ML21257A468

Request for Additional Information Related to Westinghouse Electric Company, LLC, Exemption Request for Alternate Disposal of Specific Waste (Enterprise Project Identifier L 2021-Lla-0101)

ML21257A468
Person / Time
Site:	Westinghouse
Issue date:	09/13/2021
From:	David Tiktinsky NRC/NMSS/DFM/FFLB
To:	Malek E Westinghouse Columbia Fuel Fabrication
D Tiktinsky NMSS/DFM/FFLB 301-415-8740
References
Download: ML21257A468 (2)

Text

From: Tiktinsky, David To: Malek, Elise Cc: Schwartzman, Adam; Tobin, Jennifer; Zimmerman, Jacob; McKenney, Chris; Donnelly, Patrick

Subject:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO WESTINGHOUSE ELECTRIC COMPANY, LLC, EXEMPTION REQUEST FOR ALTERNATE DISPOSAL OF SPECIFIC WASTE (ENTERPRISE PROJECT IDENTIFIER L 2021-LLA-0101)

Date: Monday, September 13, 2021 1:52:00 PM Ms. Elise Malek Licensing Manager Westinghouse Columbia Fuel Fabrication 5801 Bluff Road Hopkins, South Carolina 29061-9121

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO WESTINGHOUSE ELECTRIC COMPANY, LLC, EXEMPTION REQUEST FOR ALTERNATE DISPOSAL OF SPECIFIC WASTE (ENTERPRISE PROJECT IDENTIFIER L2021-LLA-0101)

Dear Ms. Malek:

On June 1, 2021, Westinghouse Electric Company, LLC (WEC) submitted an alternate disposal request (ADR) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21153A001) per Title 10 of the Code of Federal Regulations (10 CFR) Section 20.2002, Method for obtaining approval of proposed disposal procedures, for the disposal radioactive materials containing byproduct material and special nuclear material (SNM) from the Columbia Fuel Fabrication Facility (CFFF).

The request seeks approval for the shipping and disposal of multiple individual shipments of volumetricallycontaminated and surface-contaminated wastes over a 5-year period (2021 - 2025). WEC proposed to use bounding dose calculations with corresponding volume limits based upon the annual U. S. Ecology Inc. (USEI) worker exposure limits as the basis for determining whether individual shipments are acceptable for disposal.

The 10 CFR 20.2002(a) requires that an ADR application include [a] description of the waste containing licensed material to be disposed of, including the physical and chemical properties important to risk evaluation.

Request for Additional Information Consistent with Westinghouses past ADR applications, characteristic waste information, such as the wastes radiological content, mass, location, volume, and homogeneity facilitates the NRC staffs review. Please provide specific information regarding the waste intended for disposal at USEI to meet the specific requirements outlined in 10 CFR 20.2002(a),

(a) A description of the waste containing licensed material to be disposed of, including the physical and chemical properties important to risk evaluation, and the proposed manner and conditions of waste disposal.

Discussion Sections 4.1, Volumetrically Contaminated Waste, and 4.3, Surface Contaminated Waste, of WECs submittal include the statement includes, but is not limited to in describing the various waste forms that would be shipped to USEI under this request. The use of this phrase provides for the inclusion of materials not described in the ADR. In addition, the application refers to different sources or types of waste and licensed material for disposal, but not the specific waste and material to be disposed. Including additional, unspecified materials or only classes of materials does not satisfy 10 CFR 20.2002(a). To satisfy the requirements in 20.2002(a), specific information related to the waste proposed for disposal, including the volumes of material and other specific characteristics that could impact risks associated with the proposed disposal action should

be included.

Basis The regulations provided in 10 CFR 20.2002 were established to provide licensees with a process by which they can propose alternate disposal options for use in place of specific disposal regulations established in the regulations (e.g., 10 CFR 20.2001, General requirements, and 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste). Use of alternate disposal procedures may reduce overall risk (e.g., risk associated with increased transportation distances and associated radiological and no-radiological impacts) and may preserve disposal capacity at low level waste disposal facilities for higher risk waste streams, while also providing reasonable assurance of adequate protection of public health and safety and protection of the environment. To ensure that these criteria can be met, the licensee is required to submit for review and approval sufficient detailed information that satisfies the requirements in 10 CFR 20.2002.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this email will be available electronically for public inspection in the NRC Public Document Room, or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions regarding this communication, please contact me at 301-415-8740 or by email at David.Tiktinsky@nrc.gov.

Sincerely, David Tiktinsky, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 7001151 License No. SNM-1107 cc: westinghouse@listmgr.nrc.gov

• via email DFM/FFLB/PM* DFM/FFLB/LA* DUWP/RTAB* DUWP/RTAB DFM/FFLB/BC OFFICE NAME DTiktinsky ELee ASchwartzman CRidge/for MBartlett/for CMcKenney JZimmerman DATE 9/10 /21 9/13/21 9/13/21 9/13/21 9/10/21 OFFICIAL RECORD COPY