NUREG-1307, Final March 2023, Two Comment Resolution Matrix for NUREG-1307, Revision 19: NEI Vllw and Energysolutions Comments
| ML23067A083 | |
| Person / Time | |
|---|---|
| Issue date: | 03/01/2023 |
| From: | Richard Turtil NRC/NMSS/DREFS/FAB |
| To: | |
| References | |
| NUREG-1307 R19 | |
| Download: ML23067A083 (1) | |
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Report on Waste Burial Charges Draft NUREG-1307, Rev.19 Changes in Decommissioning Waste Disposal Costs at Low-level Waste Burial Facilities Comment - Resolution Matrix, Jan 2023 Stakeholder Comment ML Comment Staff Response Janet Schlueter, ML23005A241 Very Low Level Waste (VLLW) - Mrs. Schlueter states: "It is important to recognize that the safe management and NRC has considered LLW disposal alternatives based on NRC's regulations in 10 CFR 20.2001, "General Requirements," of 10 Nuclear Energy Insitute disposal of all radioactive waste generated as a result of licensed operations and activities is of the utmost import to CFR Part 20, Subpart K, "Waste Disposal," which identify the methods by which a licensee may lawfully and safely dispose of its (NEI) the nuclear industry. It is in this context that we offer the comment below which is repeated from our December 2018 licensed radioactive waste. One such method, set forth in 10 CFR 20.2002, "Method for obtaining approval of proposed disposal and December 2020 letters and remains highly if not even more relevant today. While the concept of very low-level procedures," allows "alternative disposal" authorizations that are different from those already defined in the regulations, provided waste (VLLW) is briefly discussed in the draft NUREG, additional language is needed to accurately reflect currently that doses are maintained as low as is reasonably achievable (ALARA) and within the dose limits in 10 CFR Part 20. In practice, allowed disposal practices thus reducing the calculated decommissioning funding amounts. Vast volumes of VLLW 10 CFR 20.2002 is most often used for disposal of very low-level waste (VLLW) in hazardous or local solid waste disposal facilities generated during the decommissioning of nuclear facilities (and other activities as well) are currently approved by that are permitted under the Resource Conservation and Recovery Act (RCRA), but it can be used for other types of disposal not NRC and individual Agreement States for alternate means of disposal at a significantly lower cost than burial as Class already specifically defined in the regulations, such as disposal on a licensee's site or on offsite private property. In addition to the A waste in a licensed LLW disposal facility. As such, we disagree with the statement on page viii that VLLW is difficult traditional LLW disposal facilities described above, staff continues to evaluate LLW disposal trends and evolving industry practices to quantify and forecast. Licensed facilities often estimate and collect such data as part of a radioactive waste that may impact minimum decommissioning fund formula cost calculations provided for in 10 CFR 50.75. NRC is aware that some management and decommissioning program. In fact, one NRC-licensed facility estimates that approximately 72% of LLW disposal methods, such as the disposal of VLLW at unlicensed waste disposal facilities, e.g., RCRA facilities, and other its bulk Class A waste generated during decommissioning could be disposed of at a Resource Conservation and alternatives as authorized under 10 CFR 20.2002 may be less costly than disposal at traditional LLW sites. However, based on a Recovery Act hazardous waste facility. And, if that same waste was disposed of as Class A, the disposal cost would draft study conducted for the NRC (ML13063A190), which considered alternative lower cost disposition pathways for increase 250%. NRC should also consider reviewing EPRI report 1024844 (available at EPRI.com) which contains decommissioning waste, the NRC staff determined that the decommissioning fund formula is not overpredicting the costs of information related to the development of a basis for VLLW as well as tables that provide VLLW volume estimates decommissioning and therefore concludes that incorporating VLLW disposal as an alternative is not necessary at this time.
(i.e., Tables 8-3, 9-2, 9-3). Accordingly, the final version of NUREG-1307, Revision 19, does not consider the use of alternative disposal methods or their potential impact to minimum decommissioning fund formula calculations. No revisions are being made to NUREG-1307 regarding Finally, NRC acknowledges that the calculated decommissioning funding for waste disposal continues to be grossly this comment.
over estimated. See the statement on page viii Revision 19 does not consider the use of alternate disposal methods of their potential impact to minimum decommissioning fund formula calculations. Therefore, we respectfully request that NRC correct its decommissioning fund formula calculations to reflect current NRC and Agreement State approvals that allow for VLLW disposals in permitted (non-LLW) facilities. If this action requires that NRC collect additional data and information from a sample of its licensees or Agreement States, NRC should proceed to do so."
Mr. Scott Baskett, ML23010A223 Changes to LLW disposition prrices at Clive,Utah - EnergySolutions LLC sent a letter to NRC which The NRC published a notice in the Federal Register on November 29, 2022 (87 FR 73345) requesting public comment on Senior Vice President, changed the price quotes for disposition of Class A LLW at the non-compact disposal facility located at Clive, draft NUREG-1307, Revision 19, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs EnergySolutions LLC Utah. The letter indicates that the unit disposal cost information EnergySolutions had previously submitted for at Low-Level Waste Burial Facilities. The public comment period closed on December 29, 2022. The NRC use in developing NUREG-1307 Revision 19, had incorporated a cost escalation error that it had generated. acknowledges the EnergySolutions comment per correspondence received on December 28, 2022, regarding errors with This unit disposal cost information, provided by EnergySolutions in July 2022, was used in the development its previously submitted disposal unit rate cost data and revised disposal unit rate cost data (see ADAMS Accession No.
of the draft NUREG-1307 Revision 19. The EnergySolutions comment provided revised disposal cost ML23010A223). While the NRC staff recognizes the EnergySolutions comment that [a]n error in applying cost escalation information that would impact the waste burial escalation factors presented in NUREG-1307 Revision 19. occurred with the disposal unit rates provided in response to NUREG -1307 Rev[ision] 19 survey for non-compact disposal rates, the revised disposal unit rate cost information presented by EnergySolutions was received too late to be evaluated and considered for inclusion in the development and issuance of the final version of NUREG-1307, Revision 19.
The NRC staff determined it was not possible to make the conforming changes to Revision 19 without causing an undue delay in the publication of the NUREG-1307, Revision 19. A delay in publication would have negatively affected licensees required to submit decommissioning funding assurance status reports by March 31, 2023. Hence, the NRC will not reissue NUREG-1307, Revision 19 for this reporting period. However, staff will take into consideration, as necessary and on a case-by-case basis, the revised EnergySolutions data in its review of decommissioning funding assurance status reports submitted by licensees during the 2023 reporting period.
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