Exemption Request for Special Nuclear MaterialsU.S. Nuclear Regulatory Commission
Rockville, MarylandDecember 14, 2015
1
Overview
• Introductions
• Licensing Overview
• Regulatory and Technical Basis for theExemption Request
• Response to Request for AdditionalInformationInformation
• Discussion
2
J. Scott Kirk, CHP
Licensing Overview
J. Scott Kirk, CHPVice President Of Licensing & Corporate
Compliance
3
Andrews County, Texas
• WCS operates the first newdisposal facility for Class A, Bdisposal facility for Class A, Band C over het past 40 years.– Disposal authorized in the Texas
Compact Waste Disposal andFederal Waste Disposal Facilities
• 3,890,000 Ci for CWF
• 5,600,000 Ci for FWF
• Licensed by Texas Commissionon Environmental Qualityon Environmental Quality(TCEQ) and located in AndrewsCounty, Texas.
4
Licensing Overview
• WCS has concentration-based limits for SNM aspreviously approved by the NRC for waste receipts atpreviously approved by the NRC for waste receipts atthe Treatment, Storage and Disposal Facility (TSDF).
• WCS also has above ground, mass-based limits forSNM approved for receipt at the Federal WasteDisposal Facility and Texas Compact Waste DisposalFacility.
• Determination of which limits apply are based on• Determination of which limits apply are based onwhich facility will receive the waste fortreatment/storage at the TSDF or for disposal ateither the CWF or FWF.
5
Licensing Overview (Cont.)
• The TCEQ recently amended RML R04100 toinclude a definition of “In-Transport”.include a definition of “In-Transport”.
– Minor amendment that was noticed for publiccomment in the Texas Register.
– The definition was based on a previous precedentfor Envirocare of Utah (EOU).for Envirocare of Utah (EOU).
– TCEQ and NRC discussed the approach before theamendment was approved.
6
License Condition 11.TDefinition of “In-Transport”
• SNM shipped to WCS by truck or rail is considered “In-Transport” and not possessed as long as the wasteTransport” and not possessed as long as the wastecontainers remain on the delivery conveyance incompliance with all DOT requirements.
• Waste received may be in transport for 14 days.• If weather or other unexpected events prevents the
disposal of waste on the day it is removed from theconveyance, the waste shipment may be placed again “intransport” for up to 2 days if placed onto the deliverytransport” for up to 2 days if placed onto the deliveryconveyance in a manner that satisfies all DOT regulationsfor transport.
7
Doug Frenette
Site Operations
Doug FrenetteDirector of Operations
8
WCS Site OperationsAerial Overview
9
Land Disposal Facility
• Land Disposal Facility – All land, buildings andstructures, and equipment which are intendedstructures, and equipment which are intendedto be used for the disposal of low-levelradioactive wastes into the subsurface of theland. For the purposes of the license, theterm shall mean both the Compact Wasteterm shall mean both the Compact WasteDisposal Facility and Federal Waste DisposalFacility.
10
Key Items to Note
• The CWF and FWF are 2 completely separate facilitiesand are just 2 parts of the entire WCS site.and are just 2 parts of the entire WCS site.
• A Disposal Unit (sometimes referred to as “DisposalCell”) is just a discrete portion of the land disposalfacility into which waste is placed for disposal. It is alarge below grade “pit.”
• There is a disposal unit at the CWF and anotherseparate disposal unit for the FWF.
• In addition to the disposal units, the CWF and FWF• In addition to the disposal units, the CWF and FWFeach have their own separate geographic footprint,Staging Building, Decontamination Building, WasteWater Treatment Plant, Stormwater Collection Tanksand Ponds and roadways.
11
Key Items to Note
• Containerized (Waste) – to be emplaced within a canister. Referringto the final disposal configuration that waste is placed into whenbeing disposed of. WCS uses a Modular Concrete Canister (MCC)being disposed of. WCS uses a Modular Concrete Canister (MCC)for disposing of containerized wastes.
• Modular Concrete Canister – a rectangular or cylindrical reinforcedconcrete container used as a disposal vessel for containerizedwaste. Waste containers are placed into these vault-like structuresand grouted with a low strength concrete mix to fully encapsulatethe waste into a solid concrete monolithic structure.
• Bulk Waste – Material that is soil or soil-like, debris, rubble, or asingle uniform piece that is qualified for disposal under the RML.single uniform piece that is qualified for disposal under the RML.
• The FWF has the ability to receive both Containerized and Bulkwaste whereas the CWF can only take Containerized waste.
12
Key Items to Note
• These facilities are designed and operated specificallyfor the purposes of waste disposal: not storage orfor the purposes of waste disposal: not storage ortreatment.
• They are designed for waste to be received, inspected,accepted and disposed of in a short period of time.The vast majority of shipments sent to the WCS’s landdisposal facility arrive and are disposed of in the sameday; usually in 2-4 hours.
• A normal day at the land disposal facility (CWF/FWF)• A normal day at the land disposal facility (CWF/FWF)will typically be comprised of 1-4 truck shipments.
• Unusually large or complex shipments have extensivepreplanning (in conjunction with our Regulator) well inadvance of it’s arrival.
13
Rail
• WCS owns and operates an ~11 mile private rail spur.
• The rail spur connects to the Texas New Mexico• The rail spur connects to the Texas New MexicoRailway (TNMR) ~ 7 miles to the west of the WCS site.
• The spur circles the entire WCS site.
• The rail spur is not part of and does not physicallyenter the land disposal facility at any time.
• WCS has it’s own locomotive and track mobile along• WCS has it’s own locomotive and track mobile alongwith qualified personnel to move rail cars on the WCSrail spur.
• Rail Cars with waste sent to WCS are delivered to thedrop off point at the rail spur 7 miles west of the site.
14
Rail
• Rail shipments to WCS are offloaded at acentral WCS site location (building) called thecentral WCS site location (building) called theRail Pedestal Unloading Building (RPUB).
• This building is not part of the land disposalfacility. Think of it as the “front gate” for railfacility. Think of it as the “front gate” for railat WCS. This is where all rail shipments to anyfacility at the WCS site arrive.
15
Waste Categories at the LDF
• There are 7 categories of low level radioactivewaste that is handled and disposed of at the WCSwaste that is handled and disposed of at the WCSland disposal facility:1. Containerized Soil or Soil-Like
2. Containerized Debris
3. Bulk Soil or Soil-Like
4. Bulk Debris4. Bulk Debris
5. High Dose Rate
6. Cask Waste
7. Large Component
16
Waste Categories at the LDF
• Each of the 7 categories of LLRW have specificprovisions and Regulatory criteria with which they areprovisions and Regulatory criteria with which they arereceived, handled, accepted and disposed of.
• Based on WCS industry knowledge and Generatorrequests, both Containerized Debris and Bulk Debriswill be the most frequently utilized Categories thatcontain high levels of SNM (meaning whole gramquantities).
• The waste category, type of conveyance, type of• The waste category, type of conveyance, type ofpackage/container and receiving facility (CWF/FWF) alldictate the steps and onsite locations required toreceive, accept and dispose of the waste. There aredifferences for each.
17
Scenarios
• Based on these inputs; there are 9 likely scenarios to focuson for the purposes of high SNM:on for the purposes of high SNM:1. Direct Shipment to CWF – Containerized Waste – Truck2. Direct Shipment to FWF – Containerized Waste – Truck3. Direct Shipment to FWF – Bulk Waste – Truck4. Direct Shipment to CWF – Containerized Waste – Rail5. Direct Shipment to FWF – Containerized Waste – Rail6. Direct Shipment to FWF – Bulk Waste – Rail7. Onsite Transfer from the TSDF to CWF – Containerized Waste7. Onsite Transfer from the TSDF to CWF – Containerized Waste
– Truck8. Onsite Transfer from the TSDF to FWF – Containerized Waste –
Truck9. Onsite Transfer from the TSDF to FWF – Bulk Waste - Truck
18
Scenario 1
19
Scenario 2
20
Scenario 3
21
Scenario 4
22
Scenario 5
23
Scenario 6
24
Scenario 7
25
Scenario 8
26
Scenario 9
27
Video
• Watch Video demonstrating 2 of the 9scenarios.scenarios.
28
Prior to defining “In Transit”
• Prior to TCEQ defining the term “In transit” inthe WCS RML R04100, WCS did not receivethe WCS RML R04100, WCS did not receivewaste shipments that collectively containedenough SNM to exceed above groundpossession limits.
29
Current Operational Practice
• Once WCS received the definition of “In Transit” inRML RO4100, WCS implemented a practice we refer toRML RO4100, WCS implemented a practice we refer toas “Load Management.”
• Load management is a practice of only removing aportion of a DOT shipment to the land disposal facilityfrom a conveyance to ensure that we never exceedSNM above ground possession limits.
• By the definition, WCS is only in possession of the SNMfor the purposes of above ground possession limitsfor the purposes of above ground possession limitsfrom the time a container is removed from the DOTconveyance (truck or rail) until it is disposed of (i.e.placed in it’s final location in the respective landdisposal facility disposal unit.)
30
Load Management
• During the shipping request stage (>5 days prior to ashipment coming to WCS), WCS evaluates eachshipment coming to WCS), WCS evaluates eachshipment for SNM.
• In additon to the shipment, WCS takes intoconsideration all SNM that is currently at the landdisposal facility in our possession as well as all othershipments scheduled for that day.
• If the Sum of Fractions is 0.95 or more. The SiteRadiation Safety Officer and Director of Operations areRadiation Safety Officer and Director of Operations areformally notified.
• Load Management is invoked.
31
Sum of Fractions
32
Load Management
• A load plan is requested from the generator priorto delivery showing the locations of containersto delivery showing the locations of containersplaced on the conveyance.
• The morning of the shipment the sameevaluation for SNM is performed. This time theycalculate SNM totals for individual containers andnot the entire shipment.not the entire shipment.
• They calculate removal of individual containerssuch that the Sum of Fractions is below 0.95.
33
Load Management
• Once the conveyance is at the receiving location,a Specialist controls the removal of eacha Specialist controls the removal of eachcontainer from the conveyance.
• The generator load plan helps with this since weknow what containers will be most accessiblewhen we open the conveyance.
• The Specialist in the field verifies the firstcontainer to be removed from the generator IDcontainer to be removed from the generator IDnumber on the container label and manifest.
• Using the Sum of Fractions again they verify byremoving it, we stay under 0.95.
34
Load Management
• The Specialist in the field then requests anindependent verification from another Specialistindependent verification from another Specialistwho performs the same calculation.
• If they concur, they give permission to removethe container.
• Once the container is removed from theconveyance, the SNM in that container is now inconveyance, the SNM in that container is now inour possession.
• WCS performs normal waste acceptance checksas part of the RML required for all waste.
35
Load Management
• Once those checks have been successfullycompleted for that container, disposal iscompleted for that container, disposal isapproved.
• The waste is transferred and placed in therespective disposal cell.
• Once the waste is documented as disposed of,WCS no longer has above ground possession ofWCS no longer has above ground possession ofthe SNM.
• A notification is made to the Specialist and theprocess is repeated for the remaining containers.
36
Load Management
Two important aspects of Load Management:
1. More than one container may be brought offthe conveyance as long as the Sum ofFractions stays below 0.95. (Containerscontainer varying amounts of SNM)
2. At no time has WCS been able to receive an2. At no time has WCS been able to receive anindividual container of waste that by itselfexceeds the above ground possession limits.
37
What we are requesting
• Rely on existing DOT regulations that currentlyallow for a shipment of waste containers thatallow for a shipment of waste containers thatcollectively exceed above ground possessionlimits to be received and disposed of in thesame manner.
• Any loading activity will be consistent with• Any loading activity will be consistent withpre-determined criticality safety evaluationsfor packages and package arrays
38
What we are requesting
• Example: if a conveyance of SNM bearingwaste containers (10 drums) is shippedwaste containers (10 drums) is shippedcompliantly to our site (road or rail) using DOTregulations, that collectively exceeds aboveground possession limits, we want the abilityto receive, accept, transfer into cell andto receive, accept, transfer into cell anddispose of the entire shipment- all at once.
39
Why
• The existing method of Load Management hasdrawbacks.drawbacks.
• It requires multiple iterations of handling andtransferring small populations of containers thatcould be completed in a more efficient manner.
• With fewer iterations the waste could bedisposed of in a more timely fashion.disposed of in a more timely fashion.
• Ultimately, the safest and most secureconfiguration of the waste is disposal - resting inone of our disposal cells entombed in concrete.
40
What happens for a delay?
• Weather and equipment issues are the biggestconcerns.concerns.
• As part of the definition of “In Transit”:– “…Waste received by the Licensee may be in transport
for up to 14 days. If weather or another unexpectedevent prevents the disposal of such waste on the dayit is removed from the conveyance, that wasteshipment may be placed again, “In Transport” for upshipment may be placed again, “In Transport” for upto 2 days if placed onto the delivery conveyance in amanner that satisfies all DOT regulations fortransport.”
41
Equipment
• Every piece of equipment at WCS is procured withreliability in mind and is part of a rigorous preventativereliability in mind and is part of a rigorous preventativemaintenance program.
• Each piece of equipment has a back up. In some cases,there are multiple back ups so there are no single pointfailures with regard to the equipment we have. Thisincludes the personnel who operate them.
• We also have numerous contracts with local equipmentrental companies to obtain a replacement in less than arental companies to obtain a replacement in less than aday.
• Equipment delays we’ve experienced are usually veryshort duration, typically less than an hour – just thetime it takes to get a back up from another area onsite.
42
Weather
• Weather – there are some weather conditionsthat have the potential to delay disposal.that have the potential to delay disposal.– High winds (shuts down crane operations for
placing waste in disposal cells; very high winds canresult in shut down of all outdoor work)
– Excessive rain (resulting in flooding of the disposalcells)cells)
– Lightning (shut down of all outdoor work)
– Ice or snow (creates hazardous road conditionsand precludes access to disposal cells)
43
High Winds
• Wind is typically predictable with normal weatherforecasting. WCS schedules work associated withforecasting. WCS schedules work associated withactivities to coincide with forecasts. Disposal activitiesare always the number one priority and areaccomplished first.
• In rare cases we have left conveyances In-Transport (atour site but without beginning the receipt process, i.e.unloading any waste containers) until winds subside.
• If receipt process has started, and winds surprise us,• If receipt process has started, and winds surprise us,we can leave the conveyance and waste containerssecured in our Staging Building .
• Typically this is for a few hours but no more than a day.
44
Excessive Rain
• Although west Texas is an arid climate, we doexperience rain, some years more than others.experience rain, some years more than others.
• A calm rain shower without lightning does notpreclude our operational outdoor activities.
• Rain with lightning will shut down all outdooractivities (due to lightning hazard; not rain)activities (due to lightning hazard; not rain)
• Excessive rain that floods the disposal unitshas implications.
45
Excessive Rain
• Our license does not allow for us to dispose ofLLRW in standing water in immediate vicinityLLRW in standing water in immediate vicinityof the waste placement activities . (Meaningwe can’t have equipment and personnelunloading transports in standing water, norcan we be placing waste in areas that arecan we be placing waste in areas that areflooded.)
• Sometimes this precludes activities as wepump out the storm water.
46
Excessive Rain
• Previously this weather phenomenon has impacted usthe most.the most.
• This aspect has greatly improved through experience,improved storm water removal equipment and the factwe now are working on top of the MCCs in the disposalcells – this keeps out of the very bottom of the cellwhere water pools.
• In addition, to the methods discussed in High Windswe have gone a step further for extreme cases of cellwe have gone a step further for extreme cases of cellflooding and contacted our customers to delayshipments to our site until disposal cells are pumpedout.
47
Lightning
• Lightning within the vicinity of the site will shutdown all outdoor activities.down all outdoor activities.
• With the advent of technology we have reliableand accurate means of tracking storms having thepotential for lightning at the site and plan ouractivities accordingly.
• Lightning delays have occurred in the past and• Lightning delays have occurred in the past andtypically last less than hour up to 3-4 hours.
• Provisions for dealing with delays because oflightning are identical to High Winds
48
Ice and Snow
• West Texas and the Andrews area receive measurablesnowfall very infrequently, usually 1-2 times a year (ifsnowfall very infrequently, usually 1-2 times a year (ifat all).
• Ice storms are slightly more prevalent depending onthe specific year.
• These conditions have the potential for WCS to restrictaccess to the disposal units due to hazardous roadconditions. Haul roads have a fairly steep grade.
• WCS has snow and ice removal equipment to quickly• WCS has snow and ice removal equipment to quicklyaddress icy or snow covered roads and resumeoperations in the disposal units. Operations have beendelayed a few hours but no more than a day. Samemeasures apply as discussed in High Winds.
49
Earl Easton
Regulatory and Technical Basis for theExemption Request
Earl Easton
50
Exemption Request
• Would allow WCS to possess under specified• Would allow WCS to possess under specifiedconditions waste containing SNM in quantitiesexceeding 10 CFR 150.11 without having toobtain an NRC license.
• Conditions based on maintaining aboveground SNM waste in packages approvedground SNM waste in packages approvedunder criticality safety requirements fortransportation until emplaced for disposal.
51
Need for Exemption
• Reduces number of shipments and handling ofwaste.
• Reduces number of shipments and handling ofwaste.
• Reduces burden and expense on commercialand DOE waste generators.
• Provides DOE a viable option to dispose oflegacy wastes.legacy wastes.
• Provides a logical transition from Federalregulation for transportation to Stateregulation for disposal.
52
Technical Basis
53
Technical Basis
• Exemption request will rely on transportationsafety regulations for on-site transfersafety regulations for on-site transfer– Packages and package marking and labelling
– Transport Index (TI) for dose control
– Criticality Safety Index (CSI) for fissile safety
– Non-exclusive use
• In addition WSC will control the transfer• In addition WSC will control the transferenvironment to lessen chance and severity ofmishaps.
54
General Marking Requirements forall Radioactive Material Packages
• Identification of Consignee /Consignor or both
• Proper shipping name (not forexcepted packages)
• UN Number
To: WSC
RadioactiveMaterial, Type APackage
UN 2915
• Gross mass (if >50 kg)
• Package Type (not forexcepted packages)
Paras. 531-537
UN 2915
55 kg
Type A
There are two factors indetermining category:
General Labelling Requirements forall Radioactive Material Packages
There are two factors indetermining category:
– Surface radiation level
– Transport Index (TI)( Ten times Dose Rate at 1 meter)( Ten times Dose Rate at 1 meter)
– TI is used to control dosesduring storage or transit
Fissile Material Label
• Fissile material label must appliedto packages containing fissile
FISSILE
CRITICALITY
to packages containing fissilematerial in quantities that are non-fissile exempt.
• A Criticality Safety Index must beentered on label
7
CRITICALITYSAFETY INDEX
entered on label
• CSI’s are used to ensure criticalitysafety in transport.
Criticality Safety for an IndividualPackage 10 CFR 71.55
A single package must remainA single package must remainsub-critical for both Normal andHypothetical Accident Conditions
Each package will be assigned aCriticality Safety Index (CSI) in
Keff < 0.95
58
CSI =5
Criticality Safety Index (CSI) inaccordance with 10 CFR Part 71. TheCSI is used to limit the number ofpackages shipped on a conveyance.
Criticality Safety Index10 CFR 71.59
59
Criticality Safety Index10 CFR 71.22
The CSI for packages shipped under a General LicenseThe CSI for packages shipped under a General Licenseis determined from following formula:
60
CSI = 10
Criticality Safety for Conveyance
The number of packages on aThe number of packages on aconveyance will be controlled bylimiting the sum of Criticality SafetyIndices to 50 (exclusive use).
For example, if the CSI for a package is 2, then
61
For example, if the CSI for a package is 2, then25 packages can be shipped on a single conveyance.This means that an array 50 undamaged packages mustbe shown to sub-critical under normal transportconditions, and 125 damaged packages must beshown to be sub-critical under hypothetical transportaccident conditions.
Example of How the Exemptionwould be Implemented
SNM wastes will be shippedSNM wastes will be shippedto WCS in an NRC certifiedpackage - CNS 10-160B
62
Individual waste containers would beunloaded from CNS 10-160B andloaded on a transfer vehicle providedthat:
The container design has been
Example of How the Exemptionwould be Implemented
The container design has beenanalyzed under 10 CFR 71.55.
The container design has beenassigned a CSI in accordance with 10CFR Part 71.
The sum of the CSI’s for all containers
63
The sum of the CSI’s for all containerson a conveyance does not exceed 50.
The containers are securely fastened toor within the conveyance.
Example of How the Exemptionwould be Implemented
For DOE wastes, the criticality safetyFor DOE wastes, the criticality safetyevaluation for the container and theassignment of a CSI would be based onthe safety analyses performed at DOEsites for on-site storage and transfer.
NRC package certification would not berequested for transfer packages as the packages
64
requested for transfer packages as the packageswould not be used in public transportation.
The on-site transfer would not be subject toDOT regulations as the packages would not beused in public transportation
Controls to be Exercised DuringOn Site Transfer
WCS will implement a number of additionalWCS will implement a number of additionalcontrols to enhance safety during on-sitetransfer:
• SMN wastes will remain in packages meeting NRCcriticality safety standards during on-site transfer.
• The number of packages on a transfer conveyance
65
• The number of packages on a transfer conveyancewill be limited by Criticality Safety Indicesdetermined in accordance with NRC regulations.
Controls to be Exercised DuringOn Site Transfer (Cont.)
• Transfers will only occur on dedicated roads.• Transfers will only occur on dedicated roads.
• The speed of transfer vehicles will be limited to 25miles per hour.
• All on-site transfers will be escorted.
• Access to transfer routes will be blocked duringtransfer.transfer.
• Only one transfer package will be opened at anyone time.
• Waste must be placed in a safe disposalconfiguration within 24 hours of transfer.
66
Discussion
67
