ML031900362
| ML031900362 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/30/2003 |
| From: | Redeker S Sacramento Municipal Utility District (SMUD) |
| To: | NRC/SECY |
| Ngbea E S | |
| References | |
| -RFPFR, 68FR09595 02584, MPC&D: 03-078, PR-20 | |
| Download: ML031900362 (2) | |
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SMUn SACRAMENTO MUNICIPAL The Power To Do More' UTILITY DISTRICT PO. Box 15830, Sacramento, CA 95852-1830; 1-888-742-SMUD (7683)
DOCKETED MPC&D: 03-078 USNRC DOGV(6S7oNU 4.
July 2, 2003 (12:15PM)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF June 30, 2003 U.S. Nuclear Regulatory Commission ATITN: Rulemaking and Adjudications Staff Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 COMMENTS ON PROPOSED RULEMAKING ON CONTROLLING THE DISPOSITION OF SOLID MATERIALS ATTENTION: Rulemaking and Adjudications Staff The following discussion contains our comments on the NRC proposed rulemaking on controlling the disposition of solid materials. The Sacramento Municipal Utility district has been actively decommissioning the Rancho Seco Nuclear Plant since 1997. Much of the decommissioning and dismantlement work is separating the radioactive material from the non-radioactive material. This work is done in accordance with current I.E. Circular No. 81-07 and I.E. Information Notice No. 85-92. Any additional options for disposition of very low activity waste would enhance our ability to complete this decommissioning.
However, if those options were at the loss of our current clearance program, it would severely impact our completion cost and schedule.
The option of conditional use would likely be extremely burdensome unless some entity (such as DOE) took responsibility to assure material is not used for a prohibited purpose.
This would likely make the option prohibitively expensive.
The option of disposal in EPA regulated landfills is an alternative that should be explored for waste with activities up to some predetermined level as a cost-effective approach.
Waste processors in some states, such as Tennessee, are doing this with their own waste.
The WCS site in Texas is attempting to get a state license for just this approach and would be a cost-effective alternative for very low-level radioactive waste.
Rulemaking should continue to allow very low activity waste to be disposed of in RCRA licensed facilities but must be complemented by a cost effective clearance standard.
RANCHOSECO UScLEA GCA1 sEc'I-o2-RANCHO SECO NUCLEAR GENERATING STATION 0 14440Twin Cities Road, Herald, CA 95638-9799; (209) 333-2935
Rulemakine and Adiudications Staff MPC&D: 03-078 If you, or members of your staff, have questions requiring additional information or clarification, please contact Bob Jones at (916) 732-4843.
Sincerely, Steven J. Redeker, Manager Plant Closure and Decommissioning