ML20036F237
| ML20036F237 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/17/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Diaz N, Shirley Ann Jackson, Mcgaffigan E, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20036F238 | List: |
| References | |
| NUDOCS 9808240018 | |
| Download: ML20036F237 (3) | |
Text
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,3f 2-4 UNITED STATES 3
j NUCLEAR REGULATORY COMMISSION t
WASHINGTON. D.C. 20555-0001
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August 17, 1998 MEMORANDUM TO: Chairman Jackson Commissioner Diaz Commissioner McGat!igan FROM:
L. Joseph Callan b
Executive Director fo/ perations
SUBJECT:
CHANGE IN STAFF'S PLAN FOR REVIEW OF U.S. ECOLOGY'S WASTE CLASSIFICATION JUSTIFICATION FOR TROJAN REACTOR VESSEL l
in SECi-97-164, dated July 25,1997, and SECY-97-244, dated October 21,1997, the staff recommended an approach for reviewing a request from Portland General Electric Company i
(PGE) to allow shipment of the Trojan Nuclear Plant reactor vessel (RV), including its irradiated i
intemals, by barge, to the U.S. Ecology low-level radioactive waste disposal site in Hanford, Washington. The PGE proposal to dispose of the RV with its internals intact is unprecedented, i
and therefore is the subject of heightened public interest.
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With respect to waste classification, staff's approach contemplated reviews by both the Nuclear Regulatory Commission (NRC) and the State of Washington (the State). Staff noted that under NRC's manifesting requirements (10 CFR 20.2006 and 10 CFR Part 20, Appendices F and G) low-level waste shipments must be classified in accordance with 10 CFR 61.55 and that NRC's
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role is to ensure that PGE properly classifies its waste in accordance with this regulation. The I
State of Washington will classify the wastes for the purpose of ensuring that the wastes are suitable for disposal at the U.S. Ecology site.
i On January 22,1998, the Commission issued a Staff Requirements Memorandum approving the staff's proposal. As directed by the Commission, the staff sent a letter to Washington (Attachment 1) which, as an Agreement State, licenses the U.S. Ecology site. The letter requested Washington to ask U.S. Ecology to coordinate with PGE and provide to Washington a more comprehensive and defensible pathway analysis of the Trojan RV disposalimpacts.
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Based on this information,if the analysis demonstrates that the disposal of the RV will be in conformance with the performance objectives of Part 61, the waste would be classified as Class C, in accordance with 10 CFR 61.55,10 CFR 61.58, and the attemate averaging provisions of the Branch Technical Position on Concentration Averaging and Encapsulation dated January 17,1995. The letter also offered technical assistance to Washington.
On May 22,1998, U.S. Ecology submitted to the State its " Evaluation of Potential Dose Pathways from Disposal of Portland General Electric's Trojan Reactor Vessel at U.S. Ecology's Low-Level Radioactive Waste Disposal Facility, Richland, WA." The State has initiated its CONTACT: J. Hickey, DWM/NMSS ng q l~
301-415-7234 O i vs
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9808240018 980817 CF ADOCK 05000344 i
The Commissioners..
r:,vi:w and has sent technical questions to U.S. Ecology. In addition, on August 7,1998, the State informed the staff that it did not intend to seek technical assistance from the NRC for the review of the pathway analysis (Attachment 2).
The staff has reconsidered its recommended approach and is not planning to conduct an i
independent review of PGE's waste classification. Given the State's position declining assistance from NRC, and the fact that Washington, as an Agreement State, has the necessary competence and authority to review the U.S. Ecology submittal, use of NRC's limited resources to conduct a duplicative review is not warranted. The staff recognizes, as reflected in SECY-97-244, that NRC has an independent role to assure that PGE properly classifies the waste shipment. However, NRC's role does not oblige the staff to independently review PGE's waste classification documentation including the pathway analysis. The staff believes it can reasonably rely on the State's review of that documentation. This is the course the staff now plans to follow. While it is a change in approach from that described in SECY-97-244, which was approved by the Commission, it is consistent with the approach by which NRC performs its waste classification role for the vast majority of low-level waste shipments by NRC licensees.
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The staff's review of the transportation aspects of PGE's proposal will continue. After completing the transportation review, the staff intends to transmit its conclusions along with the l
results of the Washington State review for Commission consideration by October 2,1998. If i
NRC were to conduct an independent review of the pathway analysis, the review would have to be initiated by August 26,1998, to avoid negative impacts on the PGE schedule for grouting the RV in December 1998 and shipping in August 1999.
The staff intends to proceed in accordance with the change in approach described above and, thus, to refrain from conducting an independent review of the pathway analysis from PGE's i
proposal, unless directed otherwise by the Commission before August 26,1998.
Attachments:
- 1. Ltr to J. L. Erickson did 1/30/98
- 2. Ltr to R. L. Bangart dtd 8/7/98 cc: OGC, SECY, OCA, OPA, OlG, CIO, CF0 TICKET: N-9800405 DISTRIBUTION:
LCentral File 1 LLDP r/f NMSS r/f PUBLIC DWM r/f PTr:ssler HThompson LCallan RJohnson NMSS Dir. r/f CPol nd EDO r/f
- SEE PREVIOUS CONCURRENCE Path cnd File Name:A:WESSEL2.OGC OFC LLDP*
E OSP*
E OGC*
NRR*
E SFPO*
E DVM DWM*
NA'IE JHickey/cv PLohaus JRoe SShankman MWeber JGreeves DATE 8/12/98 8/12/98 8/13198 8/12/98 8/12/98 8/13/98 8/13/98 OFC NMSS ')
DEDR EPO(
h ih6 H k son Iailh NAME DATE 8//i/98 8/f}/98 8/M98 OFFICIAL RECORD COPY ACNW:
YES _ NO _
Category: Proprietary _ or CF Only _
IG:
YES _ NO _
LSS:
YES _ NO _
Delete file after distribution: Yes _ No _
=.-
The Commissioners i review and has sent technical questions to U.S. Ecology. In addition, on August 7,1998, the State informed the staff that it did not intend to seek technical assistance from the NRC for the I
review of the pathway analysis (Attachment 2).
The staff has reconsidered its recommended approach and is not planning to conduct an l
independent review of PGE's waste classification. Given the State's position declining j
assistance from NRC, and the fact that Washington, as an Agreement State, has the necessary competence and authority to review the U.S. Ecology submittal, use of NRC's limited resources to conduct a duplicative review is not warranted. The staff recognizes, as reflected in SECY 244, that NRC has an independent role to assure that PGE properly classifies the waste shipment. However, NRC's role does not oblige the staff to independently review PGE's waste classification documentation including the pathway analysis. The staff believes it can reasonably rely on the State's review of that documentation. This is the course the staff now plans to follow. While it is a change in approach from that described in SECY-97-244, which was approved by the Commission, it is consistent with the approach by which NRC performs its waste classification role for the vast majority of low-level waste shipments by NRC licensees.
The staff's review of the transportation aspects of PGE's proposal will continue. After completing the transportation review, the staff intends to transmit its conclusions along with the results of the Washington State review for Commission consideration by October 2,1998. If NRC were to conduct an independent review of the pathway analysis, the review would have to be initiated by August 26,1998, to avoid negative impacts on the PGE schedule for grouting the RV in December 1998 and shipping in August 1999.
The staff intends to proceed in accordance with the change in approach described above and, thus, to refrain from conducting an independent review of the pathway analysis from PGE's
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proposal, unless directed otherwise by the Commission before August 26,1998.
Attachments:
i
- 1. Lir to J. L. Erickson did 1/30/98
- 2. Lir to R. L. Bangart dtd 8/7/98 i
cc-OGC l
OlG l
CIO CFO t
i 1
%g 1
UNITED STATES j
- j.
j NUCLEAR REGULATORY COMMISSION wAsumaton, o.c. sneewom
,,,,, c January 30, 1998 4
Mr. John L. Enckson, Drector Division of Radoton Protecten Department of Health Airdustnal Center Buildmg 85 P.O. Box 47827 Olyinpia, WA 98504-7827
Dear Mr. Enckson:
On March 31,1997, Portland General Electnc Company (PGE) requested the U.S. Nuclear Regulatory Commission to issue a Type B Certificate of Compliance under our transportation regulations to allow a one-time shipment of the Trojan Nuclear Plant's reactor vessel with its 1
intemals for disposal at the U.S. Ecology site in Hanford, Washington. Prior to beginning a review of this transportiion package application, it is our intent to address the waste classification of the waste shipment. Under the 10 CFR 20 waste manifesting requirements, a waste generator must classify wastes in accordance with 10 CFR 61.55. It is our goal to ensure that the waste shipment is property classified.
i-On June 18,1997, PGE submitted responses to several of our questions relating to the classification of the waste shipment (Attachment 1). PGE acknowledges that some of the
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intemals are Greater-Than-Class C (GTCC), but is proposing to classify the wastes by averaging q
the reactor intemals with the pressure vessel. The core baffle plates, the core former plates, and
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the lower core plate substantially exceed the recommended ratios for classifying activated metals given in Section 3.3 of the Branch Technical Position (BTP) on Concentration Averaging and i
Encapsulation dated January 17,1995. However, PGE indicated that the one-piece shipment of 1
the RV with the intemals would allow contact handling of the shipment, would result in 39 to 44 fewer waste cans requiring storage until a GTCC waste disposal site is developed, would reduce l
contamination control problems, would reduce occupational exposures from 134 to154 person-
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rom to 67 person-rom (out of 591 person-rom estimated for the entireTrojan decommissioning),
l and would reduce waste shipments from 44 to 1.
i PGE also provided a pathway analysis performed by U.S. Ecology, which was previously i
submitted to the State of Washington. This pathway analysis addresses groundwater impacts j
and doses from direct exposure. Other ' truder pathways such as construchon and resident-m farmer scenarios are not addressed, nor is there a justification for assuming that the package will remain intact over the hazard lifetime of the nuclides that are cribcal to the vaste classification:
C-14, Ni-59, Ni 63, and Nb-94.
The NRC staff will consider attomative approaches to win ste nuclide averaging l'it can be shown that the waste s will meet the performance objectt, as in 10 CFR Part 61 (see 10 CFR 61.58 and Secten 3.9 of the BTP on Concentrabon Averaging and Encapsulabon). The evaluaten should include a comprehensive and defensible pathway analysis that includes all relevant pathways.
The draft BTP on a Peiformance Assessment Methodology for Low-Level Radioactive Waste ATTACHMENT 1 0 ?NG&/
1 J. Erickson j Disposal Facilities could be used as guidance for this analysis. The draft BTP has been available for public comment and review and does not represent a final agency position.
We request that your staff ask U.S. Ecology, in coordination with PGE, to perform a comprehensive and defensible pathways analysis to demonstrate the suitability of the proposed wastes for disposal at the Hanford disposal site. Specifically, the analysis should be based on intruder-construction and intruder resident-farmer scenarios carried out for the time frame proposed in the BTP.
If tb waste package is assumed to be intact for a period greater than 500 years, justification neecs to be provided. The draft 'BTP on a Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities" could be used as guidance. Sections 3.2.2,3.2.3,3.3.4, and 3.3.5 of this BTP provide guidance on the time frames 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 attemative averaging provisions of the BTP on Concentration Averaging and Encapsulation. We are also willing to provide any technical assistance you may desire for the review of the submitted pathway analyses.
- Singrely, if {GI
/2,e fC1 Richard L. Bangart, Director, /
Office of State Programs ;/
Attachment:
As stated