ML20210N365
| ML20210N365 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-140, SECY-97-140-01, SECY-97-140-1, SECY-97-140-R, NUDOCS 9708250196 | |
| Download: ML20210N365 (19) | |
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POLICY ISSUE (Notation Vote)
July 8, 1997 SECY-97-140 f_QB:
The Commissioners fBQM:
L. Joseph Callan Executive Director for Operations
SUBJECT:
MEMORANDUM 0F UNDERSTANDING AND INTERAGENCY AGREEMENT, BETWEEN THE U.S. DEPARTMENT OF ENERGY AND THE U.S. NUCLEAR REGULATORY COMMISSION, ON ALUMINUM-BASED RESEARCH REACTOR SPENT NUCLEAR FUEL PURPOSE:
To transmit to the Commission, for review and approval, the attached draft Memorandum of Understanding (MOV), and the attached draft Interagency Agreement (IA), between the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy (DOE).
BACKGROUND:
Consistent with the requirements of the Nuclear Waste Policy Act of 1982, as amended, DOE is responsible for the safe disposal of the nation's current and expected inventory of spent nuclear fuel (SNF) in a licensed geologic repository. This inventory includes commercially generated SNF (i.e., from domestic power reactors), as well as the non-commercial SNF within DOE's jurisdiction. The inventory of non pommercial SNF is expected to include a projected 60 metric tonnes (1.3 x 10 pounds) of aluminum-based SNF from both domestic and foreign research reactors. This SNF will be managed at the DOE 4
Savannah River site in South Carolina pending development of strategies for repository disposal.
CONTACT:
Richard A. Weller, NMSS/DWM NOTE: TO BE MADE PUBLICLY AVAILABLE IN (301) 415-7287 5 WORKING DAYS FROM THE DATE OF THIS
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The ~ aluminum-based SNF is significantly different from commercial SNF in design. structure, materials of construction.-and enrichment. While the-d aluminum-based SNF constitutes only a small fraction (about-one percent by volume) of the total inventory of SNF anticipated for repository disposal it warrants special consideration because of its unique characteristics.
In
) articular, about three-quarters of the aluminum-based SNF are in the form of l
lighly enriched uranium, with a uranium-235 enrichment of at least 20 percent and as high as 93 percent of total uranium.
F This enrichment poses potential. issues with respect to waste package design and long-term criticality control in the repository environment.
Further, the construction of SNF with aluminum (either as cladding or as a uranium-aluminum alloy fuel material) renders the fuel more susceptible to corrosion than commercial SNF.
4 To address the above issues. DOE established-a-program for the development of a technical strategy for the interim management and ultimate disposition of i
all aluminum-based research reactor SNF.
In early 1996. DOE expressed interest in briefing staff on-the elements of its technology development program, and in March 1996. NRC and DOE staffs met to discuss DOE's 1:
alternative concepts for the management, treatment, and ultimate disposition of the aluminum-based SNF.
As part cf its technology development program. DOE was particularly interested in seeking the assistance of staff in identifying potential issues'related to the ultimate dis)osition of SNF in a geologic '
repository. - Accordingly, subsecuent to the iarch 1996 meeting, staff began working with DOE to develop an FOU that would establish the framework for NRC
'to provide technical assistance to DOE in regard to the technology development
Both staffs met-again in October 1996 to discuss the details of NRC's-involvement in the technology development program.
DOE plans to develop as many as 18 technical reports, over an 18-to 24-month l
.-period, for submittal to NRC for review and comment.
Staff would review and provide comments on these reports to assist DOE in ideni fying potential issues related to-the ultimate disposition of the aluminum-based SNF in a geologic repository (e.g.. DOE concepts for criticality control).
Staff believes tLat'the level of effort for this technical assistance will necessitate a total of approximately one full-time equivalent per year.
. divided between staff and contractor support, for roughly the two-year period Center for Nuclear = Waste Regulatory Analyses. project will be obtained from't of-involvement. Anticipated support for the This MOU is entered into underithe broad umbrella of the January 15. 1997.
NRC/00E MOV on " Cooperation in Support of Significant Projects and -
Activities." The January 15. 1997 MOV established the following funding policy:
"NRC generally will not participate in projects and activities pertaining to DOE's responsibilities unless Congress appropriates resources to NRC for_such activities.
Exceptions will'be considered by NRC on a case-by-case basis and only if DOE reimburses NRC for its full agency cost."
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-The Commissioners--
3 InSECY-95-012.i"ReimbursementforWorkPerformedforOtherAgencies"the Commission established a-policy of chargin
' work-for others that is not a part of NRC'g full Agency costs in performing _
s statutory mission and for.which
-NRC receives no appropriations.
Recovery of: full costs requires charging the license fee rate in effect at the time the work is performed to recover direct salary. benefits, travel. -and an a)propriate share of Agency overhead costs.
Full-cost. recovery also requires clarging for direct contractual support costs.
DIEC11SS10N:
The staff has provided -for the Comission's review, the attached draft MOU and draft IA.
The MOU and-IA result from DOE /NRC technical and general counsel staffs' joint efforts.
Further, as-appropriate. the MOV and IA incorporate the changes specified in the June 19. 1997_ Staff Requirements Memorandum for SECY-97-096, the MOU and IA between DOE and the NRC on the
- closure of-the high-level waste storage tanks at.the Savannah River site.
The MOV establishes a basic framework for NRC to provide technical assistance
-to DOE in regard to DOE's aluminum-based SNF technology development program.
Provision of NRC technical assistance to DOE.for DOE's aluminum-based SNF_ technology development program is not included--in NRC's FY 1997-or FY 1998 budgets.
Therefore, the IA associated with this MOU provides for NRC to be reimbursed for its full costs. Should funds to support this project be appropriated to NRC in the future, then the terms of the IA
-will be reassessed.
-COORDINATION:
-This paper has been coordinated with the Office of the General Counsel, and it-I has no legal _ objection. The Office of the Chief Financial Officer / has also reviewed the paper and concurs.
RECOMMENDATION:
It is recommended that the Commission approve the signing of the attached MOU and IA.
L.QpsephCallan Executive Director for Operations Attachments:
1.
MOU-
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Commissioners'Lcomments or consent.should be provided directly to the Office of.the Secretary by COB Wednesday. July 23, 1997.
Commission-Staff-Office' comments,-if any, should be submitted to the-Commissioners NLT July 16. 1997, with an information copy;to the 0ffice of the Secretary.
If-the paper is of such a nature that;it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may1be expected.
DISTRIBUTION:
Commissoiners OGC-OCAA1 01G OPA
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ATTACHMENT I MOU
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AIEMORANDUh1 OF DNDERSTANDING IIETWEEN Tile U.S. DEPARTA1ENT OF ENERGY AND Tile U.S. NUCLEAR REGULATORY COA 1 MISSION ON ALUMINUM HASED RESEARCil REACTOR SPENT NUCLEAR FUEL 1.
Purnose The purpose of this Memorandum of Understanding (M0tJ) between the U.S.
Department of Energy (00E) and the U.S. Nuclear Regulatory Commission (NRC)is to establish a basic framework for NRC ta prons technical assistance to DOE in connection with DOE's ide itification of potential issues relating to the ultimate disposition of aluminum based iescarch reactor spent nuclear uel(SNF) from both foreign and domestic r
research reactors. DOE's goal is the near term placement of SNF into interim storage in a form that will be acceptable for ultimate disposalin a geologic repository. The NRC's technical support will assist DOE in identifying issues relating to NRC high level waste (HLW) disposal requirements that may be applicable to the ultimate disposition of aluminum based SNF.
11.
Introductin_n Aluminum based research reactor SNF is a relatively small part of DOE's total SNP l
inventory and an even smaller part of the totalinventory of SNF requiring disposition (less than 1% of all SNF by volume). Nevertheless, alumir.un-based research reactor SNF presents certain technical challenges, About 70% contains highly enriched uranium (that is, greater than 20% U-235). Even many of the low enricheu fue! assemblies have enrichmcnts approaching 20% U 235. These enrichment values introduce unique criticality controlissues. In addition, this SNF is either aluminum clad or uranium.
aluminum alloy and, therefore, vulnerable to corrosion when placed in wet storage for l
long periods. Such SNF exists in a variety of sizes, shapes, and structural configurations, with attendant differences in handling, packaging, and treatment requirements, and may therefore result in several similar, but differing, waste forms for interim storage and ultimate disposition.
Establishing a course of action leading to the ultimate disposition of aluminum-based research teactor SNF is a matter of high priority to DOE. With regard to foreign research reactor SNF containing highly enriched uranium, the ultimate disposition of such fuel is in the United States' national interest. The current projected availability of the geologic repository is such that interim management of this SNF will be required.
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DOE has developed a technical strategy for interim management and expected ultimate disposition of aluminum based research reactor SNF. The DOE strategy calls for I
technology development efforts to be conducted at the DOE Savannah River Site through cooperation with and the assistance of DOE's Omce of Civilian Radioactive Waste Management (OCRWM). DOE hopes to make a decision by the year 2000 on one or more disposition approaches for aluminum based research reactor SNF, A critical factor in the consideration of approaches is repository waste form requirements. It is essential that such requirements be investigated and tentstive!y identified by DOE so that DOE can proceed with near term implementatloa ofinterim storage approaches based on an informed judgment of what will be equired for ultimate disposal in the repository.
DOE has designated the Savannah River Operations Omcc (DOE SR) to manage aluminum based SNF in coordination with the Idaho Operations Omce and the Idaho National Engineering Laboratory. DOE SR will provice documents and materials for review by the NRC and reimburse the NRC for its activitics under this MOU.
Ill.
Authority A.
Department of Energy i
The Atomic Energy A::t of 1954, as amended, including sections 31,91,1611; the Energy Reorganization Act of 1974, as amended, including section 104; the Nuclear Waste Policy Act of 1982, as amended, including section 114; the Department of Energy Organization Act of 1977, including section 301(a); the Economy Act of 1932, as amended; section VI of the umbrella MOU between NRC and DOE dated February 24,1978; and section IV B 2 of the MOU between NRC and DOE for Cooperation in Support of Significant Projects and Activities, dated January 15,1997.
H.
Nuclear Regulatory Commission The Economy Act of 1932, as amended; the Atomic Energy Act of 1954, as amended, including section 31; the Energy Reorganization Act of 1974, as amended, including section 205; section VI of the umbrella MOU between NRC and DOE dated; February 24,1978; and section IV-B 2 of the MOU between NRC and DOE for Cooperation in Support of Significant Projects and Activities, dated January 15,1997.
IV.
Anreements Between Partiel A.
R'esponsibilities The Key Program Representatives for this MOU will be:
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1.
Director, Omce of Nuclear hiaterial Safety and Safeguards, NRC 2.
Assistant hinnager for hinterial and Facility Stabilization, DOE-SR (in coordination with tne Ultice of Spcot Fuel hianagement) 3.
Director, Omce of Program hianagement and Administration, DOE Omce of Civilian Radioactive Waste hianagement l
4.
Assistant hianager for Licensing, Yucca hiountain Site Characterization Ollice I
These individuals may designate appropriate stafTrepresentatives for the purpose of administering this h10U.
H.
General f
1.
NRC and DOE recognize the importance of providing information to the l
public regarding activities and regulatory decisions that may affect the
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public health and safety or protection of the environment. hicetings between NRC and DOE in connection with these activities shall be governed by the NRC's policy on open staff meetings (58 FR 48340, September 20,1994),
2.
Each agency will be responsible for safeguarding, control of, and accounting for clsssified, proprietary, and procurement sensitive information used or furnished in connection with tasks under this hiOU in accordance with its established procedores.
3.
Committees such as the Advisory Committee on Nuclear Waste, the Defense Nuclear Facilities Safety Board, and the Nuclear Waste Technical Review Board provide independent review of their respective agency's facilities, activities, and related matter ( As appropriate, NRC and DOE agree to support these types ofindependent reviews by providing readily available information or attending briefings related to their respective areas ofresponsibility.
4.
Each agency shall be responsible for processing allegations (i.e.,
declarations or statements or e.ssertions ofimpropriety or inadequacy whose validity has not been ertablished) regarding the DOE research reactor SNF program under its establi;hed allegations procedures. Each agency will keep the other agency idiarmed, as appropriate, of such allegations, the allegation's status, and the allegation's resolution.
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5.
If an issue arises in the implementation of thl MOU which cannot be resolved at the agency working level, the NRC and DOE agree to refer the matter within 30 days to the Director, NMSS, NRC and to the Assistant Manager for Material and Facility Stabilization, DOE SR for appropriate action.
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6.
DOE SR will provide office space as necessary to accommodate NRC visits to the Savannah River Site and will coordinate attendaace of all parties to any reviews requested by the NRC. Close coordination between the NRC and DOE is essential to timely project implementation.
C.
Planning and Reimbursement of Costs -
1; NRC and DOE will cooperate in planning activities to ensure that both agencies anticipate the magnitude of funding, the allocation of resources, and the timing of events necessary to conduct tasks associated with this MOU.
2.
Tasks for which DOE requests NRC review, consultation, or comments in accordance with the attached or a subsequently-executed Interagency Agreement are generally subject to reimbursement at full agency costs from DOE in accordance with established NRC regulations, policies, and procedures on reimbursement for work performed for other Federal agencies.
3.
DOE shall reimburse NRC for resources expended, subject to the availability of funds, to conduct specific tasks for which DOE requests NRC review. The parties intend to enter into an Interagency Agreement for this purpose and to estimate the level of resources and periods of performance associated with this eff' ort. This MOU shall not be used to obligate or commit funds or as the basis for the transfer of funds.
4.
DOE anticipates holding face to face discussions with NRC approximately once a month.
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D, Specific Tasks 1.
NRC will assist DOE in identifying potential technical issues associated
- with the ultimate disposition of aluminum based research reactor SNF for planned repository configurations.
2.
NRC and DOE will work together to develop an overall schedule for accomplishing specific activities under this MOU.
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3.
DOE will conduct evaluations and analyses, document the results ofsuch efforts, and provide the results to NRC. NRC will provide such comments, as appropriate, on the documenied results as rnay assist DOE in identifying potentialissus associated with the ultimate disposition of the aluminum-based research reactor SNF. Topics may include treatment methodologies, packaging approaches, material form, pyrophoricity, criticality control, and potential impact of disposal of this SNF on overall repository performance l
over the time frames ofinterest.
V.
Other Provisions A.
Nothing in this MOU shall limit the authority of either agency to exercise its authority independently with regard to matters that are the rubject of this MOU.
B.
Nothing in this MOU is intended to conflict with any other MOU between the NRC and DOE. In the event of a conflict between this MOU and any MOU between the NRC and DOE regarding prelicensing and licensing interactions affecting facilities of the Civilian Radioactive Waste Management System subject to licensing authority of the NRC, the provisions of the other MOU shall govern.
C.
This agreement is not intended to conflict with the NRC's responsibility to license a geologic repository. The NRC's activities under this MOU do not constitute a commitment to issue any approval, authorization or license, or in any way affect the NRC's authority in any licensing proceeding.
D.
Nothing in this MOU shall be deemed to establish any right or provide a basis for any action, either legal or equitable, by any person or class of persons challenging a Government action or a failure to act.
E.
This MOU shall be effective upon signature of both parties and will remain in effect until December 31,2001 or until terminated by mutual written agreement or by written notice of either party submitted at least 180 days in advance of termination. Amendments or modifications to this MOU may be made upon the written agreement of the parties.
F.
The NRC shall coordinate the disposition of rights to inventions with the DOE Patent Counsel.
G.
The NRC shall be reimbursed for the cost of activities within the scope of this MOU, as provided for in the Interagency Agreement which implements this MOU.
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4 VI.
Sinnatures For the Department of Energy For the Nuclear Regulatory Commission n
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Assistant Maja'ger :
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- gFacility Stabilization E Savannah River Material and NRC OfUce ofNuclear Material Safety i
and Safeguards b 6 8 3 0.\\ % 7 l
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U.S. DEPARTMENT OF ENERGY (DOE)
FUNDS-OUT INTERAGENCY AGREEMENT (IA)
INTERAGENCY AGREEMENT FACE PAGE I. ADDRESS OF ISSUING DOE OFFICE
- 2. a. RECIPIENT / PERFORMING AGENCY U. S. Department of Energy (DOE)
Savannah River Operations Office U. S. Nuclear Regulatory Commhslon P. O. Box A Washington, DC 20555 Aiken SC 29802 Administered for DOE by:
- b. Program Director / Technical Contact Beth O' Rear, Contract Specialist Margaret Federune Contracts Management Division U. S. Nuclear Regulatory Commhslon U. S. Department of Energy 11555 Rockviue Pike Savannah River Operations Office Rockvale, MD 20852 2738 P. O. Box A, Aiken, SC 29803 Phone: (301) 415 4 708 FAX: (301) 415 5397 Phone: (803) 725 1345 FAX: (803) 725-8573
- 3. a. DOE I A No.
DE-AIO9 97 SRI 8579
- 4. TYPE OF AWARD
- b. Modification No. 4000 NEW {
INCREMENTAL ] 011tER
- 5. PROJECT TITLE:
- 6. AUTIlORITY Alurninurn-Based Research Reactor Spent Nuclear Fuel
'nic Economy Act of 1932 (31 U.S.C.1535) : Department o Energy Organhation Act of 19771 P.L. 95 91
- 7. a. PROJECT PERIOD
- b. FUNDING PERIOD FROM:(Date of Acceptance TO: hxndur 31, ADI FROM:
Date of Acceptance TO: Ibcondar 31, ZD1 Date in Block 13)
(Date in Block 13)
- 8. ACCOUNTING AND APPROPRIATION DATA
$250,000 89X0242.91 EW7040
- 9. MET 110D OF PAYMENT:
- 10. BILLING INSTRUCTIONS:
O Advance x
Reimbursement I x l OPAC l
l S.F.1981 Voucher
- 11. DOE PROGRAM OFFICER Submit SF 1981 Voucher to:
Assistant Manag<Tfor Matedals and Facility Stabuhation U. S Deran=ient of Emngy U. S. Department of Energy Savannah En Orw d Omce Savannah River Operations Office Al'IM Acce==das Br ech P. O. Box A Aiken, SC 29802 P.O. Ben A. Aiken.SC 29802 Phone: (803) 952-2%f, FAX: (803) 952M
- 12. DO NT CI OFFICER
- 13. PERFORMING AGENCY ACCEPTANCE w h
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(date)
(signature)
(date)
NAME/TTTLE (Typed)
NAME/HTLE (Typed)
D. L. Campbeu, Contracting Officer John J. Linehan, Director Contracts Management Division Office of Nuclear Material Safety and Safeguards U. S. Depaitment of Energy U. S. Nuclear Regulatory Commission Savannah River Operations Office Washington, DC 20555 (301) 415-7780
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Aik 29802
- 14. GENERAL PROVISIONS / REQUIREMENTS
. Phone: (803) 725-2846 FAX: (803) 725-8573 See Attachment n
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t INTERAGENCY AGREEMENT BETWEEN Tile l
U.S. DEPARTMENT OF ENEROY U.S. NUCLEAR REOULATORY COMMISSION AND TiiE i
. Interagency Agreement j
Page1of4
- 1..
PURPOSE f
1
'Ihe purpose of this Interagency Agreement (IA) between the U.S. Department of Energy
_(DOE) and the U.S. Nuclear-Regulatory Commission (NRC). is to implement the Memorandum of Understanding dated April 30,1997-for NRC to provide technical l
assistance to DOE in mnnection with DOE's identification of potential issues relating to
- the ultimate disposition, in a geological respository, of aluminum-based research reactor
. spent nuclear fuel (SNF) from both foreign and domestic research reactors.
11, STATEMENT OF WORK The services to be perfonned are included in the attached Statement of Work.
111.
DURATION OFTHE AGREEMENT
- this Agreement shall terrein in effect f or m the date of execution until December 31, 2001, unless it is terminated by mutual written agreement or by written notice of either party submitted at least 180 days in advance of termination. This Agreement may be modified at any time by the mutual agreement of both DOE and NRC.
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Interagency Agreement No. DE A109 97SR18579-Page 2 0f 4 t
IV.
KEY PROGRAM REPRESENTATIVES DOB and NRC Key Program Representatives are identified below. These individuals may designate appropriate stafTrepresentatives for the day +to-day administration of this Agreement.-
-A.DDE Assistant Manager for Material and Facility Stabilization, DOE Savannah River Operations 001cc B.NEC Margaret Federline, Deputy Director Division of Waste Management 001ce of Nuclear Material Safety and Safeguards V.
jjSTIMATED COST AND OBLIGATION OF FUNDS A. The total cost for performance of the work during Fiscal Year 1997 is estimated at
$250,000. Costs will be billed in accostlance with NRC policy for charging full costs for reimbursable work NRC policy requires charging for direct staff time based upon the hourly rate as established in 10 CFR Part 170, in addition to any contractor costs incurred in order to perform services specified in the Statement of Work. Funding after Fiscal Year 1997 will be established on a yearly basis as mutually determined by DOE and NRC and subject to the availability of appropriated funds.
B. Pursuant to Article Vil, Limitation of Funds; funds in the amount of $250,000 are initially obligated for payment of allowable costs.
t Interagency Agreement No. DE A109 97SR18579 Page 3 of 4 VI.
. Payment A. Billing will be accomplished by the On Line Payment and Collection (OPAC) system -
as necessary.
NRC Billine Information Agency Location Code:
31 00-0001 NRC Point of
Contact:
Thalia Stevenson Address:
U.S. Nuclear Regulatory Commission Office of the Controller Division of Accounting and Finance Mail Stop: T-9C4 Washington, DC 20555 Telephone:
(301)415 6093 SR Finance Contact Agency Location Code:
89-00-0601 DOE-SR Point of
Contact:
Renee Alvis Address:
P.O. Box A Aiken, SC 29802 Telephone:
(803) 725 5605 B. NRC shall submit a financial report on a quarterly basis. Details shall be included on work completed and costs. The financial reports shall be submitted to the following address:
. U.S. Department of Energy Savannah River Operations Omcc i
ATrN: Donni,e L. Campbell, Contracting Omcer -
l P.O. Box A Aiken,SC 29802
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If Interagency Agreement No. DE-A109-97SR18579 Page 4 of 4 VII.
LIMITATION OF JUNDS A. It is estimated that the cost to DOE SR for the performance of work under this Agreement will not exceed the estimated cost set forth !n Article V.A.
l
- ESTIMATED COST AND OBLIGATION OF FUNDS. NRC agrees to use its best efforts to perform the work specified in the Statement of Work.
B. The amount presently available for payment and obligated to this Agreement is specified in Article V.B ESTIMATED COST AND OBLIGATION OF FUNDS. It is contemplated that from time to time additional funds will be obligated under this Agreement. NRC agrees not to exceed the total amount obligated.
Vll.
DOCUMENTS ATTACHED AND PART OF THIS AGREEMENT Statement of Work, Attachment A.
IX.--
DOCUMENTS INCLUDED BY REFERENCE The Memorandum of Understandinn between the U.S. Department of Energy and the U.S. Nuclear Regulatory Commission on-Aluminum Based Research Reactor Spent Nuclear Fuel is hereby incorporated by reference in this Agreement.
X.
REAL PROPERTY AND FACILITIES There is no real property or facilities under this Agreement.
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Attachment A Interagency Agreement I
No. DE-A109 97 SRI 8579 Fage I of 2 s
q STATEMENT OF WORK FROM THE i
U.S. DEPARTMENT OF ENEROY-
>ON ALUMINUM BASED REACTOR
-- SPENT NUCLEAR FUEL
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l.0 BACKOROUND 1.1 DOE has developed a technical strategy regarding the interim management and eventual ultimate disposition of aluminum based research reactor SNF. This strategy calls for
. technology development efforts to be conducted that will allow DOE to make a decision by the year 2000 on one or more disposition approaches for aluminum-based research reactor SNF. DOE seeks NRC's technical. support to assist DOE's Savannah River
. Operations Office (DOE-SR) in identifying issues relating to NRC disposal requirements that may be appl';.able to the ultimate disposition of the aluminum based SNF.
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. 1.2 The scope of effort is limited to technical assistance by the NRC staffin connection with DOE's identification of potential issues that might affect the direct disposition of the SNF after storage, including disposition in a repository under NRC high level waste disposal regulations.
2.0 DESCRIPTION
OF WORK TO BE PERFORMED 2.1 -
The NRC staff will assist DOE in interpreting NRC disposal requirements that may be.
applicable to the ultimate disposition of the aluminum-based SNF.
The NRC and DOE will work together to develop an overall schedule for accomplishing 2.2 specific activities under this Interagency Agreement.
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2.3 DOE will conduct evaluations and analyses, document the results of such efforts, and provide the results to the NRC staff. The NRC staff will provide such conunents, as appropriate, on the documented results as may assist DOE in identifying potential issues associated with the ultimate disposition of the aluminum bases research reactor SNF.
Topics may include treatment methodologies, packaging approt.ches, material forms, pyrophoricity, criticality control, and waste form data analysis.
2.4 Additional tasks may be identified throughout the course ofimplementing the agreement.
I 2.5 DOE-SR will pmvide ollice space as necessary to acconunodate NRC visits to the Savannah River Site and will coordinate attendance of all parties to any reviews requested by the NRC. Close coordination between the NRC and DOE is essential to timely project implementation.