ML20011E421
| ML20011E421 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1990 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20011E420 | List: |
| References | |
| REF-WM-3 NUDOCS 9002130383 | |
| Download: ML20011E421 (4) | |
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J MEM0 ADAVIS-1
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MEMORANDUM FORi A. Bert Davis, Regional Administrator i
. Region III fFROM:
. Robert M. Bernero, Director Office of Nuclear Material Safety
.and Safeguards
SUBJECT:
DRAFT PROPOSED ILLIN0IS DEPARTMENT OF NUCLEAR SAFETY REGULATION ENTITLED " STANDARDS FOR THE TREATMENT OF LOW-LEVEL RADI0 ACTIVE WASTE" This memorandum' transmits our comments on the above subject State of Illinois regulations. We have not provided detailed technical comments on these regulations because we think we should meet with Illinois after they receive-i the general comments listed below. Providing Standards or Rules for treatment of low-level. waste has proven to be a very complicated process for NRC and the existing sited: states (South Carolina, Nevada, and Washington). We would like to meet with Illinois and go over what our experience has been in this area and provide detailed comments'in-the meeting.
The' following are our general. connent.s:
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1..
The draft State regulations are'not clear on what role an engineered L
structure and/or waste _ from properties-are to provide 'the stability l
required by.10 CFR 61..We need tn understand where the state stands on
. this issue before we can provide mere detailed connents.
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2.
- We need to discuss what action, if any, Illinois will take'rega'rding NRC's current review procedures for handling waste form stability L
-approvals and-certifications (see enclosed review procedures for topical reports).
1 Many of the waste _ form criteria in the Illinois draft regulation appear-L 3.
L to be based on qualification and test criteria in the NRC Technical l
Position (TP) on Waste Form for 10 CFR Part 61.. We do not believe that L
the State of Illinois should use the TP on Waste Form as the basis for a
- regulation. This TP _is currently under review and we expect that changes will take place as new information on material testing and site performance is obtained.
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1 relay some of t is experience to Illinois in the proposed meeti Please
. advise us if<such a meeting can be arranged with the appropri e_IDNS staff.
RobertM.Bernero,Difectors:
Office of Nuclear M terial Safety; and Safeguards-
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Attachment:
As stated
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LSUBJEC ABSTRACT:. COP 94ENTS ON IL DEPT OF NUCLEAR SAFETY REGULATION i
p"TANDARDSFORTHETREATMENTOFLLRADWASTE" 10hc.:L
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-DATE:01/Ji/90
- 01/3[/90:0
/90:013g/90:Olgl/90 :01/ /90 :01/ /90
-0FFICIAL RECORD COPY t
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- MEMO ADAVIS 3
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l-h, MEMORANDUM FOR:
'A. Bert Davis, Regional Administrator-4 Region III 3:
_ FROM::
Robert M. Bernero, Director e
l Office of Nuclear Material l'
Safety and Safeguards SUBJECT-DRAFT PROPOSED ILLIN0IS DEPARTMENT OF NUCLEAR SAFETY l1 REGULATION ENTITLED " STANDARDS FOR THE TREATMENT OF LOW-LEVEL RADI0 ACTIVE WASTE"
( '
This memo transmits our comments on the above subject State of Illinois
. regulations. We have not-provided detailed technical comments on these regulations because we' think we should meet with Illinois after they receive-the general comments listed below..Providing Standards or Rules for treatment.
existing sited states'(proven to be a very complicated process for NRC and t of low-level waste has South Carolina, Nevada.and Washington). We would like
- to meet with Illinois and go over what our experience has been.in this' area and provide detailed comments in the meeting.
The following are-our. general comments.
p 1.-
The draft State regulations are not clear on what role an engineered 1
structure and/or waste from properties are to provide the stability required by 10 CFR 61. We.need to understand where the state stands on this issue before we can provide more detailed comments.
2.
We need to discuss what action, if any, Illinois will take regarding NRC's current review procedures for handling waste form stability
-l approvals and certifications -(see attached review proceduresL for topicalreports).
L I
3.
Many of the waste form criteria in the Illinois draft regulation appear L
to be based on qualification and test criteria in the NRC Technical Position on Waste Form (TP)'for 10 CFR Part 61. We'do not believe that the State of Illinois should use the Technical Position ar. Waste Form as the basis for a regulation. This technical position is currently under review and we expect that changes will take place as new information on i
material testing and site performance is obtained.
In summary, we agree with Illinois' intention to clarify for % generators what the waste acceptance criteria will be for its new facility. However, there are a number of potential pitfalls associated with specifying these criteria. We have had a few bad experiences in this area and we would like to I
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DRAFT PROPOSED IL DEPT OF NUCLEAR. SAFETY REGULATION.
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