ML20216E633
| ML20216E633 | |
| Person / Time | |
|---|---|
| Issue date: | 09/05/1997 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Wallo A ENERGY, DEPT. OF |
| Shared Package | |
| ML20216E638 | List: |
| References | |
| REF-WM-3 NUDOCS 9709110031 | |
| Download: ML20216E633 (8) | |
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Septenber 5,1997 Mr. Andrew Wallo, Director Air, Water and Radiation Division Office of Environment Safety, and Health U.S. Department of Energy Forrestal Building, Room 098, EH 232 Wash!ngton, DC 20585
Dear Mr. Wallo:
I am responding to David Huizenga's memorandum of July 24,1997, in which he requested Nuclear Regulatory Commission comments on two draft IAEA documents on low-level radioactive waste disposal. Our comments are enclosed. If you have any questions, f
please cail me at (301)-415 7347.
Sincerely, (ORIGINALSIGNEDBY:]
John T. Greeves, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated Ticket No, EDO 97549, DWM-179 DISTRIBUTION:
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't,*****,e September 5, 1997 Mr. Andrew Wallo, Director Air, Water and Radiation Division Office of Environment, Safety, and Health U.S. Department of Energy Forrestal Building, Room 098, EH 232 Washington, DC 20585 Dear Mr< Wallof (/
I am responding to David Hulzenga's memorandum of July 24,1997, in which he requested Nuclear Regulatory Commission comments on two draft lAEA c'ocuments on low-level radioactive waste disposal. Our comments are enclosed if you have any questions, please call me at (301)-415 7347.
Sincerely, 9; o
- ~)s pem dohn T. Greeves, Director f
Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated
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COMMENTS ON DRAFT lAEA DOCUMENTS l.
lAEA Draft Safety Requirements on " Hear Surface Disposal of Radioactive Waste," (No.111.S.3)
G9BeLal This version of the Safety Requiremants generally reflects previous NRC staff comments. The revised requirements for institutional controls appear to be written broadly and flexibly enough to allow for a variety of different apprcaches to achieve safety.
Sucific Comments:
103 and 107 The document is said to apply to *near surface disposal' of waste and to "near surface repositories." It would be useful if it were made clear that this document does not apply to restricted release scena ios for facil. ties undergoing remediation and decommissioning.
203 The phrase "... mitigating the consequences of any releans," suggests that measures should be taken to achieve *zero release *, Suggest revising to *... mitigating the consequences of unacceptable releases to the accessibis environment."
1 213 Section 213 applies to extreme events that could result in very large doses (.5 Sv) and states that measures should be taken to reduce the potential for such events. We believe that this section is not necessary. The previous paragraph adequately addresses the full spectrum of unlikely events, including those that potentially could cause large doses. It requires that these events be considered in the safety analysis of the facility. Also, we are unaware of any events
% a disposal facility that could cause short term exposures on the order of 0.5 Sv. Such a dose is theoretically possible f" a nuclear power teactor, and requirements such as "protectic actions' are imposed to address such situations but we believe that such doses are not credible for a disposal facility.
303 The requirement cites oredictive modelina of future behavior as one of the means of estimating performance. To be consistent with the accompanying occument on safety assessments, the requirement should suggest that model outputs are Indicators of what could happen in the -
future, or that models are used to reach reasonable assurance that a site provides an adequate level of safety, l'he Safety Assessment document contains useful guidance on this point that Enclosure
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could be incorporated into the document on Near Surface Disposal, viz.
204 which states:
"The real aim of the post-closure assessments is, therefore, not to predict the disposal system performance, but rather to reach reasonable assurance that it will provide an adequate level of safety."
H 304 lhe requirement suggests that a system of multiple barriers is needed, where the consequence of failure of one barrier is limited by the performance of another. This implies a ' defense in depth" approach where redundant barriers are used and the failure of one barrier does not prevent the system from functioning as needed to protect public health and safety. This concept is not employed in the same way in NRC's LLW disposal program. Generally performance of all of the system components (waste package, engineered barriers, site features, etc) are modeled using conservative assumptions, and with sensitivity studies.
Barriers may not be assumed to " fail" (i.e. to have no contribution to performance). To address this problem, we suggest that the third sentence be deleted.
504 & 511 These sections state that the waste package must meet all of the transportation requirements and rule out the possibility that waste packages could be contained in overpacks or liners for transportation purposes, and then removed for disposal. Clarification is needed.
1101 This requirement states that the safety of a closed repository should not rely on institutional controls that require extensive and ongoing maintenance.
1107 discusses what may need to be done under an appropriate maintenance program. The suggested maintenance activities are quite extensive and would suggest that a closed repository could rely on extensive controls and maintenance. We suggest that language be added that helps to clarify these two sections and their relationship to each other.
II.
IAEA Draft Safety C.uide on " Safety Assessment for Near Surface Disposal (No.
11 C 3.3) 204 This section states that safety assessments may need to project site and facility behavior for time periods of the order of hundreds or even some thousar:ds of years. It would be helpfulif additional guidance could be provided on how to determine the time frames that are adequate for safety assessments.
g Mr. Andrew Wallo, Director Air, Water and Radiation Division Office of Environment, Safety, and Health U.S. Department of Energy Forrestal Building, Room 098, EH 232 l
Washington, DC 20585
Dear Mr. Wallo:
I am responding to David Huizenga's memorandum of July 24,1 7 o.hich he requested NRC comments on two draft IAEA documents on low level r ioactive waste disposal. Our
/
comments are attached. If you have any questions, ple e caH me at (301)-415 7347.
Since ly, J n T. Greeves, Director ivi of Waste Management Offi of Nuclear Material Safety and Safeguards
Enclosure:
As stated Ticket No. EDO 97549, DWM-17 DISTRIBUTION:
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'2 4I g-i TICKET NUMBER: E0090549 DUE TO DIVISION: September 3. 1997 DUE TO NMSS: September 5, 1997 DUE TO EDO:
September 10. 1997 LETTER T0:
Andrew Walb. DOE FROM:
John Greeves. NRC
SUBJECT:
Comments on Draft IAEA Safety Standards for LLW ORIGINATOR: J. Kennedy ROOM NO./ BLDG:T7F40 SECRETARY: Cecilia Villarreal PHONE NO :
415-6668 I
NOTEl This ticket will be closed by Greeves letter to Andrew Wallo of DOE, NOT with a letter from Callan to IAEA, as the original ticket directed. This was agreed to by EDO several weeks ago. The reason is that DOE coordinates all comments fo,-
the U.S.A. and had sent us a letter asking for our comments. Thus, the incoming from lAEA received by the EDO has been superseded and replaced with the DOE incoming--JEK
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EDO Principal Correspondence Control FROM:
DUE: 09/10/97 EDO CONTROL: G970549 DOC DT: 06/25/97 FINAL REPLY:
Secretariat of the International Atomic Energy Agency (IAEA)
TO:
Callan, EDO FOR SIGNATURE OF :
- GRN CRC NO:
Callan, EDO DESC:
ROUTING:
COMMENTS ON DP. AFT SAFETY STANDARDS DOCUMENTS -
Callan SAFETY REQUIREMENTS ON NEAR SURFACE DISPOSAL OF Jordan RADIOACTIVE WASTE AND SAFETY GUIDE ON SAFETY ASSESSMENT FOR NEAR SURFACE DISPOSAL Thompson Norry Blaha.A e
Burns DATE: 07/22/97 Bangart, SP ASSIGNED TO:
CONTACT:
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FOlt INI'OllMATION k
o INTERNATIONAL ATOMIC ENERGY AGENCY
- AGENCE INTERN ATIONALE DE L'ENERGIE ATOMIQUE ME*RYllAPORllOE ATEllTCTDO Il0 ATOMilOf1311EPrilli ORG ANISMO INTERNACIONAL DE ENERGIA ATOMICA WAoRAMERsTRAssE 5.P.o. DoX 100. A.1400 VIENNA, AUSTRIA TLLE.X: 1 12645, CADLE: INAToM vlENNA, FACSIMILE:(+43 I) 20607, TILEPHoNE:(+43 l} 2060. E-MAILt IAEo @tArAl.tATA oR.AT.
su sssti roLAss mta to txAL omicTty to txnwsion mrn DE kAMMR LA WWNct T2.03 Circ, ccwostmasenurur u mano ot rosit 26101 The Secretariat of the International Atomic Energy Agency presents its compliments to the Ministries of Foreign Affairs of Member States of the Agency and has the honour to request that they draw the attention of the appropriate Goverer ntal authorities to review the following draft Safety Standards documents.
L Safety Requirernents on Near Surface Disposal ofRadioactive ll'aste 2.
Safety Guide on Safety Assessinentfor Near Surface Disposal These documents were prepared within the Radioactive Waste Safety Standards (RADWASS) program'ne. They were developed and reviewed through consultants' meetings, technical committee j
meetings and by the Agency's Waste Safety Standards Advisory Committee (WASSAC).
The two documents contain the essential safety considerations concemed with the practice of near surface disposal of radioactive wastes. They have been developed in parallel and are closely linked in the sense that the Safety Guide elaborates the basic statements made in the Safety Requirements document on the subject of safety assessment. The Safety Requirements document is a significantly revised version of an earlier draft Safety Standard sent for Member States review in 1994.
These documents are submitted together in order to provide Member States and their experts the opportunity for a simultaneous review and evaluation of the two closely related texts. The English versiors are enclosed.
These documents are planned to be presented to the WASSAC meeting in December,1997 and, if approved, subsequently, fcr final approval, to the Advisory Commission on Safety Standards (ACSS) and the Board of Govemors (Safety Requirements) or the Director General (Safety Guide).
Comments on the two documents should be received by the Secretariat by 20 September,1997.
I The responsible IAEA' officer for these reports is Mr.1. Vovk of the Division of Radiation and Waste Safety. He may be contacted for further information in connection with the subject.
The Secretariat of the Intemational Atomic Energy Agency avails itself of this opportunity to renew to the Ministries of Foreign Affairs the assurances ofits highest consideration.
Attachments 25 June 1997
( 'I Wi!Off.EDO T9(O actg I;m, I 30 pei.
EDO -- G970549 COPY COPIE COPY
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