ML20199G026
| ML20199G026 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/03/1997 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199F987 | List: |
| References | |
| SECY-97-244-C, NUDOCS 9802040196 | |
| Download: ML20199G026 (3) | |
Text
,
NOT ATIO N VOTE f
RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DICUS
SUBJECT:
SECY-97-244 -WASTE CLASSIFICATION OF THE TROJAN REACTOR VESSEL Approved xx Disapproved -
Abstain Not Participating Request Discussion COMMENTS: I approve the staff action as proposed in SECY 97-244, subject to the attached edits clarifying the draf t nature of the Branch Technical Position on a Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities.
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SIMATURU J Release Vote /_n_/
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/fT7 DATE Withhold Vote /
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Entered on "AS" Yes X No 7882 28APs 7aa*"
CORR,ESPONDENCE PDR _
i Mr. John L. Erickson, Director Division of Radiation Protection Department of Nealth Airdustrial Center suf2 diar #5 P.O. Box 4*/027 01ysyia, WA 90504-7827 Dear Mr. Erickson On March 31, 1997, Portland General Electric Company (POR) requested the U.S.
Nuclear Regulatory Comunission to issue a Type a Certificate of Complicace under our transportation regulations to r.11ow a one time shipment of the Trojan Nuclear Plant's reactor vessel with its internals for disposal at the U.S.
Ecology site in Manford, Washington. Prior to beginning a full review of this transportation package aprlication, 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 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 properly classified.
On June 14, 1997, POE submitted responses to several of our questions relating to the classification of the waste shipment (Aftachment 1).
POE acknowledges that some of the internals are Greater Than Class C (GTCC), but is proposing to classify the wastes by averaging the reactor internals with the pressure vessel. The core baffle plates, the core former plates, and the lower core plate substantially exceed the recommended ratios for classifying activated metals given in section 3.3 of the trac.ch Technical Position of Concentration Averaging and Encapsulation dated January 17, 1995. However, PGE indicated that the one-piece shipment of the RV with the internals 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 contamination control problems, would reduce occupational exposures frue tu to 154 person rom to 67 person-rem (out of 591 person rem estimated for ths c. tire Trojan deconunissioning), and would reduce waste shipments from 44 to 1.
PGE also provided 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 scenarios are not addressed, nor is there a justification for assuming that the package will remain intact over the hasard lifetime of the nuclides that are critical to the waste classificationi c.14, Ni-59, Ni-63, and Nb-94.
The NRC staff will consider alternative approaches to waste nuclide averaging if it can be shown that the wastes will meet the performance objectives in 1 0 CFR Part 61 (see 1 0 CFR 61.58 and Section 3.9 of the Branch Technical Position (BTP)qon Concentration Averaging and Encapsulation). The evaluation should include a comprehensive and defensible pathway analysis that includes all relevant pathways. The draf t Branch Technical Position on a (BTP) Performance Assessme.nt Methodology for Low-Level Radioactive Waste Disposal Facilities could be used as guidance for this analysis. The draft,BTP hast;beetna q availableeforppublict.icosamentrand* review and does note represeppia,ih posLti,on p,g g g y,w q q gai 2
r 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 e 10,0t: p;; pried I;;ur.f:d M.gg. ped,jin the draf t BTP.
If the waste package is assumed to be intact for a period greater than 500 years, justification needs to be provided.
The draft " Branch Technical Position on a Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities' should be used as guidance.
Sections 3.2.2, 3.2.3, 3.3.4, and 3.3.5 of this Branch Technical Position 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 internals is suitable for disposal under the state of Washington's regulations, we will consider allowing the shipment to be-classified under the alternative averaging provisions of the Branch Technical Position 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.
Sincerely, Richard L.
Bangart, Director Office of State Programs 4
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