ML20206H674
| ML20206H674 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1986 |
| From: | Johnson T, Starmer R, Voglewede J NRC |
| To: | |
| Shared Package | |
| ML20206H509 | List: |
| References | |
| NUDOCS 8606260257 | |
| Download: ML20206H674 (10) | |
Text
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8 EPRI/ASME Radwaste Workshop 2/10-11/86 Savannah, GA 407.19/TCJ/1/2/86 CURRENT REGULATORY ISSUES T. C. Johnson, R. J. Starmer, J. Voglewede, T. L. Jungling, L. S. Person, K. C. Chang, C. H. Peterson Introduction The purpose of this discussion is to address current regulatory issues applicable to low-level waste disposal practices at nuclear power plants.
Topics to be covered include the status of implementation programs for 10 CFR Part 61, the development of regulatory guides for waste form and waste classification, the status of topical report reviews and the impacts of new legislation on NRC programs.
Implementation of 10 CFR Part 61 i
The implementation o the low-level waste management regulation,10 CFR Part 61, has proceeded smoothly based on reviews of licensee inspection reports.
Utilities have developed waste classification programs based on assays of waste stream samples and have instituted programs to ensure that the waste stability requirements are met.
After the first two years of the implementation of 10 CFR Part 61, we have responded to many questions regarding waste classification and waste stability and we have reviewed new data, such as the NRC sponsored study, " Assay of Long-Lived Radionuclides in Low-Level Wastes from Power Reactors" (NUREG/CR-4101) performed by Science Applications International Corporation (SAIC).
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407.19/TCJ/1/2/86 .
le These experiences have enabled t s to conclude that the fundamental philosophy
- of 10 CFR Part 61 is solid and practical. We are currently, however.
l addressing several areas where we believe modifications are needed. This i discussion will provide additional background on these modifications.- ,
Regulatory Guides 4
The NRC is currently preparing regulatory guides on waste classification and l
j waste form based on the technical positions issued in May 1983. These j
regulatory guides will be fundamentally unchanged versions of the technical l positions but will clarify several areas which have resulted in questions.
1 One of the major questions in the area of waste form is the acceptability of j asphalt. Several systems have been ordered and will be operational in the
) near future. The unit at Palisades has been producing hot wastes for approximately one year. While asphalt has good leach resistance properties it ;
3 has very little mechanical strength. It is not a hard, brittle material like l a cement solidified product but is soft and will flow under load. In order to
! ensure that Class B and C asphalt solidified wastes will meet the stability requirements we are allowing the option of administrative disposal site ,
l controls to ensure that asphalt wastes are properly backfilled. By !
l backfilling, flow of the asphalt wastes into surrounding voids between containers will be minimized.
I l We are also providing editorial clarification in several areas based on ,
)
industry questions. These areas include: 1) a clearer statement on what waste ,
j streams should be qualified (bead resins, powdered resins, boric acid i
evaporator bottoms, etc.), 2) tests which are needed to correlate small j laboratory specimens and full-size specimens (compression and immersion tests
} on a single, full-size specimen from one waste stream) and 3) an option to replace the fungi culture, penicillium funiculosum (requires a special license
- because it is a plant pathogen), with an alternative fungi culture.
I l
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o g 407.19/TCJ/1/2/86 In the area of waste classificatin we are planning to reduce the frequency of Tc-99 and I-129 assays to once every three years. This change is supported by results from the SAIC study and should reduce costs to utility waste generators.
We are also providing additional guidance on classifying activated components. This guidance would allow the use of activation analysis based on compositions of target nuclides supplied in materials certifications or other sample or chemical analysis of the activated material. The activation analysis should be followed up with a dose-to-curie measurement to verify the suitability for the activation analysis.
The NRC Division of Waste Management is currently providing comments to the Office of Research which is responsible for regulatory guide preparation. The current goal is to release the regulatory guides for formal comment this summer. Prior to release for formal comment, we will solicit comments from Agreement States regulating disposal facilities and the Utility Nuclear Waste Management Group.
Waste Classification Computer Codes The NRC has reviewed and approved Waste Management Group's Radman computer code for classifying wastes. We are currently reviewing the Impell Wastetrac code and the Cygna Cytrac code. Impell had also submitted their 61 TRAC code but recently withdrew it because of issues involving the technical efficacy of classifying wastes by extrapolating waste radionuclide inventories solely from reactor coolant concentrations.
i q' 407.19/TCJ/1/2/86 Topical Reports NRC has received twenty-one topical reports on high integrity containers (HIC's),
solidification agents and waste classification computer codes. Of these twenty-one reports, three have been approved (The Radman Computer code, the NUPAC FL-50 HIC and the General Electric AZTECH solidification agent). Two of these reports have been withdrawn (the NUS Polyethylene HIC and the Pacific Nuclear Filter Encapsulation Method). We are reviewing vendor responses to our comments on two topicals and are waiting for vendor responses on eight topicals. The
- remaining six reports are under review.
Impacts of New Legislation The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLWPAA) will affect the regulatory program at NRC in several areas. These areas include:
- a. Greater than Class C wastes,
- b. Emergency access to disposal sites,
- c. Alternative disposal methods,
- d. Licensing capability,
- e. Below regulatory concern (BRC) wastes.
The issue of regulatory responsiblity of mixed radioactive and hazardous chemical wastes was not addressed in this act. The LLWPAA also sets out detailed requirements for restricting access to regional disposal facilities and for allocating disposal capacity. The legislation also included adoption of the interstate compacts submitted to Congress. The LLWPAA gives the federal government responsibility for the disposal of wastes which exceed the
1 407.19/TCJ/1/2/86 Class C limits in 10 CFR Part 61. Greater than Class C wastes gelerated by NRC licensees would be required to be disposed of in an NRC licensed facility.
The LLWPAA sets out a process for evaluating emergency access to regional disposal sites from generators not in the compact region of that disposal
! facility. In event that wastes are generated which pose an immediate threat to public health and safety or to common defense and security, the NRC is authorized to make a determination of the need for emergency access to the available disposal site. The LLWPAA sets out the procedures for making this determination, the limitations for its use and requirements for reciprocal access, volume reduction and surcharges.
The NRC is also required to consult with the States and other interested parties and within twelve months of the enactment of the LLWPAA identify alternative disposal methods to shallow land burial and establish and publish technical guidance regarding those methods. Within 24 months of the LLWPAA enactment NRC must publish all technical information which a State or compact must provide in order to pursue the alternative methods together with the technical requirements for these facilities.
The LLWPAA also requires the NRC to establish procedures and a licensing capability within 12 months of the enactment of the LLWPAA. In addition, to the extent practicable, the review and processing of license applications (except for public hearings) should be completed with 15 months of the receipt of the application.
Within six months of the enactment of the LLWPAA, the NRC must establish standards and procedures and develop the technical capability for reviewing petitions to exempt from Commission regulations specified waste streams containing sufficiently low radionuclide concentrations to be below regulatory Concern.
I EPRI/ASME Radwaste Workshop 2/10-11/86 Savannah, GA 407.19/TCJ/1/2/86
, CURRENT REGULATORY ISSUES T. C. Johnson, R. J. Starrer, J. Voglewede, T. L. Jungling, L. S. Persor., K. C. Chang, C. H. Peterson Introduction The purpose of this discussion is to address current regulatory issues applicable to icw-level waste disposal cractices at nuclear power plants.
Topics to be covered include the status or impismentation programs for 10 CFR Part 61, the development of regulatory guides for waste form und waste classification, the status of topical report reviews and the impacts of new legislation on NRC programs.
. Implementation of 10 CFR Part 61 The implementation of the low-level waste management regulation,10 CFR Part
, 61, has proceeded smoothly based on reviews of licensee inspection reports.
Utilities have developed waste classification programs based on assays of waste stream samples and have instituted programs to ensure that the waste
! stability requirements are met. .
After the first two years of the idblrmentation of 10 CFR Part 61, we have responded to many questions regardino waste classification and waste stability and we have reviewed new data, such as the NRC sponsored study, " Assay of Long-Lived Radionuclides in Low-Level Wastes from Power Reactors" (NUREG/CR-4101) performed by Science Applications International Corporation +
(SAIC).
e e
l i
I
- -, , ,_..m. _ _ -
407.19/TCJ/1/2/86 Taese experier.ces have enabled us to conclude that the fundamental philosophy of 10 CFR Part 61 is solid and practical. We are currently, however, addressing several areas where we believe modifications are needed. This i discussion will provide additional background on these modifications.
Regulatory Cuides The NRC is currently preparing regulatory guides on waste classification and a waste form based on the technical positions issued in May 1983. These regulatory guides will be fundamentally unchanged versions of the technical '
positions but will clarify several areas which have resulted in questions. '
One of the major questions in the area of waste form is the acceptability of '
asphalt. Several systems have been ordered and will be operational in the near future. The unit at Palisades has been producing hot wastes for -
approximately one year. While asphalt has good leach resistance properties it >
has very little mechanical strength. It is not a hard, brittle material like a cement solidified product but is sof t and will flow under load. In order to ensure that Class B and C asphalt solidified wastes will ineet the stability requirements we are allowing the option of administrative disposal site controls to ensure that asphalt wastes are properly backfilled. By backfilling, flow of the asphalt wastes into surrounding voids between containers will be minimized.
We are also providing editorial clarification in several areas based on industry questions. These areas include: 1) a clearer statement on what waste streams should be qualified (bead resins, powdered resins, boric acid evaporator bottoms, etc.), 2) tests which are needed to correlate small laboratory specimens and full-size specimens (compression and immersion tests on a single, full-size specimen from one waste stream) and 3) an option to !
replace the fungi culture, penicillium funiculosum (requires a special license ,
1 because it is a plant pathogen), with an alternative fungi culture. l l
l i
4 407.19/TCJ/1/2/86 In the area of waste classificatin we are planning to reduce the frequency of Tc-99 and I-129 assays to once every three years. This change is supported by results from the SAIC study and should reduce costs to utility waste generators.
. We are also providing additional guidance on classifying activated
- components. This guidance would allow the use of activation analysis based on
- compositions of target nuclides supplied in materials certifications or other sample or chemical analysis of the activated material. The activation
! analysis should be followed up with a dose-to-curie measurement to verify the i suitability for the activation analysis.
l The NRC Division of Waste Management is currently providing comments to the Office of Pesearch which is responsible for regulatory guide preparation. The
) current goal is to release the regulatory guides for formal comment this
! summer. Prior to release for formal comment, we will solicit comments from i Agreement States regulating disposal facilities and the Utility Nuclear Waste Management Group.
i j Waste Classification Computer Codes The NRC has reviewed and approved Waste Management Group's Radman computer
- code for classifying wastes. We are currently reviewing the Impell Wastetrac code and the Cygna Cytrac code. Impell had also submitted their 61 TRAC code j but recently withdrew it because of issues involving the technical efficacy of classifying wastes by extrapolating waste radionuclide inventories solely from
- reactor coolant concentrations.
I i
t l
- .o 407.19/TCJ/1/2/86 Topical Reports NRC has received twenty-one topical reports on high integrity containers (HIC's),
i solidification agents and waste classification computer codes. Of these twenty-one reports, three have been approved (The Radman Computer code, the NUPAC FL-50 HIC and the General Electric AZTECH solidification agent). Two of these reports have been withdrawn (the NUS Polyethylene HIC and the Pacific Nuclear Filter Encapsulation Method). We are reviewing vendor responses to our comments on two topicals and are waiting for vendor responses on eight topicals. The remaining six reports are under review.
Impacts of New Legislation The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLWPAA) will affect the regulatory program at NRC in several areas. These areas include:
, a. Greater than Class C wastes,
- b. Emergency access to disposal sites,
- c. Alternative disposal methods,
- d. Licensing capability,
- e. Below regulatory concern (BRC) wastes.
The issue of regulatory responsiblity of mixed radioactive and hazardous chemical wastes was not addressed in this act. The LLWPAA also sets out detailed requirements for restricting access to regional disposal facilities
, and for allocating disposal capacity. The legislation also included adoption of the interstate compacts submitted to Congress. The LLWPAA gives the federal government responsibility for the disposal of wastes which exceed the l l
l l
[ .
407.19/TCJ/1/2/86 Class C limits in 10 CFR Part 61. G eater than Class C wastes generated by NRC licensees would be required to be disposed of in an NRC licensed facility.
The LLWPAA sets out a process for evaluating emergency access to regional disposal sites from generators not in the compact region of that disposal facility. In event that wastes are generated which pose an immediate threat to public health and safety or to common defense and security, the NRC is authorized to make a determination of the need for emergency access to the available disposal site. The LLWPAA sets out the procedures for making this determination, the limitations for its use and requirements for reciprocal access, volume reduction and surcharges.
The NRC is also required to consult with the States and other interested parties and within twelve months of the enactment of the LLWPAA identify alternative disposal methods to shallow land burial and establish and publish technical guidance regarding those methods. Within 24 months of the LLWPAA enactment NRC must publish all technical information which a State or compact must provide in order to pursue the alternative methods together with the technical requirements for these facilities.
The LLWPAA also requires the NRC to establish procedures and a licensing capability within 12 months of the enactment of the LLWPAA. In addition, to the extent practicable, the review and processing of license applications (except for public hearings) should be completed with 15 months of the receipt of the application.
Within six months of the enactment of the LLWPAA, the NRC must establish standards and procedures and develop the technical capability for reviewing petitions to exempt from Commission regulations specified waste streams containing sufficiently low radionuclide concentrations to be below regulatory Concern.