ML20011E969

Summarizes 890627 Meeting in Region IV W/Representatives of State of UT Re Regulatory Jurisdiction Over Source Matl

ML20011E969
Person / Time
Issue date:	09/14/1989
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20011D107	List: ML20011D106 ML20011D123 ML20011E969
References
FOIA-89-542 NUDOCS 9002230223
Download: ML20011E969 (51)

Text

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MEMORANDUM FOR:

Robert M. Bernero, Director Office of Nuclear Material Safety & Safeguards i

FROM:

John M. Montgomery Acting Regional Administrator

SUBJECT:

ACCEPTANCE OF SOURCE MATERIAL AT URANIUM MILLS FOR PROCESSING AND DISPOSAL On June 27, 1989, a meeting was held in Region IV with representatives of the i

State of Utah and NRC concerning the regulatory jurisdiction over source material.

The meeting was the result of a number of discussions over the past several months' due to receipt of Teledyne Wah Chang source material from Grego for processing and disposal at the UNETC0 White Mesa uranium mill near Blanding, Utah.

The Wah Chang material is a waste stream from the production of zirconium anC contains recoverable amounts of uranium in excess of one-twentieth of 1 percem-(0.05 percent) of the mixture.

UMETC0 is requesting authorization to' process.

t this source material through their mill with the resulting. byproduct material being disposed of in the tailings impoundment pile.

It is the understanding o the State of Utah that UMETC0 will be compensated both by retention of the produced uranium and a tare payment by Wah Chang.

Utah has objected to NRC authorizing UMETC0 to process this material.

Their contention is that the actual purpose is to dispose of this material la the tailings pile under the guise of reprocessing it, as evidenced by the method o' compensation.

In addition, they also contend, based on their Agreement State agreement with NRC, that the Commission discontinued its regulatory authority in Utah with respect to source materials except where the Commission retained regulatory authority and responsibility with respect to regulation of (a) the extraction or concentration of source material from " source material cre" and the management and disposal of the resulting byproduct material as well as (b) the land disposal of source, byproduct and special nuclear material received from other persons. The primary issue with respect to (a), above, being whether the Wah Chang material is " source material ore."

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2 Shipment of the waste material to the site falls under 00T authority and, once received onsite, the material is under NRC authority.

Thorefore, the remaining issue is the question of NRC authority _to consider Introduction of this material into the mill material ore" nor " ore" process as source material cre.

Neither " source by itself is defined in the Atomic Energy Act of 1954, as amended (the Act), or the Commission's regulations." However, one of the meanings of the term "cre" as set forth in Webster's Third New International Dictionary is "a source from which valuable material is extracted."** If this were considered a secondary recovery operation, the resultant waste material could properly be classed as byproduct material and disposed of ir, the tailings pile.

For UNETC0, any action on their request is pending NRC determination that the material would not be classified as a mixed waste.

Chemical analyses revealed some constituents that may cause the waste to fall under CERCLA / RCRA regulations.

UMETC0 is presently working with EPA and Wah Chang to get that question resolved.

Wah Chang has suspended shipments of the material to UNETC0 until all the issues are resolved.

Of the total estimated volume of about 8000 cybic yards approximately 2000 cubic yards were delivered.

Relative to the volumeofmIlltailingsinthepile,thisWahChangwasteisnegligible.

The policy or precedent-setting issue that requires resolution is NRC's position regarding licensees accepting this type of material for processing at NRC-regulated uranium mills.

Preliminary discussions were held with Paul Lohaus of the Operations Branch, Low-Level Waste and Decommissioning Division, NMSS, on June 28, 1989, and again oi. August 10, 1989, with Paul Lohaus, Mike Fliegel and John Greeves.

This is not the first time that NRC has received inquiries about the processing of previously processed material through uranius mills.

These inquiries have ranged from scrap and wastes resulting from demolition of NARM contaminated buildings, to the Denver radium wastes, to raffinate pond residue from the Sequoyah Fuel Company facility at Gore, Oklahoma.

As you are aware, we have also recently received inquiries about disposal (not processing) of the sludge resulting from uranium / radius removed from eine water at a uranium eine, I

Related to this same case, the Bureau of Indian Affairs (81A) has recentl,y stated that one reason for the Spokane Indian Tribe to take over the Sherwood, l

Washington Mill is to process this same eine water through the mill, with the l

resultant waste going to the tailings tapoundment.

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" Unrefined and'enprocessed cre" is defined in 10 CFR 40.4 to mean ore in its l

natural fore prior to any processing such as grinding, roasting or j

benefeciating, or refining.

It is our understanding that this tem was defined for its use in Part 40.13.

• • It is worth noting that Byproduct Material is defined in Part 40.4 and in Section 11.e.(2) of the Act as meaning "the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content...." (emphasis added).

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3 Another case of interest to Utah is the radioactive soil from Maywood, New J6rsey (which has been defined by 00E as " byproduct material").

We understand that some interest has been expressed in disposing of this material at Plateau Resources Limited's Shootaring Canyon Mill at Ticaboo, Utah.

This was also the subject of a letter from Congressman Wayne Owens of Utah to Chairman Carr.

If this material meets the definition of byproduct material, we may be faced with a situation where the volume of material to be disposed is roughly 10 times the volume of mill tailings at the site.

Our policy in the past has been to allow disposal of byproduct generated offsite in a mill tailines pile if the volume was small in relation to the volume of mill tailings.

If the material is not '

byproduct material, as defined in Section 11.e.(2) of the Act, it may not be disposed of in the tailings pile without specific agreement from 00E that they would accept the site after license termination.

For the case of the contaminated scrap resulting from NARM contaminated buildings, our response was that such material was not acceptable because its physical nature would not allow processing through the mill and, furthensore, '

the source material content was negligible.

For the Sequoyah Fuels Company ;

raffinate pond material, it was determined that it was persissible to procese-it as " refined and processed cre" (copy of memo enclosed).

In another case, NRC authorized a mill to elute some'Jon exchange columns and to dispose of the spent resins.

For this case, the ion exchange columns were being used at domestic wells on the Navajo reservation to strip naturally occurring radium.

The action was considered as a public service since there was no place reasonably close to dispose of the material, and the volume was minuscule in comparison to the mill tailings.

There are other cases, but these are typical of the inquiries we have received.

As can be seen, NRC has dealt with the issue of the processing and disposal of I

material other than unrefined and unprocessed ore on a case-specific basis.

However, it is clear that guidance is needed so that both the Wah Chang issue and all future requests are handled consistently.

Accordingly, we suggest that what material may be accepted for disposal at a uranius mil tailings site be developed into a general NRC policy statement.

We will be happy t6 assist in this development.

Because of the continuing interest, including the Itcensees who foresee a potential for producing revenue, this policy statement should be developed as soon as feasible.

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t LLW F O R~U M Report of the Material vs. Waste Working Group i

to the Low Level Radioactive Waste Forum

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Background

On July 13,1989, the LLW Forum conducted a Seminar on Interregional Low Level Radioactive Waste (LLW) Treatment and Processing. The purpose of the seminar was to discuss the advantages and disadvantages of a national versus regional system for LLW treatment and processing and to identify other issues related to the interagional shipment of low level radioactive waste for treatment and processing.

As part of the seminar, several compact and state representatives prepared background papers which discussed current generator practices for classifying shipments to processors as either radioactive material or low level radioactive waste and which examined potential problems associated with these practices. Seminar participants expressed the following concerns and discussed their impacts on waste tracking capabitties, public acceptance and public health and safety.

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1) It is the generator's responsibility to determine the appropriate classification for radioactive material / waste being shipped off-site. If the generator is shipping directly to a disposal

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site, this determination is relatively simple as the shipment must be classified as waste and is manifested in accordance with requirements found in 10 GR Part 20.311. However, if a shipment is destined for a LLW xocessor, the generator may classify the shipment as either waste or material. Current;y, there are no federal or state guidelines on how generators should make this determination.

2) Due to inconsistent rectices and ambiguous situations, similar shipments to processing facilities have been c assified as waste in some cases and as material in others.

3) Shipments of radioactive materials to processing facilities are not subject to compact import and export controls which are only applicable to shipments of low-level rarlioactive waste to processing facilities.

4) Department of Transportation manifest requirements for shipments of radioactive material are slightly less comprehensive than the Nuclear Regulatory Commission's manifest requirements for low level radioactive waste.

5) LLW prr==s receiving shi nts of radioactive material must determine if portions of the material received are low-el radioactive waste or non hazardous solid waste or have some economic value allowing for retum, reuse, resale or recycle of the " product stream."

As a result, processors require generators to provide characterization data on shipments of material as well as waste. If the material / waste is inadequately characterized, the processor must adequately characterize the material / waste and ply manifest any resulting low-level radioactive waste requiring shipment for disposa-tm Lmt Padmmme Hius Fman h lI I

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Working Group-Appointed During the seminar discussion, a Working Group was appointed to examine current generator practices for classifying slupments to processing facilities as material or low-level radioacave waste and to identify potential problems associated with these practices. *lhe Working Group was also asked to suggest guidelines for generators to use in classifying shipments of material / waste to nocessing facilities. The Working Group was instructed to seek input on the guidelines from the iLW Forum, the Conference of Radiation Control Program Directors' E 5 Committee on LLW and the Nuclear Waste Brokers and Processors Association. Bill Dornsife (Pennsylvania), Jay Dunkleberger (New York) and Clark Bullard (Central Midwest Compact) agreed to serve on the Working Group.

Working Group Findings In subsequent discussions, the Working Group has determined that potential public health and safety problems resulting from inconsistencies m generator practices for classifymg shipments to processors have generally been avoided due to:

the proc,essors' requirements that shipments of radioactive material, as well as low level radioactive waste, be adequately characterized, the sited states' requirements that processors provide sufficient information to the current disposal site operators to ensure identification of the original waste generator, and the NRC's requirements that the processor remanifest the low level radioactive waste and cestify that it is accurately characterized.

While some generators are currently shipping radioactive materials to processing facilities which should be classified and shi health or safety problems c.pped as low level radioactive waste, it appears that no si

.rrently exist in these cases despite:

different regulatory requirements for shipping radioactive materials versus requirements for shipping low level radioactive waste or subsequent reclassification of radioactive material as low level radioactive waste made by

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processing faci 11tica.

Most or all of the shipments received by processing facilities which have been classified as radioactive material instead oflow level radioactive waste, ap to eventually be characterized and disposed of property. More quantitative information is to confirm this conclusion.

Nonetheless, the potential for generators to misclassify low level radioactive waste as radioactive material for shipment to a processing facility still exists due to inconsistencies in how generators classify and characterize individual s tipments. While misclassification is apparently not a problem from a public health and safety standpoint, these inconsistencies may, in the future, adversely affect a state's or compact's ability to track interregional material / waste shipments, to refilate the imp and export of waste and material that may eventuall,y be determined to be 'ow level radioactive waste and to ensure that LLW generated in a region is disposed of in that region's i

disposal facility, even if processed outside the region where generated. The classification of shipments to psors as radioactive material rather than low-level radioactive waste may also l

impair a state s or compact's ability to ensure that the shipment is adequately characterized and tracked. More information is needed to support the conclusion that public health and safety i

problems are not occurring due to generators classifying shipments to processors as radioactive material.

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c (Wor' king Group Recommendations To address these concems the Woddng Group recommends the following:

1) Guidelines should be developed to assist generators in more accurately and consistently classifying shipments of material / waste to processing facilities. 'Ihe guidelines proposed by the Workmg Group are summarized below.

2) NRC should consider issuing these guidelines to licensees and Agreement States in an information notice or through some attemative means.

3)' NRC should consider revising 10 GE Part 20.311(f)(2) to require facilities which process, repackage and remamfest lo'v level radioactive waste to identify the original-generator as part of the manifest accompanying the shipment to the disposal site. This revision will make the regulations consistent with current practices and existing host state requirements.

4) NRC should consider including, as part of its rulemaking on LLW data collection, the requirement for a uniform manifest to facilitate tracking low level mdioactive waste from the original generator through processing and stcrage facilities to disposal sites.

5) Processors should be contacted to determine if generators, by classifying shipments low-level radioactive waste as radioactive material results in inadequate or inaccurate characterization of the radiological and hazardous componcats of the material, thereby causing increased worker exposure or other regulatory problems for the processor.

Pro msed Working - Group Guidelines for Classifying Shipments to Processing Fac lities

'Itc Working Group's suggested guidelines to be used by. generators when classifyinJ shipments of radioactive material / waste to processing facilities are Listed below. These guidet.nes will be discussed and revised as necessary at the LLW Forum's October meeting. After the Forum meeting, the guidelines should be distributed to other interested parties for comments.

1) Contaminated substances or equipment bein shipped for decontamination should be charified as radioactive material, unless a of the shipment's content by weight will L

not be returned to the generator, reused, recyc or sold u uncontaminated material. Any material which cannot x decontaminated should be considered low level radioactive waste and attributed to the original generator for disposal. Any low level radioactive waste resulting from the decontamination process, which cannot be attributed to the original i

generator, should be ena=id-ed the processing facility's low-level radioactive waste.

2) Shipments going to processing facilities for separation, volume reduction (incineration or compaction) or other trearmant should be classified as low-level radioactive waste, unless a majority of the material can be returned, reused, recycled or sold.

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3) Shipments of contamiantad packaging materials should be cantidaed low-level radiMve waste for purposes of tracking its mport and export, even if the materials are to be used as H

part of the processor's waste stabilization media. The eventual disposal of this material once incmyorsted in the waste form, should be negotiated by the compact or state of origin with the processor and the compact or state in which the processor is located.

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4) Shipments of scaled sources to manufacturers or other facilities for reuse or recycling purposes should be classified as a radioactive material.

- Future Considerations Several other considerations were identified by the Working Group pertaining to the post 1992 management of LLW for discussion at the October Forum meeting.

1) Consistency in classifying shipments of materials / waste from generators to processors will facilitate the tracking of interregional shipments and will assist in promoting and implementing agreements among compacts and states regarding the import and export of LLW for treatment and processing and the eventual return of LLW to the compact or state of origin for ultimate disposal Campe and states should begin negotiating agreements to l

facilitate interregional LLW treatment and processing and the return of LLW for disposal to the compact or state of origin regardless of where the material was determined to be a LLW.

2) One Working Group member suggested the need for a more uniform national definidon of low-level radioactive _ waste to facilitate and ensure adec uate tracidn.g of interregional shipments to processing facilities, ne member recommenced that this d efinition be based on the type of facility receiving the shipment, with exempdons for certain items shipped for i

decontamination that will be returned to the point of origin for reuse. Other types of shipments could be exempted as necessary to facilitate decontamination and recovery of usable material using new technologies. In the member's opihion, this approach will aid in l

defining what material / waste will be tracked interregionally by states and compacts, thereby I

improvmg the accountability and veracity of the tracking system as more shipments would 1

enter the system at an earlier point in the process.

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3) While the Working Group concluded that generators need guidelines to most consistently j

classify shipments of material / waste to processing facilities, questions were raised i

L regardmg differences in transportation requirements resulting from generators classifying l

shipments to processing facilities as waste rather than material. In practice, radioacuve l

materials are transported by DOT " common carriers," while shipments of low-level radioactive waste jencrally are transported by " contract carriers." nese questions should L

be investigated to cetermine regulatory and practical impacts on generator transportation options which may result t w implementation of the Working Group's suggested guiAslinme_

4) Methods for allocating LLW processing or treatment by-product residues, such as process liquids and filters, back to the origina, generator should be investigated. Under current sractices of not allocating process waste or treatment rdAm. certain states or regions may se required to dispose of rels,tively large percentages of the LLW resulting from treatment and g-x='ag facilities.

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5) In addition to making material / waste determinations more consistent and uniform nadonwide, generators need to more accurately characterize LLW shipments to processing facilities, a=padaHy in terms of radionuclide concentration data and identification of mixed waste. State and com sact officials should e===lan current contractual arrangements between generators anc. processors pertaining so material / waste characterization. Based on this nammerina, state and compact officials may need to investigate methods for ensuring i

better characterization of shipments between generators and processors if current practices are determined to be inadequate.

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6) Different M policies and replations may apply to used radiophannaceuticals shipped -

to the manufacunw or other facilldes fw storage tw decay dependng on whether they are classined as radioacdve material or low level radioactive wases, While two members of the

t Working Group felt these shipments should be classified as a waste, the other suggested l

that a nadonal consensus on how these shipments will be classified is needed before recommending a guideline. As a result, it was suggested that LLW Forum discuss this item collectivel before Inoposing a guideline. There as little or no question that shi xnents of '

newly-uced radotsotopes to users should be classified as radioactive materia.

9/15/89 4

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AGENDA i

BGV PLASAR REVIEW KICK 0FF MEETING 7/20/89 1.

Introductory Remarks (1:30 pe)

A.

Welcome Surmeier/Tokar 8.

Overall Task C. 'ObjectivesofReview D.

SFaC

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SRP F.

Acceptance Criteria II. Nature of PLASAR for 86V A.

Sections to be reviewed Kane B.

Sections receiving little/no review III. Anticipated Products A.

Q-l's & Comments Kane B.

Safety Evaluation Status Report (SESR)

C.

Recommendations for SRP/SF4C Revisions IV. Conduct of Review A.

Milestones / Schedule Kane 8.

Review Responsibilities C.

Logistics 1.

Coordination 2.

Communications (Written & Verbal) 1 VI. Adjournment 6

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STANDARD FORMAT & CONTENT '(NUREG-1199) i 1.

TELLS THE APPUCANT WDMT INFORMATION TO PROVIDE IN THE i

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ADW FORMAT POR PRESS 4TWO THE INFORMATION.

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HE1PS ENSURE TDET THE SAR CONTAINS THE INFORMATION REQUIRED sv io cPn P=t ei.

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AIDS THE APPUCANT AND fetC STAFF IN ENSURING THAT THE DFOImmilON IS COMPLEM.

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NEtes PensONs REAomeo THE sAR To toCan evoRunviON.

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CONTNSUTES TOWARD EFFICIENCY IN THE REVIEW PROCESS.

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ACCEPTANCE CRITIRIA 4.1 Manulaterv Raauirementa Cites applicable sections of Part 61 or other regulations 4.2. Ranulaterv auidanea Cites applicable Regulatory Guideo (if any)

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Contains the actual acceptance criteria h

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ARE ADEQUMLY SUPPORND BV OATA' AND ANALYSES.

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. WP 0 81989 Midwest Interstate Low Level Radioactive Waste Commission Room 588-

• 350 N. Robert Street

• St. Paul, MN 55101 *-(012) 293 0128, A

Soptember 6,: '1989 MD.-Elaine Carlin Low-Level-Waste Management Program

-Dopartment of-Ecology-

Mail Stop'PV-ll'

' Olympia, WA 98504

Dear Ms. Carlin:

At t the July Low-Level: Radioactive Waste Forum meeting, the Sited

states indicated their willingness to review draft Governors' Cortification

-documentation in advance of its formal submission later this year.

The Midwest Compact Commission would like to.take odvantage-of.this opportunity, and has-enclosed the documentation provided by each of its member states.

I-Ao'e'.first step-in the certification process, our states agreed.thet 1

-the generators would be responsible for. management and storage'of weste between January 1, 1993.and May 1, 1999,.when Michigan expects to begin. operation of its containment facility.. (Deferral of rosponsibility-to generators is provided for in Section 5(d)(2)(C)(ii) of the-. Low-Level Radioactive.Weste Policy Amendments

Act of-1985.) ! Recognizing tho' possibility of deley, - however,- the compact. conservative 1y' extended the period until : January 1, 1996.

In January of this year, the Commission approved a pocket of oxplanatory~ material, a model licensee survey, and-schedules that ooch-state would use in preparing the necessary documentation.

The echedules carefully tracked the: guidance'available et that_ time-from t.he Nuclear Regulatory Commission (NRC) and the Sited States.

The

'pccket ensured that all of.the states were fully informed of'the

. guidance.

It also provided a framework for development of regione@ly consistent information that. met the guidance requirements.

Ucing lists-provided by the NRC or the appropriate agreement state-l 7

agency, surveys were mailed to licensees.- Each state prepared Scheduls #1 using information from the surveys.

If Schedule #2

-indicated a lack of utorage capacity for waste generated-during the r

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-interim _ period, licensees were asked to describe their' plans to p_.

provide for the necessary storage on Schedules #3 and #4.

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Wo wish to note the following with regard to the enciesed

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1) It is based on the information provided to our states by the licensees.

-2) Our states will not take title to, posseaaion of, or assume liability for wasta.during the interim period.

3) The length of the interim period is was based on operation of 3

a new compact fac111ty on, or before, January 1, 1996.

4) In estimating volumes, the current federal regulatory tramework was assumed to remain unchanged.

Also, it wee assumed that the licensees will obtain the necessary permits or approvala and the NRC will have sufficient resources to respond in a timely manner.

Our states have no enforcement authority regarding the licensee description of actions that will be taken.

5) A serious, unforeseen accident or emergency could result in waste volumes that exceed the contingencies that licensees have incorporated'into their storage plans.

By November 30, the Compact intends to have Governore' signatures on p

-c joint letter. certifying that the states will be capable of managing.

ond storing waste after December 31, 1993.

Pending the outcome of your review, we, expect to formully submit the certification and cupporting documentation to you and the NRC at that time.

If you have any-questions regarding the enclosed documentation, please do no sitate to contact me.

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reg arson Executive Director j) j; i

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soo, m h..a m.isei soo s mee sue c.e.a clay, Mme serie Telephone (704) 445 4449 September 26, 1989 Mr. Gregg Larson Executive Director Midwest Low-Level Radioactive Waste compact commission I'l 350 North Robert, Room 548 St. Paul, Minnesota 55101 j

Dear Mr.

T. arson:

The following information is provided in response to your lettetr of September 6,1989, and our subsequent telephone conversation of Il 1

september 13, 1989.

u As you have been advised,.tha sited states are currently reviewirup the -draf t materials which ' outline the ~ Midwest Compaat's interim l

That review should _

-l plan to deal with post-1993 radioactive waste.

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l be complete-within the next-ten days.

l In our telephone conversation, you requested an earlier-response on the adequacy of your september e cover letter to serve as the c

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for a covernor's-certification document.

The sited states basis are pleased to provide you with the results of our analysis.

A majer concern lies with your interpretation of sections 5 (4) (3) (C) (ii) and 5 (e) (1) (C) (11) of the Low-Level Radioactive l

Waste Policy Act Amendments of 1985.

It is true that states may, in 1993, elect not to take title to, take possession of, and assume liability for waste generated post-can be legiti-However, nothing in Section 5(d1 (2)(C)(11) l 1992..

mately construed to obviate the responshbility of each Covernor to describe state actions to ensure the appropriate management of waste after December-31, 1992.

It is particularly noteworthy that liemility in the Act refers to 1.ncurred by such responsibility for " damages directly or indirect 1/

generator or owner as a consequence of the failure of the State to take possession of the waste."

(See section 5(d)(2)(C)(1).)

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Mr. Gregg Larson Page Two september 26, 1989 7:lecting not to assume liability for damages in no way absolves the covernor of each state tros responsibility to ensure that i

.edequate capacity will exist to appropriately manage the waste.

it is also important to note that section $ (d) (2) (c) (ii) only 1

addresses the issue of title and possession of waste within the context of repayment or previously collected surcharges to generators, such a provision cannot be construed out of contert to modify the plain language of section s (e) (1) (c) (ii).

section 5 (e) (1) (c) (ii) is clear on its face.

"The covernor 6 4 provide a written certification...that such Alais will be capathe or providing for, and will provide for, the storage, dieposal, er management of... waste generated within such State...and include a description of the actions that will be taken to ensure that such capacity exists."

(Emphasis added.)

In your letter, you point out that your member states have "no enforcement authority regarding the licenses description of actions that will be taken."

That statement is irrelevant to the require-nonts of Section 5 (e) (1) (C) (ii),

which clearly mandate the Goverppr, not the licensee, describe the actions necessary to guarantee adequate waste management capacity.

Buttressing the clear language of section 5(e) (1)(c) (ii) is the october 22, 1985, report of thw committee on Interior and Insular Affairs which accompanied MR 1083.

That report also calls special attention to the need for the gigit to provide for the management or waste, it disposal capacity was not available on January 1,

1903.

(See attached.)

It is the currently stated intent of Midwest compact member states to temporarily require generators to store or ot serwise manage the

-waste they generate after Dwuwmber 31, 1993.

In order to subm(t a Governor's certification which meets the requirements of Section 5(e) (1) (C) (ii), each Governor must describe the atAla actions that j

will ensure the generators do, in fact, adequately and appropriate-ly manage the waste.

oivon the inaiviauality 11xely to be required of each Governor's/ state's actions, it is highly improbable that a joint certification letter would be acceptable as outlined in your letter of september 6, 1989.

l Toward that end, snam of the possible actions which would markedly strengthen your proposed certification would include descriptions et state actions to:

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Mr. Gregg I, arson Page Three i

september.as, inst K'

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(1) verify and document the existence of required regulatosfy approvals for generators who maintain they possess the authority and capacity to manage their own waste.

(a) verity.and document that generater proposaie to acquire the authority and/or capacity to manage their waste age i

feasible and consistant with existing regulatomy I

requiremente.

(3) verify and document that such generator proposel's identlfy the personnel accountable for ibplementatiott, the specific actione to be taken. and the timetabiqs

-[

necessary to provide for waste management ne later then January 1, 1993.

(4)

Provide assurances that necessary state funding will he requested by the Governor, or otherwise available, t e support.the waste management plan of any state-funded waste generator (i.e., state Univoreity programs, etc. ).

(5)

Identify the specific monitoring authority, ef forte arid timetables to verity gunerator progress toward finalis -

tion _of their waste management proposals.

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. authority exists, develop the plan and timetable fr establishing such an auenority.

(6)

Identify the time f rames and authority for developirig

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specific contingency pian (e) to be implemented by the state to manage waste of generators who finit to achiede i

their own waste management capacity /authowity.

Examples would ihclude establishing' backup plans for hospitale tio have access to each other s waste storagp especity, qr a

state contract with a broker for interin vastle management.

l-

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Ensure that an authority tocountable to the dovernor is,.

or will be, in place to ensure timely implementation of the state actione and any needed contingency plan.

As further clarification, it is recognised that not all of'the I

verification and accumentation efforts need be completed by 1/1/90.

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Mowever, Governor's certification documents should outline the process and timetables for completing same.

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september 24, 1989 j

i Jt ja hoped that the information and' comments providea will.be of 1

value to your compact member states in their ef forts to fully cor. ply.witt the requirements of section 5(o) (1) (c) (11).

sincerely, l

orr oriepentrog,- irector l"

Department of Human Resources j

State of Nevada l

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5 Y *44 STAFF MEETING ON LOW LEVEL WASTE 4

GOVERNOI'S CONFERENCE BOON STATE OF ILLINDIS CENTER

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CEICA00, ILLINDIS OCTORER 12, 1989 AGEED4 10:00 a.m.

Welcome and Revied of the Agenda l

Jonathan Lash, Vermont Frank Murray, New York 10:30 a.m.

Background and Status Report on Low Level Waste Policy Act Holmes Brown, Afton Associates i

11:00 a.m.

Low Level Waste Classification Paul Lohaus, Fred Comba Nuclear Regulatory Commission 11:30 a.m.

Discussion of Conceras I

l Diane D'Arrigo, Nuclear Information and Resource

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Services j

12:00 Lunch (On Tour Own)

A variety of good eating establishments are located in the lower level of the State of Illinois Center J

1:00 p.m.

Discussion of State Concerns 2:00 p.m.

Discussion of Bart Steps o

Should staff develop a policy position or amendment for the Governors' consideration at the upcoming NGA meetinst o

If so, should a work group be formed to de-velop a specific proposalf 3:00 p.m.

Concluding Remarks and Adjoura Jonathan Lash l

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STATE OF NEVADA STATE OF SOUTH CAROLINA i

STATE OF WASHINGTON October 12,1989 i

The Honorable Madeleine Munin, Chair Committee on Energy and Environment i

National Governors Auociation I

444 North Capitol Street, NW Washington, D.C. 20001

Dear Governor Kunin:

Our states, Nevada, South Carolina and Washington, have disposed of most of the country's civilian low level radioactive wastes for the past quarter century. We each have cartied additional burdens of federal l

radioactive wastes as well. That's why we supported pauage of the Low level Radioactive Waste Policy Act of 1980, and its strengthening in 1985. We continue to support the underlying principle of the Act that states and regions should assume responsibility for disposal of the low level radioactive wastes generated within their borders and providing manifold benefits to their citizens.

We believe the policy is working well. As the Act's 1990 milestone draws near, we expect most of our colleagues will certify that they now have political and technical proceues in place that will achieve the goal of the Act in a timely way. Two or three new regionallow level disposal sites are expected to have license i

applications developed to meet the milestone.

We recognize that the Act is likely to cause some streu and strain along the way. However, it is working..

working as Congreu intended to encourage better waste management and equitable distribution of waste disposal burdens. We oppose any action by the National Governors Association that suggests Congreu should reopen the National Low level Radioactive Waste Policy Am.

Sincerely, O

UpQ. L 21.

CARROLL A. CAMPBEIK_JR.

w Governor of South Carolina d

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RSLO COUNTERPART MEETING AGENDA OCTOBER 16-17. 1989 Rockville. Maryland October 16 - Monday B.13 WFN Conference Room i

1:00 p.m.

Regional and Headquarters Updates 3:00 p.m.

Break 3:15 p.m.

Connunicating with the States 3:45 p.m.

Discussion with Harold Denton-GPA 4:15 p.m.

Status Report on Decomissioning issues - Mike Bell-LLW 2.F 21 October 17 - Tuesday BrD WFN Conference Room 8:30 a.m.

Discussion of Pending LLW Issues - Paul Lohaus-LLW l

Governors' certification Storage options Mixed waste Technical assistance in support of licensing (PLASAR)

Greater than Class C Electronic Manifest Rulemaking EPA Proposed LLW Standard Reassertion of Regulatory Authority for Onsite Disposal 10:00 a.m.

Break j

10:15 a.m.

Continuation of LLW !ssues RiskCommunication(Salomon) i 11:00 a.m.

Status of BRC - Bill Lahs-RES Noon Lunch L

1:00 p.m.

Implementation of Policy Statement on Cooperation with States Implementation Guidance I

Further Action involving MOU's LLW Agreements ERDS MOU's 3:45 p.m.

Meeting with Commissioner James Curtiss F-1 l

-