ML20249B203
| ML20249B203 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1998 |
| From: | Kennedy J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nelson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9806220170 | |
| Download: ML20249B203 (51) | |
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June 16, 1998' MEMORANDUM TOi Robert A. Nelsori, Chief
- Low-LevelWaste and Regulatory
. Issues Section 4 ~ Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
- FROM: James Eb Kennedy, Senior Project Manager .
Low-Level Waste and Regulatory [0RIGINAL SIGNED BY:]
lasues Section Low-Level Waste and Decommissioning
. Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
REPORT OF MEETING WITH DOE NATIONAL LLW.
MANAGEMENT PROGRAM ON LICENSING AN ASSURED ISOLATION FACILITY On June 3,1998, U.S. Nuclear Regulatory Commission staff met with representatives of the DOE National Low-Low Level Waste Management Program to discuss a proposed approach for licensing an' Assured Isolation Facility. A report of this meeting is attached.
Enclosure:
As stated CONTACT: James E. Kennedy (301)4 15-6668 TICKET NO.: N/A DISTRIBUTION
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- June 16, 1998 MEMORANDUM TO: Robert A. Nelson, Chief Low-Level Waste and Regulatory issues Section Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards FROM: James E. Kennedy, Senior Project Manager Low-Level Waste and Regulatory [0RIGINAL SIGNED BY:]
lssues Section Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
REPORT OF MEETING WITH DOE NATIONAL LLW MANAGEMENT PROGRAM ON LICENSING AN ASSURED ISOLATION FACILITY On June 3,1998, U S. Nuclear Regulatory Commission staff met with representatives of the DOE National Low-Low Lev 91 Waste Management Program to discuss a proposed approach for licensing an Assured Isoietion Facility. A report of this meeting is attached.
Enclosure:
As stated CONTACT: James E. Kennedy (301)-415-6668 TICKET NO.: N/A DISTRIBUTION:
- w/o attachment 5 Central File LLDP r/f JGreeves MFederline JAustin*
MWeber JHolonich NMSS r/f DWM t/f MBell*
LBell* Nelson TCJohnson* PUBLIC THarris SSoong DGauch EO'Donnell SSalomon RNeel* JHickey DOCUMENT NAME:s:kiwm\lldp\jek\aif.wpd OFC (tidD\ LLDP [
HAME bKent A R sc h DATE d /h ]th // //
OFFICIAL RECORD COPY ACNW: YES X NO _
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MEETING REPORT Date: June 3,1998 Time: 9:00 AM - 11:30 A.M.
Place: U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Room 1-F-5 Rockville, MD
Purpose:
For U.S Department of Energy (DOE) National Low-Level Radioactive Waste Program staff and contractors to brief NRC staff on proposed Assured Isolation Facility (AIF) licensing approach Attendees: See Attachment 1.
Backaround:
Assured isolation is a new approach for LLW management that has been developed by the DOE National LLW Management Program. The concept was first described in the September 1995 issue of Radwaste Magazine, and again in the September 1996 issue, in a question and answer format. NRC has commented on assured isolation in a May 9,1996 letter from Chairman Jackson to David LeRoy, and in a January 6,1996 staff letter to DOE Headquarters staff. One of the key issues identified in NRC's letters is the approach for licensing such a facility, in particuiar whether it would be licensed as a disposal facility under 10 CFR Part 61, a storage facility under 10 CFR Parts 30,40 and/or 70, or under a new section of the regulations.
In a May 6,1998 letter to NRC staff, Idaho National Engineering and Environmental Laboratory (INEEL), on behalf of the DOE National LLW Management Program, requested a meeting with NRC staff to present the report, " Licensing an Assured Isolation Facility for Low-Level Radioactive Waste." This report provides detailed guidance for an AIF license applicaSon, based on a strategy of licensing such a facility for a storage under existing NRC regulations in 10 CFR Parts 30,40, and 70.
Discussion:
William Newberry of INEEULockheed Martin provided additional background information on the report that was discussed in the meeting. Several States have an interest in the AIF concept and the ability to license such a facility has been one of the key issues for States. To address this issue, the National LLW Management Program contracted with Morgan, Lewis and Bocklus, a law firm, assisted by Rogers and Ar.sociates Engineering, to prepare a report that identifies a licensing approach for such a facility and detailed guidance for a license applicant to prepare the application and for NRC staff to review the application. The report is " functionally similar" to a standard format and content guide and standard review plan that NRC staff Enclosure
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riormally prepares for specific kinds of license app!ications (such as a low-level waste disposal facility). The standard format and content guide identifies the information that needs to be in
. the application, and the standard review plan tells the staff how to conduct the review.
- Don Silverman of Morgan, Lewis and Bockius, and Robert Baird of Rogers and Associates described in detail the content of the report. Attachment 2 is the package of viewgraphs .
presented at the meeting. The suggested approach is to license the AIF as a materials facility under Parts 30,40, and 70, using criteria drawn from Part 30,40, and 70 guidance. Draft Regulatory Guide 3.52 and draft NUREG-1520 for Part 70 licensing were used as primary sources. NRC's disposal regulations in 10 CFR Part 61 and its associated guidance (NUREGs-
- 1199 and 1200) were also selectively applied. For example, the site suitability requirements in r 10 CFR Part 61 were not adopted in the report, since the AIF is to receive a storage license, but waste classification requirements were adopted. The report does not specify a license term
- for the application, but the presenters stated that it could be 10 to 30 years or longer and would be proposed for NRC consideration by the applicant.
The report states that groundwater contamination is viewed as non-credible in normal operation. However, in response to NRC staff questions, the presenters stated that this assumption would be reexamined in light of potential accidents at the facility. The report also states that funds would be set aside for decommissioning the facility and disposing of its waste in a permanent disposal facility. -In response to staff questions about whether the AIF would be converted into a permanent disposal facility, the presenters stated that such a possibility was a business decision to be made by the developer of the facility and would involve a risk that conversion to disposal would not be possible, since the initial licensing would be for storage only. There is no discussion of conversion to a disposal facility in the report. The report authors believe that the facility's adequacy for disposal becomes a regulatory issue only if the licensee decides to convert the facility for permanent isolation of the waste.
The report summarized at this meeting is expected to be completed in about a month and a copy will be provided to NRC staff. If a State were to request assistance from the Commission regarding the feasibility of assured isolation in that State, NRC would evaluate the request in accordance with its regulatory responsibilities. NRC staff noted that NRC was not planning on reviewing and comment on the report absent such a request.
Achons; s There were no actions identified during the meeting.
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, , MEETING ATTENDEES - /// d - M 0
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Attachment 2-Handouts on Licensing an Assured Isolation Facility-hardcopy only.
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4 l BRIEFING OF NRC STAFF ON DRAFT AIF LICENSING STUDY Lockheed Martin Idaho Technologies, Inc.
l Morgan, Lewis & Bockius, LLP Rogers and Associates Engineering Corporation June 3,1998 A H a w ~ 4 z.,
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l AGENDA e introduction a Purpose, Structure and Organization of the Report a Discussion of Basic Licensing Approach a Discussion of Key Licensing issues a Volume 2 " Walk-Through" a Wrap-Up/Next Steps
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- PURPOSE, STRUCTURE AND ORGANIZATION e Report Provides Detailed Guidance for AIF License Application a Volume 1 - Licensing Strategy and issues
- Section 1 - Introduction
- Section 11 - Principal AIF Attributes
- Section 111 - Licensing Approach Overview
- Section IV - Key Regulatory Issues
- Section V - Methodology i
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. r-PURPOSE, STRUCTURE AND ORGANIZATION a Volume 2 - Recommendations on Content and Review of Application
- Appropriate and Necessary Criteria .
- License Application Table of Contents
- Application Content Guidance
- Agency Review Guidance
- Bases for Selection
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BASIC LICENSING APPROACH e Criteria Designed to Fulfill the Facility's Objective: Safe Isolation of LLW Over the License Term m Additional Criteria Related to Business / Investment Considerations Not included a Activities to be Licensed involve Receipt, Packaging and Long-Term Monitored Isolation I
e Criteria Must Provide Reasonable Assurance That Activities Can Be Conducted Without Undue Risk-m AIF is a Materials License Facility Under Parts 30,40, and 70 l e Licensing Criteria Drawn From Part 30,40, and 70 Guidance i
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BASIC LICENSING APPROACH a AIF is Not Being Licensed for Disposal u However, Part 61 Licensing Criteria are a Useful Source of Guidance for implementing Parts 30,40, and 70 m Part 61 Criteria Selectively Applied a Excluded Requirements for Closure, institutional Control, Termination of Active Monitoring and Maintenance a Excluded Detailed Site Characterization and Suitability Criteria L.......... . i.. . . . . . . . . . . . . . . . _ . ,
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- KEY LICENSING ISSUES a Part 61. Performance Objectives a Part 61 Technical Requirements a Dose Pathways a Financial Assurance for Decommissioning a Term of the License a Physical Protection and Criticality Safety a NEPA a Emergency Planning J
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PART 61 PERFORMANCE OBJECTIVES a Protection of General Population (25/75/25 mrem) - Not Applicable a Protection of Individuals from inadvertent Intrusion - Not Applicable a Protection of Individuals During Operations - Partially Applicable ,
a Post-Closure Site Stability - Not Applicable l
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PART 61 TECHNICAL REQUIREMENTS m Disposal Site Suitability a Disposal Site Design a Disposal Facility Operation and Closure 1
m Environmental Monitoring u Alternative Requirements a Waste Classification i a Waste Characteristics a Labeling u Altemative Classification and Characteristic Requirements a Institutional Requirements i
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DOSE PATHWAYS a Direct Gamma, Atmospheric Transport Considered a Surface Water Under Accident / Abnormal Conditions Considered a Release to Groundwater Viewed as Non-Credible l
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FINANCIAL ASSURANCE FOR DECOMMISSIONING
- Standard Materials Licensing Guidance Utilized a Alleviates "De Facto" Disposal Concern i b
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i LICENSE TERM a No Particular Term Prescribed by Law or Regulation a Lengthy Term Seems Justifiable l
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l PHYSICAL PROTECTION AND CRITICALITY SAFETY a Expect Only Low Strategic Significance Materials a Expect < Critical Quantities of SNM 4
NEPA a Guidance includes Basic Content of an ER
- Description of Proposed Action
- Purpose of Proposed Action
- Affected Environment
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- Discussion of Considerations
- Analysis of Proposed Action / Alternatives
- Federal / State Environmental Requirements hmi _ _ . _ . _ _ . _ _
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i EMERGENCY PLANNING l m Guidelines Drawn from 10 CFR $30.31(i) e Part 61 Guidance Departs from Standard Materials Licensing Practice
- Emergency Plan Required Regardless of Projected Dose
- Includes Lower Doses Than Parts 30,40, and 70
- - Suggests Need for Offsite Plans and FEMA Review a
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VOLUME 2 " WALK-THROUGH" a Summaries of Each Chapter Provided including
- Content Guidance-
- Review Guidance
- Bases
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CHAPTER 1 - GENERAL AND INSTITUTIONAL INFORMATION a Provides General Introductory Information on Applicant, Facility, Site, Possession Limits, Conformance to Reg. Guides a Drawn From NUREGs - 1199 and 1200 m Deleted Disposal Unit Design, Covers, Surface Water Control, Intruder Barriers, Governmental Land Ownership, Closure and Post-Closure 4 m Draft Reg. Guide 3.52 Used to Add Criteria for identifying Type, Form and Quantity of Licensed material J i
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l CHAPTER 2 - SITE DESCRIPTION m- Requires Gene.al, and Relatively Brief, Information on Geography, Demography and Land Use, Meteorology, Hydrology, Geology.and Seismicity a Reconnaissance Level Information Required, Not Detailed Site Characterization a Drawn from Draft Reg. Guide 3.52 and Draft NUREG-1520 Because Applicant is Not Demonstrating Compliance With Part 61 Disposal Site Suitability Requirements e information Comparable to a Fuel Cycle Facility Application
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CHAPTER 3.1 - ORGANIZATIONAL STRUCTURE a Provides Information on Applicant's Organizational Structure, General Qualification and Training Requirements, and Background and Experience Requirements for Designated Positions a Drawn From NUREGs - 1199 and 1200 With Limited Deletions Specific to Near-Surface Disposal Facilities Such as Application and Staffing for
" Closure and Post-Closure Activities" l
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A CHAPTER 3.2 - QUALIFICATIONS OF APPLICANT a Provides Inforrnatio') on Functions, Responsibilities, Authorities, and Qualifications of Key Positions a NUREG-1199 Was Used in its Entirety. NUREG-1200 Was Edited to 4 p Focus on Key Criteria and to Remove Redundant Information.
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CHAPTER 3.3 - TRAINING PROGRAM e Describes the Applicant's Training and Retraining Programs including Courses, Instructor Qualifications, Schedules, etc.
m NUREG-1199 Was Used in its Entirety. NUREG-1200 Was Edited to 4 Focus on Key Criteria and to Remove Redundant Information. ,
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CHAPTER 3.4 - EMERGENCY PLANNING m Requires the Applicant to Provide an Evaluation Showing that the Maximum Offsite Dose Would Not Exceed 1 rem EDE or 5 rems (Thyroid), or Provide an Emergency Plan a Drawn From 10 CFR s 30.32(i) e Part 61 Guidance Exceeds Requirements for Other Materials Licensees and Appears to Exceed Part 61
- NUREG-1200 Mandates an Emergency Plan Regardless of Dose Assessment; and an "Offsite" Plan, and Contains More Restrictive Dose Criteria
- AIF Report Volume 1,Section IV.H Provides Additional Basis Information I
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.o CHAPTER 3.5 - REVIEW AND AUDIT a Describes the Applicant's Review and Audit Program including Reviews of Facility Changes and Unplanned Events, and independent Safety
. Reviews -t s '. NUREG-1199 Was Used in its Entirety. NUREG-1200 Was Edited to-Focus on Key Criteria and to Remove Redundant Information.
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4 CHAPTER 3.6 - FACILITY ADMINISTRATIVE AND OPERATING PROCEDURES e Provides General Descriptions of Administrative and Operating Procedures a NUREG-1199 Was Used in its Entirety. NUREG-1200 Was Edited to Focus on Key Criteria and to Remove Redundant Information.
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CHAPTER 3.7 - PHYSICAL SECURITY a Describes Applicant's Plans for Facility Security m NUREG-1199 Was Used in its Entirety. NUREG-1200 Was Edited to Remove- References to implementation 1-2 Months "Before Fuel Loading" and to Replace With 1-2 Months Before " Receipt of Waste". -
4 CHAPTER 4.1 - PRINCIPAL DESIGN FEATURES a Provides a Consolidated, General Description of Principal Design Features to Address Seven Facility Functional Requirements Such as Protection Against Water infiltration, Isolation Unit Integrity and Occupational Exposures a Drawn From NUREGs - 1199 and 1200 Except That Four of Eleven
" Functional Requirements Were Deleted
- Facilitating Site Closure and Stabilization
- Minimizing Need for Long Term Maintenance
- Providing a Barrier Against Inadvertent intrusion
- Providing an Adequate Buffer Zone for Monitoring and Mitigative Action l
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CHAPTER 4.2 - STRUCTURAL DESIGN FOR ASSURED ISOLATION UNITS a Describes the Structural Design Criteria for the Assured Isolation Units including Information on Loads, Codes and Standards, and Design Criteria a Drawn From NUREG-1199 and NUREG-1200 Structural Design Criteria for Below Ground Units and Earth-Mounded Concrete Bunkers (Section 3.2A)
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-l CHAPTER 4.3 - DESIGN CONSIDERATIONS FOR NORMAL AND ABNORMAIJACCIDENT CONDITIONS a Discusses Design Criteria to Assure Safe Isolation and Allow Active Monitoring and Surveillance a Criteria Address the Seven Functions Discussed Under Chapter 4.1 m NUREGs - 1199 and 1200 Were Used With Modifications to Conform i Terminology to the AIF Concept Such as Changing " Disposal" Units to
" Assured Isolation" Units and Deleting References to Closure, Inadvertent intruders, etc.
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d CHAPTER 4.4 - DESIGN OF AUXILIARY SYSTEMS AND FACILITIES a Requires information on Various Auxiliary Systems including Utility, Fire Protection, and Erosion and Flood Control Systems.
m NUREGs - 1199 and 1200 Were Used With Modifications to Conform Terminology to the AIF Concept Such as Changing " Disposal" to l
" Isolation" and Deleting References to Closure and Stabilization.
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CHAPTER 5.1 - RECEIPT AND INSPECTION OF WASTE
. Describes Procedures for Waste Receipt and Inspection including Examination on Receipt, Surveys and Testing
. NUREGs - 1199 and 1200 Were Used. Waste Manifesting, i
Characteristic, Classification and Labeling Criteria Were included for Reasons Described in AIF Report, Volume 1, Sections IV. B.6-8.
CHAPTER 5.2 - WASTE HANDLING AND ISOLA flON e Requires Information on Procedures for Handling of Waste After Receipt including Measures to Protect Workers, Handling Operations and Equipment a Drawn From NUREGs - 1199 and 1200 1
3 m Refereiices to Waste " Segregation" Have Been Deleted.
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CHAPTER 5.3 OPERATIONAL ENVIRONMENTAL MONITORING AND SURVEILLANCE a Provides Information on Environmental Monitoring and Surveillance l Plans During Operations to Demonstrate Compliance With Part 20 s Drawn From NUREGs - 1199 and 1200 Except That Requirements Related to Long-Term Post-Closure Performance and Specific Ref-erences to ANSI and Other Standards Were Deleted a Reader Referred to NUREG-1200 for References to ANSI and Other Standards c...
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CHAPTER 6.1 - DETERMINATION OF TYPES,
! KINDS AND QUANTITIES OF WASTE e Provides Information on Waste Quantities, and Physical, Chemical and Radiological Characteristics Sufficient to Permit Modeling of impacts and to Assess Adequacy of Decommissioning Funding a Drawn From NUREGs - 1199 and 1200 and Covers Waste Received ~
During Operations. Wastes Generaiad During " Closure" Activities and !!
Closure and Post-Closure Doses Are Exduded as Not Relevant to an AIF.
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CHAPTER 6.2 - COVER SYSTEM INFILTRATION m Cover System Not Likely a Prerequisite for Licensing, Panicularly in Warmer Climates a Discusses Hydrologic Infiltration Estimates and Measures for Use in Assessing Adequacy of Site Covers a Drawn From NUREGs - 1199 and 1200 Except for Minor Edits to Remove References to " Disposal" and " Closure" a Emphasis is on Infiltration into the Engineered Cover System, Not into the isolation Vaults Themselves 34 -
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CHAPTER 6.3 - RADIOLOGICAL RELEASE - NORMAL CONDITIONS a Provides an Assessment of Anticipated Releases During Normal Operations via Direct Gamma and Atmospheric Transport Pathways a Provides an Assessment of Anticipated Releases Under Accident / Abnormal Conditions via Surface Water Pathway a Drawn From NUREGs - 1199 and 1200 m References to Closure and Post Closure Releases Were Deleted 1 m References to Groundwater and Biotic Pathways Were Deleted Based on Anticipated AIF Design and Operational Characteristics.
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4 CHAPTER 6.4 - RADIOLOGICAL RELEASE - ACCIDENTS OR UNUSUAL OPERATIONAL CONDITIONS a Provides information on Potential Releases Under Various Accident or Abnormal Operating Scenarios a Drawn From NUREGs - 1194 and 1200 With Minor Edits to Delete .
References to " Disposal" Facilities
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CHAPTER 6.5'- TRANSFER OF RADIOACTIVITY I TO HUMAN ACCESS LOCATION m Provides Assessment of Most Significant-Transport Mechanisms, Focusing on Direct Gamma Radiation and Atmospheric Transport Pathways a Provides an Assessment of Surface Water Pathway Under Accident / Abnormal Conditions ;
e Deleted References to Closure and Post-Closure Periods of Concern 3
and to " Disposal" m Drawn From NUREGs - 1199 and 1200 m References to Groundwater Pathway Removed Under Same Rationale as Chapter 6.3
CHAPTER 6.6 - ASSESSMENT OF IMPACTS AND REGULATORY COMPLIANCE e Provides an Assessment of RadiologicalImpacts From Normal, Accident and Unusual Operational Conditions to Show Compliance With Regulatory Limits a Drawn From NUREGs - 1199 and 1200 Except That References to (
Impacts During Closure and Post-Closure Periods Were Deleted i
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CHAPTER 7 - RADIATION SAFETY a Describes the Basic Elements of the Proposed Radiation Safety Program
!ncluding ALARA, RWPs, Training, Contamination Control, etc.
m Drawn From Draft Reg. Guide 3.52 and Draft NUREG-1520 as Most '
Current and Comprehensive NRC Sources s References to " Integrated Safety Analysis" Deleted as Unnecessary for I
an AIF
- a. References to Byproduct Material and Source Material Added l
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CHAPTER 8 - QUALITY ASSURANCE 2 Describes the Basic Elements of the QA Program a Drawn From Draft Reg. Guide 3.52 and NUREG-1520 m References to ISA and to Other. Items Particular to Part 70 Were Deleted. Information in NUREG-1520 was Streamlined to Focus on Acceptance Criteria.
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,.o CHAPTER 9.1 - DECOMMISSIONING FUNDING PLAN a Addresses the Applicant's Plans for Providing Adequate Funds for Decommissioning including a Cost-Estimate and Description of Methods to Assure Adequate Funds a Drawn From Draft Reg. Guide 3.52, Draft NUREG-1520 and Reg. Guide ;
3.66 m Part 61 Funding Guidelines We:e Not Utilized. )
m References to the Draft Reg. Guide 3.52 " Conceptual Decommissioning Plan" Were Deleted as Beyond the Scope of Regulatory Requirements CHAPTER 9.2 - FINANCIAL ASSURANCE MECHANISMS i
a Provides Guidance on the Text of the Financial Assurance Mechanisms Available for Decommissioning f
a Drawn From Draft Reg. Guide 3.52 and Draft NUREG-1520 With Only -
Minor Changes to Eliminate Redundant Information 4
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CHAPTER 10 - ENVIRONMENTAL REPORT a Provides Guidance on Preparation of the Environmental Report Under NEPA e Drawn From Draft Reg. Guide 3.52 and Draft NUREG-1520 m Scope of Above Documents Was Deemed More Appropriate Than Part 4 61 Guidance Which is Heavily influenced by Final, Terminal Disposal (
Considerations J
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