ML21292A117
| ML21292A117 | |
| Person / Time | |
|---|---|
| Site: | 07007032 |
| Issue date: | 10/22/2021 |
| From: | Jennifer Tobin NRC/NMSS/DFM/FFLB |
| To: | Jacob Zimmerman NRC/NMSS/DFM/FFLB |
| Jenny Tobin NMSS/DFM/FFL 301-415-2328 | |
| References | |
| Download: ML21292A117 (5) | |
Text
October 22, 2021 MEMORANDUM TO: Jacob I. Zimmerman, Chief Fuel Facilities Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM:
Jenny Tobin, Project manager Fuel Facilities Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF OCTOBER 7, 2021, PUBLIC MEETING WITH PERMAFIX NORTHWEST TO DISCUSS MATERIAL CONTROL AND ACCOUNTABILITY (MC&A) AND THE POTENTIAL FOR AN EXEMPTION AS A PART OF PRE-SUBMITTAL LICENSING DISCUSSIONS On October 7, 2021, the U.S. Nuclear Regulatory Commission staff held an Observation type public meeting with PermaFix Northwest (PFNW) to engage in pre-submittal discussions regarding an application for a limited-scope Part 70 license. This was the second in a series of pre-submittal public meetings.
The purpose of the meeting was to discuss PFNWs planned approach for addressing material control and accounting (MC&A) in their application and potential request for an exemption to some of these requirements. PFNW and their contractor Enercon presented their proposed approach to MC&A via slide presentation (Agencywide Documents Access and Management System (ADAMS) Accession Number ML21267A453). NRC staff asked questions throughout the presentation, PFNW and Enercon provided verbal responses and will use the pre-submittal discussion to inform the application for a limited scope Part 70 license that they intend to submit later this year.
Enclosures:
- 1. Meeting Summary
- 2. Participant List CONTACT: Jenny Tobin, NMSS/DFM/FFLB 301-415-2328 Docket: 70-7032 License: n/a
SUMMARY
OF PUBLIC MEETING WITH PERMAFIX NORTHWEST TO DISCUSS MATERIAL CONTROL AND ACCOUNTABILITY (MC&A) AND THE POTENTIAL FOR AN EXEMPTION AS A PART OF PRE-SUBMITTAL LICENSING DISCUSSIONS DATE AND TIME:
October 7, 2021, 2:00-3:30 LOCATION:
Teleconference PURPOSE:
The purpose of this meeting was to discuss PFNWs planned approach for addressing MC&A in their application and potential request for an exemption to some of these requirements. PFNW and their contractor Enercon presented their proposed approach to MC&A via slide presentation (Agencywide Documents Access and Management System (ADAMS) Accession Number ML21267A453). NRC staff asked questions throughout the presentation, PFNW and Enercon provided verbal responses and will use the pre-submittal discussion to inform the application for a limited scope Part 70 license that they intend to submit later this year.
BACKGROUND:
This was the second in a series of proposed public meetings to engage in pre-submittal discussions on a variety of topics. The first one was held September 19, 2021, with a topic of Criticality Safety and potential for exemption.
DISCUSSION:
On Thursday, October 7, 2021, the U.S Nuclear Regulatory Commission (NRC) staff held a meeting with representatives from PermaFix Northwest (PFNW) and their contractor Enercon; the State of Washington, Department of Health was also in attendance. Representatives of NIRS and Hanford Challenge were also in attendance.
The PFNW and Enercon staff presented slides outlining their proposed approach for material control and accountability (MC&A). The presentation began with an overview of the PFNW facility which has been operating as a waste processor for the last 20 years under a radioactive materials license from the State of Washington (Agreement State license). The facility mainly processes mixed waste for Department of Energy and commercial waste generators. After batch processing, the waste is returned to the customer for storage and/or disposal. The Washington State license currently limits the quantity of special nuclear material that PFNW can possess; only the NRC has the authority to license higher quantities (via a Part 70 license). Due to the nature of the waste processing work, PFNW plans to pursue only a limited-scope Part 70 license.
PFNW plans to submit an application later this year and requested pre-submittal discussions (via public meeting) to engage NRC staff on their proposed approach on a variety of topics that will be included in the Part 70 application.
This public meeting focused attention on the intention to request an exemption from Part 74 Subpart D of Title 10 of the Code of Federal Regulations, Special Nuclear Material of Moderate Strategic Significance. PFNW and Enercon stated that they rely upon DOEs conservative waste characterization and must review and accept manifest documentation prior to shipment to PFNW. The physical and radiological characteristics of the waste materials significantly impact the ability to perform accurate measurements of the SNM content therefore PFNW will propose an exemption from certain requirements of Subpart D of Part 74. As an alternative, the focus of PFNWs MC&A program would be management and control of the waste, from receipt to return to the DOE generator. PFNW also plans to use a number of compensatory measures including the use of video surveillance, tamper-indicating devices, and waste mass balances to demonstrate return of all waste to the generator. Staff from PFNW, Enercon and NRC discussed the proposed approach that may be included in the application, including the use of NUREG-1520, revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications. No regulatory decisions were made at this meeting.
One staff member from the State of Washington, Department of Health (issuer of PFNW State license) was in attendance and clarified that the Washington State materials license would be maintained. Ms. DArrigo (NIRS) requested the ADAMS Accession No.
for the draft MC&A NUREG that NRC staff stated is out for public comment (NUREG-2159, rev. 1, ML21263A119). NRC staff suggested that the applicant review the draft NUREG for applicability and guidance to this project. Mr. Carpenter (Hanford Challenge) requested that the application be open for public comment once submitted and expressed concern about potential effects to local communities with more waste traveling to/from the site. He also raised awareness of a State EPA analysis that is currently underway for the site and the fact that there were two fires onsite in 2019.
During the Q&A portion, NRC staff clarified that the applicant needs to address 10 CFR 74 subpart B, General Reporting and Recordkeeping Requirements, in addition to subpart D and that a Part 70 NRC license is site specific and would have no bearing on the PermaFix facilities in Tennessee or Florida.
RESULTS:
PFNW and Enercon will use the discussions to inform the contents of their application.
ATTACHMENTS:
PermaFix PreSubmittal Public Meeting Slides October 7, 2021 - MC&A ML21267A453
PARTICIPANTS LIST Name Organization Richard Grondin PermaFix Northwest Curt Canon PermaFix Northwest Dakin Utley PermaFix Northwest Tom Magette Enercon (contractor to PFNW)
Phil Gianutsos Enercon (contractor to PFNW)
Tom Fay Enercon (contractor to PFNW)
Dwayne Blaylock Enercon (contractor to PFNW)
Martha Williams Enercon (contractor to PFNW)
Dick Rosano Enercon (contractor to PFNW)
Cheryl Rogers State of Washington, Department of Health Diane DArrigo Nuclear Information and Resource Service (NIRS)
Tom Carpenter Hanford Challenge James Rubenstone NRC, NMSS Glenn Tuttle NRC, NMSS Tom Pham NRC, NMSS Suzanne Ani NRC, NMSS Jacob Zimmerman NRC, NMSS Jenny Tobin NRC, NMSS Patty Jehle NRC, OGC Allyce Bolger NRC, RIV
- via email OFFICE NMSS/DFM/
FFLB/PM*
NMSS/DFM/
FFLB/LA*
NMSS/DFM/
FFLB/BC*
NAME JTobin ELee (WWheatley for)
JZimmerman DATE 10/19/2021 10/20/2021 10/21/2021