ML20199G089
| ML20199G089 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/05/1997 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199F987 | List: |
| References | |
| SECY-97-244-C, NUDOCS 9802040211 | |
| Download: ML20199G089 (3) | |
Text
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NOT ATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY 97-244 - WASTE CLASSlFICATION OF THE TROJAN REACTOR VESSEL 4
Approved v_,
Disapproved Abstain Not Participating Request Discussion COMMENTS:
I approve of the staff's proposed approach for resolving issues related to the waste classification of the Trojan reactor vessel subject to the attached edits to the letter to the State of Washington. The edit to paragraph 6 of the letter is needed for consistency with paragraph 4 of the letter and it is responsive to a recent concern expressed by an Agreement State that the draft " Branch Technical Position on a Performance Assessment Methodology for Low-level Radioactive Waste Disposal Facilities" not become a defacto regulatory standard for the Agreement States, especially before it is even finalized. As I understand it, the BTP, once finalized (currently planned for early 1999), will be a strictly voluntary standard for Agreement States.
,.. n SIGNATURE D 0 '.
t Release Vote / X /
h k i,'
DATE I
Withhold Vote /
/
Entered on "AS" Yes
/ No 9902040211 900122 l
PDR COMMS NRCC CORRESPONDENCE PDR t
t o t' u v ' v t- / /
Mr. John L Erickson, Diredor Division of Radiation Protodion Department of Health Airdustrial Center Building #6 P.O. Box 47827 Olympia, WA 98504 7827
Dear Mr. Erickson:
On March 31,1997 Portland General Electric Company (PGE) requested the U.8. Nuclear Regulatory Commission to issue a Type B Certificate of Compliance under our transportation regulations to allow a or: h,e shipment of the Trojan Nuclear Plant's reactor vessel with its intomals for disposal at the U.S. Ecology site in Hanford, Washington. Prior to beginning a full review of this transportation package application, it is our intent to address the waste classification of the waste shipment and make sure of its suitability for disposal. Under the 10 CFR 20 waste manifesting requireraents, a waste generator must classify wastes in accordance with 10 CFR 81.53. It is our goal to ensure that the waste shipmerd is property classified.
On June 18,1997 PGE submitted responses to several of our questions relating to the classifloation of the waste shipment (Attachment 1). PGE acknowledges that some of the intomals are Greater Than Class C (GTCC), but is proposing to classify the wastes by -
averaging the reactor intomals with the pressure vessel. The core baffle plates, the core forme plates, and the lower core plate substantially exceed the recommended ratios for classifying activated metals given in Section 3.3 of the Branch Technical Positionpj Ceneeid,e,en Averaging and Encapsulation dated January 17,19g5. However, PGE It' iosted that the one-d pisos shipment of the RV with the intomais would allow contact handling of the shipment, would result in 39 to 44 fewer waste cens requiring storage until a GTCC waste disposal site is developed, would reduce contamination control problems, would reduce oooupational exposures from 134 to 154 person-tem to 67 persorwom (out of 591 person-rom estimated for the entire Trojan decommissioning), and would reduce waste shipments from 44 to 1.
PGE also ge/,ded a pathway analysis performed by U.S. Ecology, which was previously submitted to the State of Washington. This pathway analysis addresses groundwater impacts and doses from direct exposure, Other intruder pathways such as construction and resident-farmer soonarios are not addressed, nor is there a justification for assuming that the package w!!! remain intact over the hazard lifetime of the nuclides that are critical to the waste classification: C 14, Ni 59, Ni43, and Nb-94.
The NRC staff will consider altemative approaches to waste nuclide averaging if it can be shown that the wastes will meet the performance objectives in 10 CFR Part 61 (see 10 CFR 61.58 and Section 3.9 of the Branch Technical Position on Concentration Averaging and Encapsulation). The evaiustion should include a comprehensive and defensible pathway analysis that includes all relevant pathways. The draft Branch Technical Position on a -
Forformance Assesmnent Methodology for Low-Level Radioactive Waste Disposal Facilities c_.wid be used as guidance for this analysis.
ATTACHMENT 3
..i
2 We request that your staff ask U.S. Ecology, in coordination with PGE, to perform a comprehensive and defensible pothways analysis to demonstrate the suitability of the propcM wastes for disposal at the Hanford disposal site. Spoolflosley, the analysis should be based on intruder construction and intruder resident-farmer scenarios corrlod out for a 10,000 year period.
If the waste peakage is assumed to be intact for a period greater than 500 years, justifloation noods to be provided. The dret ' Branch Technical Position on a anos Assessment
'treWgi for Low Level Radioactive Weste Disposal Facilities
- used as guidance.
x Scotions 3.2.2,3.2.3,3.3.4, and 3.3.6 of this Branch Technical Positbn provide guidance on the time fremos for the performance assessment, use of engineered barriers, and evaluation of waste forms for the performance assessment. After your review of this information, if you conclude that the reactor vessel with intemals is suitable for disposal under the State of Washington's regulations, we will consider allowing the shipment to be classified under the altemative averaging provisions of the Branch Technical Position on conoontration Averaging and Encapsulation. We are also willing to provide any technical assistance you may desire for the review of the submitted pathway ana!yses.
Sincerely, Richard L Bangert, Director Offloe of State Programs 4
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