ML20287A546

Westinghouse - Response to Request for Additional Information Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Facility Waste

ML20287A546
Person / Time
Site:	Westinghouse
Issue date:	10/12/2020
From:	Westinghouse, Westinghouse
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML20287A544	List: ML20287A545 ML20287A546
References
LTR-RAC-20-80
Download: ML20287A546 (3)

Text

WESTINGHOUSE NON-PROPRIETARY CLASS 3 to LTR-RAC-20-80 Date: October 12, 2020 Enclosure 1 Response to Request for Additional Information Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Facility Waste 1 of 3

WESTINGHOUSE NON-PROPRIETARY CLASS 3 to LTR-RAC-20-80 Date: October 12, 2020 On May 8, 2020, Westinghouse submitted a request for alternate disposal approval and exemption for specific Columbia Fuel Fabrication waste containing byproduct and special nuclear material. Specifically, the request was for an exemption to the requirements in 10 CFR 70.3 License Requirements to allow Westinghouse to transfer the specific waste for disposal at the US Ecology Idaho, INC disposal facility.

The staff needs additional information in order to potentially grant an exemption to 10 CFR 70.3 as per the regulatory requirement in 10 CFR 70.17(a). Westinghouse should provide information that justifies:

a. The exemption is authorized by law

b. The exemption will not endanger life or property or the common defense and security

c. The exemption is otherwise in the public interest.

WESTINGHOUSE RESPONSE The NRC issued license SNM-1107 to Westinghouse Columbia Fuel Fabrication Facility (CFFF) and CFFF is required to comply with the regulations as provided in 10 CFR 70, Domestic Licensing of Special Nuclear Material. Specific exemptions to 10 CFR 70 may be granted under 10 CFR 70.17 if the applicant can demonstrate that the exemption is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest.

By Westinghouse letter (A. Spalding) to the NRC Document Control Desk, Request for Alternate Disposal Approval and Exemptions for Specific Columbia Fuel Fabrication Facility Waste, LTR-RAC-20-45 (ML20129J935), Westinghouse submitted a request for an exemption for the specific material provide therein and provided information to support the NRC Staff review. Below is a summary of how the proposed exemption request meets the requirements of 10 CFR 70.17(a).

Authorized by Law In LTR-RAC-20-45, Enclosure 1, Columbia Fuel Fabrication Facility Evaluation in Support of 10 CFR 20.2002 Request for Alternate Waste Disposal, the removal of the East Lagoon will be completed in accordance with NPDES permit #SC0001848 issued by South Carolina Department of Health and Environmental Control as well as Richland County requirements. In addition, the material will be transported in compliance with US Department of Transportation (DOT) regulations to US Ecology Idaho, Inc. (USEI). USEI is a Subtitle C Resource Conservation and Recovery Act (RCRA) hazardous waste disposal facility permitted by the State of Idaho to receive radioactive waste that is not licensed or exempted from licensing by the NRC. As such, the material will be removed per state and local regulations, will be shipped per existing federal regulations to a location approved by the state of Idaho to receive the material. The proposed exemption is not otherwise inconsistent with NRC regulations or other applicable laws.

Therefore, the request is authorized by law pending NRC approval of the exemption.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 to LTR-RAC-20-80 Date: October 12, 2020 Not endanger Life, Property, or the Common Defense and Security In LTR-RAC-20-45, Enclosure 1, Section 5.0, Radiological Assessment, describes exposure scenarios for the Maximally Exposed Individual, describes how the material will meet DOT regulations for transport and confirms that a persons annual dose will not exceed 15 mrem for 1,000 years after closure of the USEI facility.

In LTR-RAC-20-45, Enclosure 1, Section 6.0, Criticality Safety, identifies that the USEI Waste Acceptance Criteria would not be exceeded before the safety limit of 0.1 gram of U-235 per liter of media would be reached.

Finally, CFFF maintains an NRC approved Physical Security Plan (ML19295F234). As such, shipments of the waste material for disposal at USEI will be conducted in accordance with applicable regulations that provide reasonable assurance the requested exemption will not endanger life, property or the common defense and security.

In the Public Interest This exemption request supports the Westinghouse capital improvement project to close the East Lagoon in 2021. This project is part of CFFFs ongoing efforts to remediate legacy environmental concerns at the site. Closing a lagoon with an aging liner, as described in LTR-RAC-20-45, Enclosure 1, Section 3.1, East Lagoon, is protective of the environment and in the interest of public health and safety.

Summary Westinghouse has provided the aforementioned information to support, in accordance with 10 CFR 70.17(a), an NRC determination that the request for disposal of specific materials from the CFFF site at the USEI site is in accordance with applicable laws and regulations, will not endanger life or property or the common defense and security, and is in the interest of the public.

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