Limiting Condition for Operation: TRU Waste Storage Facility MAR Inventory Control ACTION(s) - Continued

DOE-STD-1186-2004

LCO 3.3

The total quantity of containerized waste that can be stored in

WASTE STORAGE FACILITY is restricted to 2,000 plutonium-

239 equivalent curies. Compliance shall be demonstrated by

tracking the total quantity of nuclear material present within all

waste boxes and other containers.

The LCO set the initial MAR for accident scenarios that

involve the entire WASTE STORAGE FACILITY waste

inventory (i.e., major fire, seismic). The initial MAR

determination for these scenarios is based on projected waste

container loading to the Site 95th UCL + 20% values. Using

these values represents a very conservative MAR

determination for the entire WASTE STORAGE FACILITY

inventory.

The MAR loadings for the highest estimated single TRU

containers were used in the safety analysis for scenarios

involving just a few waste containers and are carried forward

as requirements. Compliance with these requirements can be

demonstrated by utilizing the Waste and Environmental

Management System (WEMS) database and process

knowledge, scan data, radiological surveys, or other

assessment methods indicating that the waste is TRU.

Therefore, WEMS must contain a curie value or a waste type

designation of TRU prior to acceptance of a container. High

Americium wastes do not fall in the category of TRU and are

not evaluated in this safety analysis.

MODE APPLICABILITY

Waste storage is the only activity conducted in the WASTE

STORAGE FACILITY.

ACTIONS A.1 and A.2

If WASTE STORAGE FACILITY exceeds the total quantity of

material permitted, the building shall be brought into

compliance to re-establish the assumptions of the WASTE

STORAGE FACILITY specific safety analyses. Compliance

may be re-established by removing container(s) from WASTE

STORAGE FACILITY, re-assay to obtain a more accurate

count, or expert review of an existing assay. Bringing WASTE

STORAGE FACILITY into compliance within 3 weeks is

required. Three weeks is considered adequate time for facility

management to identify, communicate with, and coordinate a

transfer to an appropriate on-site facility.1

Each facility must provide technically a defensible basis for Action Statement time limits based on analyses

performed for the respective LCOs and associated Action Statements.