USE_Update of LLRW Alternate Disposal Options_080511

Report
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Regulated under the Atomic Energy Act
◦ Low concentrations of source, byproduct and
special nuclear material
◦ Accelerator produced material
◦ Generally exempted materials, products & devices
(e.g. smoke detectors, luminous dials, etc.)
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Not Regulated under the Atomic Energy Act
◦ Naturally occurring radioactive material (NORM)
except radium & certain other discrete sources
◦ Technologically-enhanced NORM (TENORM)
◦ Pre-UMTRCA uranium and thorium ore processing
waste (FUSRAP)
Waste Specific:
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NRC Decommissioning Plan approval
NRC General Exemption
NRC/Agreement State license condition/amendment
NRC/Agreement State approval letter
NRC/Agreement State specific exemption*
Disposal Facility-Specific:
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State law or regulation
RCRA permit condition/amendment
*Policy Note: A 10 CFR 20.2002 alternate disposal authorization is not
an exemption. However, NRC policy is to issue an exemption
concurrently.
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Select RCRA Subtitle-C Sites are viable options
for LARW
Characteristics similar to Part 61 LLRW sites
(‘hybrid’ sites)
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Remote location with limited population
Meet performance assessment criteria
Desert environment with low annual rainfall
Deep depth to groundwater
Not all RCRA sites meet these criteria
RCRA Hazardous Waste Cell Design
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Site-specific radiological performance
assessment (RESRAD)
Operating Procedures
Emergency Response Plan
Rad Training, Occupational Monitoring, and
Personnel Dosimetry
Environmental Monitoring
Closure/Post-closure Financial Assurance
“Hybrid” RCRA Site:
Grand View, ID (US Ecology)
• Avg 700,000 tons
disposed over last 5
years
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~50% radioactive
material
Majority FUSRAP &
EPA CERCLA waste
NRC/AS exempt
waste volumes
increasing
Generator Requests
Alternate Disposal
Authorization & Exemption
NRC/AS Conducts
Technical Review
Rejects
NRC/AS Approves
USE Submits Safety
Assessment to ID
Requests More
Info
IDEQ Reviews
Concurs
Rejects
General:
 NORM up to 1,500 pCi/g
 Source material <0.05% by weight
 Accelerator produced material <10 mrem/hr
 Generally exempt items & devices
With Specific Exemption:
 Source, Byproduct & SNM <3,000 pCi/g, and
 NRC/Agreement State exemption based on “less
than a few millirem” projected dose per Safety
Analysis
Andrews, TX Site
Robstown, TX Site
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All NORM isotopes except radium <150 pCi/gm
or less
Radium <30 pCi/g
Uranium & thorium <0.05% by weight
Exempt byproduct material with state approval
Specific Licensed Material: “300-day rule”
Mixed hazardous & radioactive material
acceptable
* Applies to both Andrews (WCS) & Robstown (US Ecology) sites
Permittee evaluates waste per TAC
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Requests
information
Rejects
Submits concurrence request to TCEQ:
Reference applicable exemption rule
Physical description- composition, weight,
etc.
Isotope concentrations
Generator & waste location
Must be exempt in state of origin
TCEQ Reviews
TCEQ Issues Written
Concurrence For Disposal
Rejects
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Safety Light Corporation, Bloomsburg PA
NRC/PADEP licensed, EPA Superfund Site
Cleanup conducted by USACE
~1,600 cy of soil & debris
50 pCi/g 137Cs, 180 pCi/g 90Sr, 50 pCi/g 226Ra
PADEP exemption granted
in Nov 2008
Shipments made via IMC to
ID RCRA Site
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BASF (Former Englehard Chemical Co.),
Plainville, MA
Formerly licensed by AEA (term. in 1963)
123 tons of Natural, Depleted, and Low
Enriched Uranium (~4%)
Approval letter granted by MDPH (Feb 2010)
Idaho concurrence
Disposed at Idaho RCRA site
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PG&E, Humboldt Bay NPP
Undergoing decommissioning
~200,000 ft3 of soil & debris from Units 1&2
5 pCi/g 137Cs, 5 pCi/g 60Co, 1 pCi/g 14C, more
NRC issued EA with
FONSI and exemption
in Nov 2010
Shipments ongoing to
ID RCRA Site
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Former Molycorp source material processing
operation in Washington, PA: NRC licensed
~100,000 cy of soil and slag from production of
ferro-alloys (Nb amd Mo)
232Th ~50 pCi/g, 238U ~15 pCi/g, 226Ra ~5 pCi/g
Classified as unimportant
quantity of source material
(<.05% by weight)
Disposed at Idaho RCRA
site
“The Committee should work with the staff to consider and
provide advice on what NRC can do to assist in providing
greater disposal options for low-level radioactive waste, e.g.
use of appropriate Resource Conservation and Recovery Act
(RCRA) Subtitle C hazardous waste facilities.”
U.S. NRC Staff Requirements Memo - 1/16/07
Questions ??

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