ML20236S335
| ML20236S335 | |
| Person / Time | |
|---|---|
| Site: | 070*****, 07003084, 07003095, 07003034 |
| Issue date: | 06/12/1998 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Sinclair W UTAH, STATE OF |
| References | |
| NUDOCS 9807240270 | |
| Download: ML20236S335 (9) | |
Text
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[l UNITED STATES NUCLEAR REGULATORi COMMISSION i
WASHINGTON, D.C. "' 8"*1 June 12, 1998 William J. Sinclair, Director rg qq Division of Radiation Control Department of Environmental Quality 30t[
State of Utah P.O. Box 144850 Salt Lake City, Utah 84114
SUBJECT:
REVIEW OF ENVIROCARE OF UTAH, INC., DRAFT LICENSE
Dear Mr. Sinclair:
The U.S. Nuclear Regulatory Commission (NRC) staff has received the draft license dated April 13,1998, associated with renewal of the waste disposal license for Envirocare of Utah, Inc.
(UT2300249). The draft license was issued by the Utah Department of Environmental Quality for public comment untilJune 15,1998. We note that the draft license would increase the allowable concentrations of special nuclear material (SNM) in waste possessed at the Envirocare facility.
As you know, the NRC staff has been studying criticality safety issues related to disposal of SNM.
Under NRC contract, the Oak Ridge National Laboratory conducted a study, "The Potential for Criticality Following Disposal of Uranium at Low-Level Waste Facilities, NUREG-6505, Vol.1,"
which has already been provided to your office. This report addresses certain aspects of criticality safety associated with disposal of waste containing relatively low concentrations of SNM.
In addition,-'until recently, two operating low-level waste facilities were licensed by the NRC for possession of greater than critical mass que-tities of SNM. At both of these facilities, NRC specified license condilicas addressing criticality safety for operations, waste ernplacemant, and J
disposal. Last year, the NRC was requesteo by the respective licensees to reduce the SNM i
possession limits and transfer the licenses to the Agreement States (South Carolina and
)
l Washington). This transfer has been completed, and the State of Washington incorporated NRC's j
criticality. safety license conditions into its license for the Hanford facility. The State of South
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Carolina did not incorporate the criticality safety license conditions into the State license itself, but
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the operating procedures governing emplacement criticality are stillin effect. Enclosed are copies of excerpts for the State of Washington license and South Carolina facility operating procedure for your information.
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W. Sincl:ir 2
The NRC staff continues to evaluate the issue of criticality safety with respect to disposal of SNM, including disposal of materials containing relativelylow concentrationsof SNM. We are developing guidance relative to emplacement of SNM at low-levelwaste facilities. We plan to consult with you and other Agreement States in preparing this guidance, in the interim, uniti the evaluation is completed and guidance is available, we recommend that you consider whether it is appropriate to authorizeincreasesin the SNM quantities and concentrationsin materials received and disposed of at the facility, if you have any questions or commerts, please contact Tim Harris of my staff at (301) 415-6613.
Sincerely,
[ original signed by]
John W. N. Hickey, Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated TICKET NO.: N/A DISTRIBUTION:
Central File LLDP r/f NMSSr/f LHowell,RIV JGreeves JKennedy JHolonich MWeber PUBLIC DOCUMENT NAME : s : \\ dwm\\ l l dp\\ teh\\ si ncl ai r. s nm
- See previous concurrence SS[1 OFC LLDP
- LM//
LtJ)R 0 40 h^~l
/f NAME THarris blson Jh$ key BRegNh, kohk.
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DATE 6/12/98 6//J/98 6//)/98 6/12/98 6/12/98 6/5/98 1
0FFICIAL RECORD COPY ACNW: YES X
NO IG : YES NO X
Delete file after distribution:
Yes X No f
LSS : YES NO X
l l
---_________________.)
W. Sinclair 2
T'he NRC staff continues to evaluate the issue of criticality safety with respect to disposal of SNM, includingdisposalof materialscontainingrelativelyIcw concentrationsof SNM. We are developing guidance relative to emplacement of SNM at low-levelwaste facilities. We plan to consult with you i
and other Agreement States in preparing this guidance. In the interim, until the evaluation is i
completed and guidance is available, we recommend that you consider whether it is appropriate to authorize increases in the SNM quantities and concentrationsin materials received and disposed of at the facility.
I If you have any questions or commerts, please contact Tim Harris of my staff at (301) 415-6613.
Sincerely, i
John W. N. Hickey, Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated l -
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3 State of Washingten
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Radioactive Materials Licenso 6
33 Fa5e d
Pag" WN-IO19-2 Uomse Number Amendment No. 24 described in approved vendor topical reports. Only those stabilization media approved by the department and listed in Appendix D to this license, or High Integrity Containers approved by the department and listed in Appendix E to this license may be used. Stability may also be achieved using engineered barriers in the disposal unit. ~ Specific approval by the department is required prior to construction of any newly designed or redesigned engineered barrier. Only those engineered barriers listed in Appendix F of this license are approved for use at the facility.
26.
The classification and package identification marking required by Condition 25 is in l
addition to any marking cr labeling required by-U.S. NRC or U.S. DOT, and shall consist of lettering 1/2 inch high or greater in a durable contrasting color to the i ible on the
- .~s-. background surrounding the lettering. The classification marking shall be v s same side as the radioactive marking or label and in close proximity (within six inches).
Waste packages marked " Radioactive," " Limited Quantity," or " Radioactive LSA" need only one classification marking, whereas waste packages labeled, White I, Yello.w II, or J
Yellow III shall have classification markings in close proximity '(within six inches) to each label. Waste materials shipped in casks shall have the classification markings visible on the outside of the cask.
27.
The licensee may possess SNM that has not been disposed of at the facility, subject to the following restrictions and all oth'er conditions of this licensc.:
'A.
No single package shall contain more than 100 grams of U-235, or 60 grams of U-233, or 60 grams of Pu, or any combination thereof, such that the sum of the ratios of the quantity of each SNM radionuclides to the quantities specified herein j
exceeds unity. Compliance with this requirement shall be determined by the following formula:
..enmn containine U-235 + rrams containine U-233 + gIagg containine Pu = <1 l
100-60 60 No single package shall contain more than 15 grams of any combination of U-B.
To the extent 235, U-233,. and Pu, per cubic foot of the total volume.
practicable, the SNM will essentially be uniformly distributed throughout the waste package.
SPECIEIQ WASTE FORM REQUIREMENTS Except as allowed under this license, untreated liquids and wet sludges are not allowe 28.
for disposal. Liquids shall be rendered non-corrosive (4 s pH s 11) prior to treatment.
004 3M4134(nom 134
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Rcdioactivo Matorials Liconso 1
13 33 "'"
WN-1019-2
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Amendment No. 24
~52..
Aa amnhdans of waste packages containing SNM in quantities g=-ihd in this license shall be disposed so that there is a minimum of eight inches of soil or a minimum of four feet of non SNM-bearing waste in all directions from any other accumulation of packages contaimng SNM in quantities specified in this license. For purposes of this license condition, accumulation means not more than 350 grams of U-235,200 grams of U-233, or 200 grams of plutonium, or any combination thereof, such that the sum of the ratios of each SNM radionuclides does not exceed unity.
SITE DESIGN AND CONSTRUCTION C'ONDITIONS
- 53., All burial trenches or disposal units shall be in a controlled area surrounded by a chain link fence, eight feet high, and topped with barbed wire.
~. 54.'
Thirty days prior to commencement of construction of any new disposal unit, the licensee
. shall submit to the department a dernited engineering plan for the trench in accordance with the provisions of the Facility Standards Manual, or a statement that the proposed trench will be Mgned and constructed in accordance with Condition 55 of this license.
55.
The licensee shall construct new disposal units in accordance with the March 6,1991 department-approved Comprehensive Facility Utilization Plan, Document 200-DOC-001, Rev. 3.
Changes to the plan must be. submitted to the department for' review and approval. Additionally, the licensee shall:
A.
Upon completion of the construction of any new trench, submit,to the department 9
two copies'of the trench construction report.' The report shall include, at a minimum, as-built drawings, daily and fmal inspection reports, laboratory and.
field soil test results, and a description of any problems encountered during construction, in order to demonstrate that the construction of the disposal unit is
' in comp"== with applicable plans and specifications contained in the approved Facility Utili=tian Plan.
B.-
30 ' days prior.to use of any new trench, notify the department in writing of the intent to physically place waste in the trench.
l 56.
The kanmaa shall conduct closure and stabilization operations in accordance with the March 6,1991 department-approved Comprehensive Facility Unli= dan Plan and the Facility Closure and Stabilinhan Plan required by Condition 67 as each trench is filled and covered.
. 57.
In addition to the requirements of Condition 56, the licensee shall design and construct interim disposal unit caps in accordance with the specifications contained in the Facility l
== = = = > men i
13.9 Pyrophoric Materials or Flammable Solids 13.9.1 Pyrophoric or flammable solid material contained in waste shall be made inert to prevent self ignition during transport and disposal.
13.9.2 The inerting process shall be approved by the Barnwell Licensing l
l Department priorto shipping.
13.g.3 No material that might react violently with water or moisture shall be accepted for disposal at the Bamwell Site.
t 13.10 Special Nuclear Material (SNM)
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NOTE:
SPECIAL NUCLEAR MATERIAL (SNM) MEANS PLUTONIUM (Pu), U 233, OR URANIUM ENRICHED IN 0-233 OR U-235.
13.10.1 All SNM waste shall be packaged and reported in accordance with-Reference 2.1,2.3, and Section 3.7 of this procedure.
13.10.2 Waste containing plutonium must meet the requirements of Condition 40 of Reference 2.1. Waste not meeting these i
requirements will require specific approval by S.C. DHEC.
13.10.3 The surface area on any side or projected plane of a package containing U-233, U-235, Pu shall be 2 ft' or greater. Only 55-gallon drums and larger packages are acomptable without prior approval from Barnwell Licensing Department.
13.10.4 Shippers having individual Mvs in excess of 100 grams of U-235 shall have on file with the Bamwell Licensing Department a statement indicating the percent confidence in their shipping values.
13.10.5 The Barnwell Licensing Department shall be notified prior tu shipment of SNM packages exceeding 100 grams of U-235 in L
which the confidence in shipping value is less than 95 percent.
13.10.6 No single packagelshipment shall contain more than 200 grams of U-233,350 grams of U-235, or 200 grams of Pu. ' For packages l.
containing a combination of U-233, U-235 or Pu, the sum of the ration of the individual quantity of each SNM radionuclides to the l
quantity speerfied above for that radionuclides shall not exceed i
unity.
i ENCLOSURE 2 i
S20-AD 010 REV.1'8 PAGE 27 t
^
3.3. Transport vehicles and containers shall be handled and off-loaded in
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accordance with References 2.3 and 2.6.
3.4 Receipt, storage, and burial of SNM shall be performed in accordance with this procedure and References 2.1,2.2,2.3,2.4,2.6 and 2.7.
3.5 A package shall be considered :n SNM package if it contains a discrete SNM source or it is contains SNM and is part of a shipment accompanied by a NRC 741 form.
'4.0 SPECIFIC PROCEDURES 4.1 All SNM shipments must comply with Reference 2.1,2.5 and 2.6.
4.2 Minimum projected surface area of package containing U-235 mu.t be at least 2.0 square feet.
4.3 Waste, packages meeting the criteria in Step 4.1 and 4.2 shall only be disposed of in concrete vaults emplaced in the bottom level of the disposal trench in accordance with the following table. The SNM waste package stacking limits are based on U-235 less than or equal to 10 percent by weight and an areal limit of 200 g/ft" in accordance with Reference 2.1.
SNM Waste Package Stacking Limits Within Bottom Level Vaults
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SNM Package Surface Ares U-235 mass U-235 mass U-235 mass (ft')
limit (g) limit (g) limit (g) 1 Layer 2 Layer 3 Layer
.3.01 350 300 200 55 gal drum 83 gal drum 5.41 350 350 N/A I
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I SEG box 12.0g 350 350 N/A B-25 box 24.00 350 350 N/A 4.3.1 Weste packages containing SNM that do not meet the criteria in the table above shall be reviewed by the Compliance Supervisor and/or Licensing Manager and disposed of in accordance with References 2.1 and 2.2.
- 4.4 Non-SNM waste may be placed directly on top of SNM waste within the
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same vault or in other vault levels of that column of vaults, a20-OP-03o REV.5 PAGE 4
e C_.-----______________--
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-<.r-m 4.5-The Compliance Technician at the trench shall document the vault number of buried SNM waste on the Radioactive Shipment Manifest (RSM) in accordance with Reference 2.3.
4.6 The Compilance Technician responsible for processing outgoing paperwork shall complete the SNM log in accordance with Reference 2.3.
5.0 RECORDS 5.1 All records of receipt and disposal of SNM shall be maintained in accordance with Reference 2.9.
5.2 Reports of receipt and disposal of SNM shall be submitted to the NRC in accordance with Reference 2.1.
S2o-OP-o3o REV.5 PAGE 5
W. Sincl ir 2
The NRC staff continues to evaluate the issue of criticality safety with respect to dispo al of SNM, including disposalof materials containing relativelylow concentrations of SNM. We a dev oping guidance relative to emplacementof SNM at low-levelwaste facilities. We plan to nsult ith you and other Agreement States in preparing this guidance. In the interim, uniti e ev uation is completed and guidance is available, we recommend that you consider whet it is propriate to authorize increases in the SNM quantities and concentrationsin materials received d disposed of at the facility.
/
If you have any questions or commerts, please contact Tim Harris of m staff (301) 415-6613.
i Sincerely, (original signed by]
John W. N. Hickey Chief Low-LevelWastepnd De commissioning Projects Brancp Division of Waste Ma gement Office of Nucidar M erial Safety and Safegu'ards
Enclosures:
As stated TICKET NO.: N/A DISTRIBUTION:
Central File LLDP r/f NMSSr/f owell,RIV JGreeves JKennedy JHolonich MWeber PUBLI DOCUMENT NAME : s : \\ dwm\\ 1 l dp\\ teh\\ s i ncla i r.
m i
0FC LLDP LLDP LLDP/
/
OSP OGC NAME THarrk RNelson Iicke[
PLohaus BReamer
[6/[98 DATE 6/I498 6/ /98 6/ /98 6/ /98 6/ /98
/
OF ICIAL RECORD COPY ACNW: YES X
NO IG : YES N0 X
De 4te f' e after distribution:
Yes X No LSS : YES NO X
l l
/
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