big Rock Point in Charlevoix, Michigan has selected the DECON option.
11.
On page 31, we propose ve.ification of a statement in the response to the e,uestion, "Do spent fuel pools leak, and if so, how much radioactive material could be leaked, and where would it go?"
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Seymour H. Weiss Vorify the accuracy of the last sentence, "All nuclear plants have a ground water monitoring system so that... " Note that the groundwater monitoring program at Connecticut Yankee was very ineffective because only a few monitoring wells were available and only one was adequate for drawing samples.
12.
On page 31, we propose verification of a statement in the response to the question, "What can be done to prevent the spent fuel pool frem boiling dry?"
Verify the accuracy and the power plants' compliance with the second sentence,"The plants technical specifications require that the spent fuel pool coolant temperature is maintained at a specific temperature and that the level of the water is maintained at a specific height over the spent fuel." Based on recent meetings with Maine Yankee, it appears that Maine Yankee never had these requirements.
13.
On page 32, we suggest the addition of a brief description of wet storage options that are available to nuclear power plants in the response to the question,"What is an Independent Spent Fuel Storage installation (ISFSI)."
14.
On page 38, we suggest the modification of the first sentence in the response to the question, "How is low-level radioactive waste shippea to the disposal site?" Change the first sentence to," Low-level radioactive waste is sEpped with appropriate shielaing to meet Depadment of Transponation and NRC shipping requirements."
15.
On page 39, we propose verification, with the Spent Fuel Projects Office (SFPO) in NMSS, of the response to the question,"Are specific routes used for transporting radioactive materials?" It is our understanding that certain high activity sh'pments are route controlled.
16.
On page 40, we propose verification, with SFPO in NMSS, of the response to the question,"Does the NRC approve the routes used for radioactive material shipments?" It is our understanding that NRC does approve certain routes used for radioactive material shipments, such as for spent fuel.
17.
On page 48, we suggest updates in the response to the question, "What uses have been made of sites t'c' were decommissicned in the past?" Pathfinder is now a naturt? gas boiler used with the existing turbine. The Shoreham site is currently not being used.
18.
On page 52, we suggest the addition of "and liquid" after the first word in the response to the question,"Can you measure the effiuent releases to know how mucn are really entering the environment?"
19.
On page 52, we suggest the deletion of the last sentence from the response to the question,"What hazards are presented to the public when the waste is shipped?"
20.
On page 54, we suggest a modification of the decommissioning status of Trojan Nuclear Plant in the response to the question,"How much does it cost to decommission a nuclear power plant?" Change the last sentence of the third paragraph to,"The Trojan Nuclear P' ant is current ly dismantling the plant."
21.
On page 55, we propose verification of the second paragraph in the response to the question,"When are the estimates of the decommissioning cost made?"
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Seymour H. Weiss
- The first sentence of the second paragraph states, "The second estimate occurs at or about 5 years prior to the projected end of operations," It is our understanding that this requirement was removed in ttle 1996 decommissioning rulemaking, and thus, is not in NRC's current regulation.
- 22.
On page 57, we propose verification of the last sentence and its deletion from the response to the question, "Do the financial assurance regulations apply for Federal government licensees?"
We advise verifying the last sentence, "The full we!ght of the Federal Govemment is behind the commitment," with R. Wood. it is somewhat uncertain that TVA has the authority to make such commitment for the Federal government.
23.
On page 58, we suggest two modifications of the response to the question,"What if the cost of decommissioning exceeds the amount of money in the trust fund" Delete from the first sentence, "five years before anticipated shutdown," because this is no longer true.
Delete the last sentence which is not correct. Note that, if there is insafficient money in the trust fund, the licensee will continue to be responsible for all the decommissioning cost. Additicaal funding may need to be provided by shareholders or from the utilities rate base.
24.
On page 58, we propose a review for accuracy by the Office of General Counsel of the response to the question, "What contingency plans are in place to assure that decommissioning and long term radioactive material storage will'se properly performed in the avent of financial default of the utility? What if the utility becomes bankrupt or insolvent? Who finances decommissioning in this case?"
If you have any questions, please contact Sherry Wu of my staff at (301) 415-6619.
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Seymour H. Weiss 5-The first sentence of the second paragraph states,"The second estimate occurs at or about 5 years prior to the projected end of operations." It is our understanding that this
= requirement was removed in the 1996 decommissioning rulemaking, and thus, is not in NRC's current regulation.
22.
On page 57, we propose verification of the last sentence and its deletion from the response to the question, "Do the financial assurance regulations apply for Federal government licensees?"
We advise verifying the last sentence, "The full weight of the Federal Govemment is behind the commitment," with R. Wood. it is somewhat uncertain that TVA has the authority to make such commitment for the Federal govemment.
3 23.
On page 58, we suggest two modifications of the response to the question,"What if the cost of decommissioning exceeds the amount of money in the trust fund" Delete from the first sentence, "five years before anticipated shutdown," because this is no longer true.
Delete the last sentence which is not correct. Note that, if there is insufficient money in the trust fund, the licensee will continue to be responsible for all the decommissioning cost. Additional funding may need to be provided by shareholders or from the utilities rate base.
24.
On page 58, we propose a review for accuracy by the Office of General Counsel of the response to the question, "What contingency plans are in place to assure that decommissionin0 and long term radioactive material storage will be properly performed in the event of financial default of the utility? What if the utility becomes bankrupt or insolvent? Who finances decommissioning in this case?"
If you have any questions, please contact Sherry Wu of my staff at (301) 415-6619.
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