ML24270A089
| ML24270A089 | |
| Person / Time | |
|---|---|
| Site: | PROJ0735 |
| Issue date: | 08/27/2024 |
| From: | Maurice Heath NRC/NMSS/DDUWP/LLWPB |
| To: | |
| Shared Package | |
| ML24270A086 | List: |
| References | |
| Download: ML24270A089 (1) | |
Text
SUMMARY
OF U.S. NUCLEAR REGULATORY COMMISSION (NRC) AND U.S. DEPARTMENT OF ENERGY (DOE) VIRTUAL PUBLIC MEETING TO DISCUSS TECHNICAL CLARIFICATION OF NRC REQUEST FOR ADDITIONAL INFORMATION ON IDAHO NATIONAL LAB CALCINE STORAGE FACILITY WIR EVALUATION DATE:
August 27, 2024 ATTENDEES (NRC):
Chris McKenney, Duane White, Cynthia Barr, Louis Caponi, Maurice Heath ATTENDEES (NRC CONTRACTOR):
Osvaldo Pensado ATTENDEES (NRC):
Valerie Kimbro, Gregery Balsmeier, David Thorne, Erik Simpson, William Kirby, Rodrigo Lobos General On October 20, 2023, the DOE submitted the Draft Basis for Section 3116 Determination for Closure of the Calcined Solids Storage Facility at the Idaho National Laboratory Site for the NRC to review. The DOE submittal to the NRC is required under Section 3116 (a) of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 (NDAA).
On April 8, 2024, NRC issued a Request for Additional Information (RAI) to DOE regarding its Draft Waste Incidental to Reprocessing (WIR) Evaluation for the Closure of the Calcined Solids Storage Facility at the Idaho National Laboratory Site (ML24095A110). The purpose of the public meetings is to discuss DOEs intended responses to the RAIs and provide an opportunity for NRC and DOE to ask clarifying questions. The public meeting outcome establishes a common understanding of the information that is needed for the NRC to complete its review. The RAI public meeting supports NRCs consultation role as defined in Section 3116 of the NDAA.
On August 27, 2024, the NRC held a virtual public meeting with DOE and stakeholders to discuss NRC RAIs on removal of highly radioactive radionuclides to the maximum extent practical (MEP). The public meeting was noticed on the NRC public meeting schedule webpage https://www.nrc.gov/pmns/mtg, Agenda Item 1. Clarification of RAI MEP-1 NRC discussed the need for additional information regarding the technical specifications and capacity of the pneumatic retrieval technology, comparison data from full-scale mockup to actual Calcined Solids Storage Facility (CSSF) bins, clarification on historical mockups, and technologies removing calcine to MEP.
DOE understands the RAI and plans to provide additional details of the technical specifications and capacity of the bulk pneumatic retrieval technology. DOE plans to provide additional testing of the bulk pneumatic retrieval system conducted in 2022, which provides additional system operating parameters and demonstrates removal to 99%. DOE has decided to discontinue its development of residual cleanout systems because of the effectiveness of the bulk retrieval system demonstrated in the 2022 testing. However, DOE noted that the exact parameters of the
2 bulk pneumatic retrieval system that will be used to remove calcine will not be developed for years, particularly due to the recent expansion of the overall project scope.
DOE plans to provide an analysis of differences between CSSF bins. NRC and DOE understand that CSSF 1 was used as a mockup because it is the most challenging to remove calcine from. DOE plans to provide a more detailed description of the attributes of the other bin sets that DOE expects will make retrieval easier than retrieval from CSSF 1. Additionally, DOE plans to provide an analysis of the differences between historical mockups and testing of CSSF bins and the actual CSSF bins.
Agenda Item 2. Clarification of RAI MEP-2 NRC discussed the need for additional information regarding the process to monitor performance of the pneumatic retrieval system during operation, criteria for terminating retrieval activities and methods to demonstrate removal of highly radioactive radionuclides to the maximum extent practical.
DOE understands the RAI and explained their plans to monitor performance and terminate operations once removal to the MEP has been achieved. DOE plans to use a combination of video surveillance, monitoring changes in retrieval rates, and visual inspection during operations to monitor operations and verify removal to the MEP has been achieved. DOE plan to provide the steps to the decision-making process to determine the termination of retrieval operations and verify that retrieval operations have successfully removed highly radioactive radionuclides to the maximum extent practical. DOE and NRC discussed the delayed timeline for determining exact parameters related to system capability and criteria for terminating operations. NRC understand that DOE is still testing and optimizing the operational parameters of the bulk pneumatic retrieval system that will be used to remove calcine. NRC requested a high-level description of the decision-making process to terminate retrieval to be included in the waste determination (WD). Additionally, DOE requested NRC to review Appendix B DOE Closure Approach for CSSF which includes more detailed information on closure for each bin set or group of bin sets, as it may contain information related to RAI MEP-2.
Given that waste retrieval is not expected for any bin set prior to DOEs issuance of a final waste determination, NRC discussed similarities between its consultative review of removal of highly radioactive radionuclides to the maximum extent practical and its monitoring responsibilities under the National Defense Authorization Act (NDAA) to assess compliance with as low as is reasonably achievable or ALARA criteria under 10 CFR 61.41, protection of the general population from releases of radioactivity. Should DOE find that calcine waste meets the NDAA criteria and is not high-level waste and can be managed as low-level waste, NRC can review DOEs efforts to remove highly radioactive radionuclides in its monitoring role to assess compliance with performance the LLW performance objectives in 10 CFR Part 61, Subpart C, in coordination with the covered state (Idaho Department of Environmental Quality).
Summary In October 2023, DOE submitted the Draft Basis for Section 3116 Determination for Closure of the CSSF at the Idaho National Laboratory Site for the NRC to review. In April 2024 NRC issued RAIs to DOE. NRC conducted a virtual public meeting to provide clarification on the RAI issued
3 to DOE on the Draft Basis for Section 3116 Determination for Closure of the Idaho National Laboratory CSSF. These RAI public meeting supports NRCs consultation role as defined in Section 3116 of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005.
The meeting provided an opportunity for NRC and DOE to ask clarifying questions and establish a common understanding of the information that is needed for the NRC to complete its review.
DOE responded that the RAI questions were clarified, and DOE believes they have a path forward for responding to the RAIs. DOE stated by letter that they will respond to the RAIs no later than January 30, 2025.