RIS 2008-12, Considerations for Extended Interim Storage of Low-Level Radioactive Waste By Fuel Cycle and Materials Licensees
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ML073330725 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF FEDERAL AND STATE MATERIALS AND ENVIRONMENTAL MANAGEMENT PROGRAMS OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, DC 20555 May 9, 2008 NRC REGULATORY ISSUE SUMMARY 2008-12 CONSIDERATIONS FOR EXTENDED INTERIM STORAGE OF LOW-LEVEL RADIOACTIVE WASTE BY FUEL CYCLE AND MATERIALS LICENSEES
ADDRESSEES
All holders of U.S. Nuclear Regulatory Commission (NRC) fuel cycle and materials license All Radiation Control Program Directors and State Liaison Officer
INTENT
The NRC is issuing this regulatory issue summary (RIS) to inform addressees of considerations related to extended interim storage of low-level radioactive waste by fuel cycle and materials licensees that may be necessary as a result of loss of permanent disposal capacity for some classes of LLR Not all of these licensees will need to store LLRW for an extended perio No specific action or written response is require NRC is providing this RIS to Agreement States for their information and distribution to their licensees as they consider appropriat
BACKGROUND
This RIS presents considerations related to the extended interim storage of low-level radioactive waste (LLRW). It updates information provided in Information Notice (IN) 90-09 "Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees," dated February 5, 199 (Similar information for power reactor licensees is given in Generic Letter 81-38, "Storage of Low-Level Radioactive Wastes at Power Reactor Sites," dated November 10, 1981) The Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA) established a series of milestones, penalties, and incentives to ensure that States or regional compacts make adequate progress towards being able to manage their LLR Throughout the 1980s and 1990s, the States and compacts worked to implement the requirements of the LLRWPAA with limited succes After June 30, 2008, it is likely those LLRW generators and licensees in 36 States, the District of Columbia, the Commonwealth of Puerto Rico, and the U.S. Territories will lose access to the full-service LLRW (Classes A, B, and C LLRW as defined in section 61.55 of 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste") disposal facility in Barnwell, South Carolin Consequently, many LLRW generators will likely need to store a portion of their LLRW for an indefinite perio This will include Class B and C waste as well as certain Class A waste streams that do not meet the waste acceptance criteria of the LLRW disposal facility in Clive, Utah. 1 Additionally, the events of September 11, 2001, have changed the Nation's safety and security paradigm for the possession and storage of byproduct, source, and special nuclear material Guidance for extended LLRW storage needs to be considered in the context of changing regulatory requirement For instance, additional requirements have been imposed on radioactive materials licensees who are authorized to possess radionuclides of concern in quantities exceeding certain threshold limits (see, e.g., 70 Federal Register 72128 (December 1, 2005) (Order Imposing Increased Controls); 72 Federal Register 70901 (December 13, 2007) (Order imposing Fingerprinting, and Criminal History Record Checks Requirements for Unescorted Access to Certain Radioactive Materials)). Changes in license possession limits necessitated by interim storage of LLRW may result in possession of radionuclides of concern in quantities exceeding these threshold limit In such cases, additional requirements - like those cited above - may be imposed on licensee The staff also prepared recommendations related to storage of all LLRW in SECY-94-198, "Review of Existing Guidance Concerning Extended Storage of Low-Level Radioactive Waste,"
dated August 1, 199 To the extent that the recommendations relate to storage of LLRW by materials and fuel cycle licensees, they are reemphasized her
SUMMARY OF ISSUE
Some licensees may need a license amendment to allow on-site storage of some LLRW for which disposal capacity is not availabl Before considering extended storage, licenses are encouraged to implement measures to minimize production of LLRW for which there is no disposal optio If the possession limits specified in a license need to be increased to allow for extended interim storage, or if the terms and conditions of a license otherwise need to be modified, a license amendment or equivalent compliance mechanism will be require Enclosure 1 to this RIS identifies information that NRC is likely to require in support of such amendment request This information may also be useful to other licensees as they assess the adequacy of their storage methods and to potential applicants for a license to construct and/or operate a centralized storage facilit The following considerations are central to extended storage and are the basis of the information included in Enclosure 1: 1 Certain other Class A Waste does not include discrete sources of Radium - 226 and other naturally occurring and accelerator produced radioactive material (NARM) which may create the potential for new LLRW streams that would require storag The EPAct 2005 specifically preserves pre-existing disposal options for this materia
- Storage is not a substitute for disposa Other than storage for radioactive decay or other short-term operational considerations, LLRW should be stored only when disposal capacity is unavailable and for no longer than necessar When feasible, licensees may wish to specify a date by which storage of specific waste streams will end and disposal or alternative disposition (such as processing for radioactive waste volume reduction, or, in the case of sealed sources, return to manufacturer) of the LLRW will take plac As part of their planning efforts, licensees may wish to also identify any stored waste streams (e.g., Class B, C, greater than Class C, unprocessed biological waste) for which no disposition pathway is reasonably foreseen, and be prepared to identify such waste streams to NRC officials upon reques
- Waste should be stored in a form suitable for disposal if there is sufficient assurance that the waste form is ultimately acceptable for disposal and will not require significant reprocessin Licensees may wish to process and/or package the waste to be stored in a manner consistent with physical stability and radiation protection goals including the consideration to keep exposure as low as reasonably achievable (ALARA). Processing and/or packaging should not preclude or diminish the likelihood of future transportation or alternative disposition pathways for any waste stream in accordance with 10 CFR Part 20, "Standards for Protection Against Radiation," Subpart K, "Waste Disposal." Individual circumstances will determine whether labeling containers of stored LLRW is required in accordance with 10 CFR 20.1904, "Labeling Containers," or exempt in accordance with 10 CFR 20.1905, "Exemptions to Labeling Requirements."
- To ensure the integrity of packaging and maintenance of waste form, stored waste packages should be protected from the elements (e.g., wind and precipitation) and from extremes of temperature and humidit To the extent that circumstances make it impractical to provide such protection from climate, the licensee may wish to determine how it will maintain package integrity and prevent the release of stored LLRW despite the exposure of stored waste packages to the element For example, maintaining a brief assessment of time-dependent deterioration that considers the specific packaging and form of the stored waste and a contingency plan for mitigation of such package deterioration to prevent radioactive release or contamination could constitute sufficient action to maintain package integrit
- Waste should be stored in an area that permits ready visual (direct or remote) inspection on a routine basi Licensees may wish to conduct and document such inspections on a quarterly basis (or on an alternative schedule as justifiable by an overall assessment of the inherent safety, stability, and security of the LLRW storage system).
- In addition to existing measures to locate waste during an emergency, the licensee may wish to consider a real-time waste tracking system that allows the location of specific packages or accumulations of packages during emergencie
- Licensees should evaluate the potential for deterioration of waste packages and determine whether procedures and equipment may be needed to repackage wast If so, licensees may wish to have them availabl
- Decomposition and chemical reaction of incompatible waste materials over time can result in gas generation or other reaction product Licensees may wish to evaluate radioactive waste that they are planning to store and take measures to prevent or mitigate the adverse consequences of these reaction Furthermore, licensees may wish to determine if the need exists for additional ventilation, air filtration, or fire detection/alarm/protection /suppression system In view of the increased quantities and potential changes in chemical compositions of radioactive waste that may now be stored for longer periods of time, licensees are reminded to assess whether new or revised provisions are necessary for their waste facility environmental release and contamination monitoring programs in order to continue to assure, and in some cases demonstrate, complianc
- Most waste forms and packaging used for extended interim LLRW storage are not likely to represent a significant increment of direct radiation exposure potential to workers. However, licensees may wish to consider their specific waste and storage plans and determine if additional radiation shielding or other actions are warranted to keep radiation exposures ALAR
- Waste should be stored in a manner that minimizes potential exposure to workers who are required to access it periodicall Licensees may wish to consider possible alternative disposition pathways and times for different waste stream In some cases, tradeoffs may be justified between package dose rate and ease of accessibilit In such cases, the NRC recommends that licensees prepare an ALARA analysis to justify the tradeof Security considerations may also be factors in the analysi
- Stored waste should be located in a restricted area or managed in accordance with Commission regulations in 10 CFR 20.1801, "Security of Stored Material." This regulation requires licensees to secure, from unauthorized removal or access, licensed materials that are stored in controlled or unrestricted area When waste storage areas are unoccupied by authorized personnel, stored waste should be locked inside a facility (the storage area itself, an immobile safe, or a similar secure device with access limited to authorized personnel) as part of a key control system or equivalent syste
- Licensees who received or will receive increased control and related orders addressing fingerprinting and criminal history should follow the requirements of those orders, including specific security, access, and detection requirement Similarly, licensee programs already established to implement those orders should be reviewed to determine necessary revision/expansions of the program to assure that continued compliance with those orders is carried over to the areas where waste containing radioactive material in quantities of concern will be stored and handled/processe
- Given the uncertainties regarding disposition alternatives for some LLRW, it may not be practical to establish a specific time limit for retention of LLRW in extended interim storag However, the NRC recognizes that it is prudent practice to move LLRW from storage to permanent disposal/disposition as quickly as is practicabl Licensees storing LLRW are encouraged to develop and maintain a strategy and timeline for disposition and/or disposal of LLRW in their possessio Different strategies and timelines may be appropriate for waste streams having or requiring different disposition pathway Waste streams for which the licensee can identify no foreseeable disposition pathway should be specifically acknowledge Notwithstanding the absence of a specific time limit for storage, NRC staff will undertake a licensing review of LLRW storage circumstances at the end of each license renewal period for NRC licensee To facilitate such review, the NRC encourages licensees to periodically reassess the circumstances dictating indefinite interim storage of LLRW, impacts on licensed activities other than LLRW storage, and impacts on nearby unlicensed activities including activities not under licensee contro The assessment should also include a reevaluation of storage technique, technique for opening/inspecting/replacing package, and recalculation of activity of LLRW in extended interim storag Licensees are also encouraged to maintain communication with regional compact and/or unaffiliated State and territorial officials (see Enclosure 2) regarding LLRW disposal options and change in disposal availability circumstance
- To the extent possible, licensees may wish to estimate the total life-cycle financial burden of extended interim LLRW storage (including but not limited to operations and maintenance, inspection and monitoring, and eventual disposition) and provide this estimate to organization decision makers for overall budget consideratio
- Storage of hazardous waste, as specified under the Resource Conservation and Recovery Act, is beyond the scope of this documen Some licensees will need to store LLRW that also contains hazardous waste Either the NRC (or Agreement State) and the U.S. Environmental Protection Agency (or Authorized State) regulate these mixed waste The considerations for handling waste provided in this RIS apply only to materials (LLRW) being stored in accordance with NRC regulation It may be prudent or necessary for the licensee to supplement information contained in this RIS with guidance (or requirements) provided by authorities with jurisdiction over the hazardous component of stored wast
BACKFIT DISCUSSION
This RIS requires no action or written response and the backfit rule (10 CFR 50.109,70.76, 72.62 and 76.76) does not appl Consequently, the NRC staff did not prepare a backfit analysi
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal Register because the RIS is informational and does not represent a departure from current regulatory requirement
CONGRESSIONAL REVIEW ACT
The RIS is not a rule as designed by the Congressional Review Act (5 U.S.C. §§ 801-808) and, therefore, is not subject to the Ac
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.).
CONTACT
This RIS requires no specific action or written respons If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate regional offic Larry W. Camper, Director Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
CONTACT
- James Shaffner, FSME/DWMEP (301) 415-5496 James.Shaffner@nrc.gov
Enclosures:
Information that NRC Staff May Require to Authorize Extended Interim Storage of Low-Level Radioactive Waste Regional Compacts, Unaffiliated States and Territories Bibliography List of Recently Issued FSME Generic Communications RIS 2008-12 Page 6of 6
CONGRESSIONAL REVIEW ACT
The RIS is not a rule as designed by the Congressional Review Act (5 U.S.C. §§ 801-808)
and, therefore, is not subject to the Ac
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.).
CONTACT
This RIS requires no specific action or written respons If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate regional offic /RA/ Larry W. Camper, Director Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
CONTACT
- James Shaffner, FSME/DWMEP (301) 415-5496 James.Shaffner@nrc.gov
Enclosures:
Information that NRC Staff May Require to Authorize Extended Interim Storage of Low-Level Radioactive Waste Regional Compacts, Unaffiliated States and Territories Bibliography List of Recently Issued FSME Generic Communications Package No.: ML073330609 OFFICE DWMEP TechEd DWMEP DWMEP DWMEP NSIS/DSP DILRL NAME JShaffner HChang ABradford SFlanders LCamper PHolahan DRathbun DATE 01/16/08 01/22/08 01/22/08 04/01/08 5/09/08 05/02/08 05/02/08 OFFICE NMSS/FCSSOGC OGC OE OIS DMMSA NAME RPierson BJones TRothschildNHilton TDonnell AMcIntosh DATE 05/02/08 05/02/08 05/02/08 02/15/08 05/02/08 01/17/08 OFFICE DMMSA DWMEP NAME RLewis LCamper DATE 05/02/08` 05/09/08 OFFICIAL RECORD COPY
Enclosure 4 List of Recently Issued FSME Generic Communications Date GC No. Subject
Addressees
10/04/07 RIS-07-23 Date For Operation Of National Source Tracking System All licensees authorized to possess Category 1 or Category 2 quantities of radioactive material All Radiation Control Program Directors and State Liaison Officers. 10/17/07 IN-07-35 Varian Medical Systems Varisource HDR Events: Iridium-
192 Source Pulled From Shielded Position All U.S. Nuclear Regulatory Commission medical use licensees and NRC Master Materials Licensees authorized to possess or use a Varian Medical Systems VariSource High Dose Rate Remote Afterloader (VariSource HDR). All Agreement State Radiation Control Program Directors and State Liaison Officers 12/05/07 RIS-07-27 Improving Public Understanding of the Risks Associated with Medical Events All U.S. Nuclear Regulatory Commission medical use licensees. All Radiation Control Program Directors, and State Liaison Officers 12/07/07 RIS-07-28 Security Requirements for Portable Gauges U.S. Nuclear Regulatory Commission portable gauge licensees and Agreement State Radiation Control Program Directors and Liaison Officers 12/14/07 IN-07-38 Ensuring Complete and Accurate Information in the Documentation of Training and Experience for Individuals Seeking Approval as Medical Authorized Users All U.S. Nuclear Regulatory Commission medical use licensees and NRC master materials licensee All Agreement State Radiation Control Program Directors and State Liaison Officers 02/01/08 RIS-08-02 Actions to Increase the Security of High Activity Radioactive Sources All U.S. Nuclear Regulatory Commission Materials and Master Materials Licensees. All Agreement State Radiation Control Program Directors and State Liaison Officers. Note: This list contains the six most recently issued generic communications, issued by the Office of Federal and State Materials and Environmental Management Programs (FSME). A full listing of all generic communications may be viewed at the NRC public website at the following address:
http://www.nrc.gov/reading-rm/doc-collections/gen-comm/index.html