A02468, Comments on Draft Branch Technical Position Re Radwaste Classification
| ML20054F474 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 05/10/1982 |
| From: | Cagnetta J, Counsil W NORTHEAST UTILITIES |
| To: | Rich Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 A02468, A2468, NUDOCS 8206160458 | |
| Download: ML20054F474 (3) | |
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May 10, 1982 MM c73-5 Docket No. 50-213 50-245 50-336 A02468 Mr. R. Dale Smith, Chief Low-Level Waste Licensing Branch O
Division of Waste Managment U. S. Nuclear Regulatory Commission 6
Washington, D.C.
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dated March 31, 1982.
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Letter, W. G. Counsil to S. J. Chi,
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Dear Mr. Smith:
lladdam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1 and 2 Comments on D' raft NRC Branch Technical Position-on Radioactive Waste Classification Northeast Utilities Service Company, on behalf of Northeast Nuclear Energy Company and Connecticut Yankee Atomic Power Company offers the following comments on the DRAFT NRC Branch Technical Poaition (BTP) on Radioactive Waste Classification.
The three-tiered approach for measuring and reporting radioactivity in wastes from light water reactors appears to be a reasonable method for satisfying the proposed 10CFR61 requirment to classify wastes at nuclear power plants, llowever, review of the BTP indicates a number of areas which require improvement in order to provide an equitable waste classifi-cation system.
First, with respect to the three generic items which were requested to be addressed:
1.
The outlined three-tiered measurement system is reasonabic if applied on a case by case basis with due regard being given to proportionate costs vs. benefits.
2.
Practical ways in which the number of actual analyses will be minimized would be to implement on a waste stream specific basis which will then be subject to review by the NRC for acceptability pursuant to proposed 10CFR61.
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Comments pert,aining to the classification scheme and the ability to measure and quantify the radionuclides set forth in Table 1 of Section l
61.55 of the proposed 10CFR61 have been pre-l viously provided to NRC in Reference 2 (attached).
l Specific Comments on BTP Page 7, d. Measurement of Specific Radionuclides I
To avoid confusion and establish guidance, it may be beneficial to define the terms " routinely" and
" periodically", especially with respect to the frequency of sampling and measurement.
Page 8, last two sentences.
It could be difficult to develop scaling factors on a waste stream specific basis for cases in which many waste streams are mixed together (e.g. spent resin tank). 'Also, in regard to confirming the representativeness of scaling factors on at least a semi-annual basis, it should be kept in mind that certain wastes from some waste streams are not even shipped this frequently (e.g. fuel pool purification resins).
Page 9, first paragraph, last sentence.
The NRC should clarify th.at the provisions of this sentence apply'only to those radionuclides listed in Table 1 of 10CFR61 and not the entire list of fission
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and activation products which could be suspected to be contained within waste products.
Page 10, last paragraph.
Rather than specify the required sampling frequency on a time basis, the NRC should specify sampling on a periodic batch basis (e.g. once every 5 batches) to account for those cases noted in the comments con-cerning page 8.
Page 11, first paragraph.
The requirement to perform gamma spectroscopy measurements on each batch is too stringent. The cost of radiation exposures incurred in obtaining frequent samples should be weighed against the benefit of identifying slight varia-tions in gamma emitters.
Should you have any questions regarding our comments, please contact us.
Very truly yours, 1
NORTHEAST UTILITIES SERVICE COMPANY As Agent for Connecticut Yankee Atomic Power Company and Northeast Nuclear Energy Company i
(B. G. C ~ r W. G. Counsil Senior Vice President VA By:
J. V. Cagneyffa Vi e esident NMlear and Environmental Engineering t
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