ML060480401
| ML060480401 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032, PROJ0736, PROJ0735 |
| Issue date: | 02/02/2006 |
| From: | Pettiette P Washington Closure Hanford |
| To: | Anna Bradford NRC/ADM/DAS/RDB |
| References | |
| 70FR74846 00006 | |
| Download: ML060480401 (3) | |
Text
RULES <, CTIVES 1 , I Washington FEB - 2 2006 126030 1 ', E 1 pp . 08 Closure ? ?Fr Hanford lW14let-U. S. Nuclear Regulatory Commission Ms. Anna Bradford RFK V /nTZ Ifr /CY4 Chief, Rules Review and Directives Branch Mail Stop T6-D59 Washington, D.C. 20555-0001
Subject:
DRAFT INTERIM CONCENTRATION AVERAGING GUIDANCE FOR WASTE DETERMINATIONS, 70 FEDERAL REGISTER 74846, DECEMBER 16., 2005, DOCKET NO. PROJ0735, PROJ0736, POOM-32
Reference:
Letter, L. W. Camper, U.S. Nuclear Regulatory Commission, to C. E. Anderson, U.S. Department of Energy, "Draft Interim Guidance on Concentration Averaging or Waste Determinations," dated December 5, 2005
Dear Ms. Bradford:
In the subject Federal Register notice, the U.S. Nuclear Regulatory Commission (NRC) solicited comments on draft interim guidance on concentration averaging. Washington Closure Hanford LLC (WCH) has reviewed the guidance, and believes that additional clarification is needed regarding the intended scope and applicability of the guidance.
Based on the discussion in the "Background" section of the Federal Register notice and information contained in associated correspondence (e.g., Mr. L. W. Camper, I S. Nuclear Regulatory Commission, to Mr. C. E. Anderson, U.S. Department of Energy. Draft Interim Guidance on ConcentrationAvera;gingfor W'aste Determinations, December 5, 2005), the guidance was developed in response to provisions in Section 3116 of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005. Section 3116 was developed to address high-level waste determinations associated with waste in underground tanks. Based on this limited scope of Section 3116, it should be clarified that the guidance is intended only for making determinations in the context of high-level waste in tanks and associated support equipment.
WCH is responsible for managing the Hanford River Corridor Contract, which includes facility and below-ground waste remediation under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as well as management of the Environmental Restoration Disposal Facility (ERDF), a disposal facility for waste generated by CERCLA cleanup actions at the Hanford Site. WCH is concerned that, as currently written, the interim concentration averaging guidance could be interpreted in a 3070 Gerg Wasingo ae (509 375-464 Washington Closure Hanford 3070 George Washington Way tel (509) 375- 4640 Richiand, WA 99354 fax (509) 375- 4644 d10PP/ . . 'em0)
FED -220 126030 Ms. Bradford Page 2 manner that adversely impacts safe, cost-.effective remediation of radioactively contaminated waste sites.
Without additional clarification, the guidance could result in classification of traditionally low-level waste (based on the NRC's 1995 Branch Technical Position on Concentration Averaging and Encapsulation) as high-level or transuranic waste. Such a consequence could occur, for example, if the approach for evaluating "thin layers of contamination on vertical surfaces" is applied to residual contamination on underground vaults that require grouting, in contrast to the conclusions that would be reached based on the "solidified mass" approach established in the 1995 Branch Technical Position.
In order to avoid unintended consequences of the draft interim concentration guidance, WCH requests that the final guidance be revised to clarify the following points:
- The guidance is intended only for high-level waste determinations, and is not meant to supersede the 1995 Branch Technical Position
- The guidance is intended only to address high-level waste within underground storage tanks and associated support equipment planned for abandonment in place, or to waste removed from such tanks and equipment for treatment and disposal in a near surface disposal facility WCH recognizes the importance of this draft guidance and appreciates the opportunity NRC has provided for public comment. If you have any questions on the information submitted in this letter, please feel free to contact Mr. Jeff James on (509) 373-3228.
Sinceey I P. L Pettiette President & Project Manager BLV:neb cc: D.H. Butler (WCH) HO-19
CORRESPONDENCE
SUMMARY
FORM Subject/Title: Draft Interim Concentration Date Submitted Required Issue Date Averaging Guidance for Waste Determination 01/26/2006 1/30/2006 Preparer: Barry Vedder
Purpose:
Provide comments to Concurrence (initial and date):
Nuclear Regulatory commission on scope of draft guidance on concentration averaging. C] Project Services Date 0 ESH&Q (Meyer) Date
-Issued in response to: -,
Federal Register notice. C Project Integration Date El Engineering Date Additional concurrences (organization, initial, date)
Relevant background/additional context: 0 C.Kennedy Date )__6__ _
If improperly interpreted by regulatory agencies, guidance could adversely impact RCC work by causing low-level ED R. Landon A - Date IZ>6 i0 C waste (under current guidance) to be high-level or transuranic waste. 0 R.McPherson Date I 3cI.C Comments request that scope of guidance be clarified in final version to X J. James Date 1/S°/06 address this concern X K. Fecht Date WCH-DC-040 (10/31/2005)