ML20012D654
| ML20012D654 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1990 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shao L NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| FRN-57FR14500, REF-WM-3 AD33-1-109, NUDOCS 9003280194 | |
| Download: ML20012D654 (3) | |
Text
214.3/GWR/3/16/90
. ' MEMORANDUM FOR:- Lawrence C. Shao, Director E R 1 e 1990 Division of Engineering-
-Office of Nuclear Regulatory Research
.FROM:
Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
OFFICE COMMENTS ON A PROPOSED RULE TO IMPROVE LOW-LEVEL WASTE SHIPMENT MANIFEST INFORMATION AND REPORTING In regard to your February 28 memorandum, we concur on the proposed rulemaking, on condition of resolution of the enclosed comments.
In particular, we believe that the Federal' Register Notice should more specifically request public comment on the appropriate entity for operation and management of a national low-level waste computer data system. As part of this, both the Commission Paper and= Federal Reqister Notice should highlight the economic impacts.of developing and opera;ing a. national low-level waste computer data base. We also believe that it would be useful to cite the enclosed August 1988 letter from the Department of Energy (DOE).
In this letter, John Baublitz of DOE j '.
indicates t1at although he expects that DOE will have the resources to develop
.and maintain a national computer data system, the long-term goal of DOE's program.will be to eventually pass responsibility for maintaining the system to the States and Compacts.
If you have questions, the contact on nty staff is Mr. G. Roles (20595).
[
Orwnal egned by G. a. Arlano Robert M. Bernero, Director Office of Nuclear Material Safety l
and Safeguards v-
Enclosures:
I-1.
Rule' Comments-2.
8/88 DOE Letter Distribution: CINnal?M1eTM' I
NMSS r/f LLTB r/f GRoles RBoyle JSurmeier PLohaus JGreeves RBangart RBrowning RBurnett CMacDonald GPangburn MHaisfield
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-PDR No: /T/
Reason: Proprietary //
or CF Only /T/
ACNW ~
Yes: /
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No: /T/
L SUBJECT ABSTRACT: SEE SUBJECT OF MEMORANDUM
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- SEE PREVIOUS CONCURRENCE 9
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l 214.3/GWR/3/16/90 MEMORANDUll TOR:- Lawrence C. S1.60, Director n
Division of Engineering Office of-Nu:: lear Regulatory Research FROM:-
Robert M. Bernero, Director Office of Nuclear Material Safety-and Safeguards.
SUBJECT:
OFFICE COMMENTS ON A PROPOSED RULE TO IMPROVE LO -LEVEL WASTE-SHIPMENT MANIFEST INFORMATION AND REPORTING In regard to your February 28 memorandum, we concur on the-oposed rulemaking, on condition of resolution of the enclosed conrnents.
In ticular, we believe that the Federal Register Notice should more specifica11 request public comment on the appropriate entity for operation and manpgement of a national low-level waste computer data system. As part of thi V, both the Commission Paper and Federal Register Notice should highlight t 6 economic imaacts of developing and operating a national low-level waste computer data aase.
We also believe that it would be useful to cite the 9 closed August 1988-letter I
fromtheDe)artmentofEnergy(DOE).
In this let'ter, John Baublitz of DOE indicates tlat although he expects that DOE wi I have the resources to-develop and maintain a national computer data system, he long-term coal of DOE's program will be to eventually pass responsi lity for maintaining the system to-the States and Compacts.
If you have questions, the contact on n staff is Mr. G. Roles (20595).
Robert N. Bernero, Director f
Office of Nuclear Material Safety a d Safeguards
Enclosure:
~ Rule Consnents 8/88 DOE ltr.
Distribution:
Centr $ File # 21'f.3 NHSS r/f LLTB/r/f GRoles RBoyle JSurmeier PLohaus JGreeves RBatigart RBrowning RBurnett CMacDonald GPangburn l
MHaisfield
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Ye !/
/
PDR PDR No: /y /
Reason:
Proprietary /
/
or CF Only / >< /
ACHW Yes: /
/
No: /%/
SUBJECT ABSTRACT:
SEE SUBJECT OF MEMORANDUM l
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L NMSS Comments on Proposed Rule to Improve LLW Manifest Information and Reporting
- 1 1.
The Federal Register Notice (FRN) should specifically request public coment on the ap(LLW) computer data system.propriate entity to establish and o 1
low-level waste As part of this, both the l
Comission Paper and FRN should highlight the economic impacts and resource implications for developing and operating this system.. Although a DOE official has indicated that he expects that DOE will have the resources to develop and maintain a national LLW computer data system, the long-term goal of DOE's program will be to eventually pass responsibility g
for maintaining the system to the States and Compacts.
(See the August i
1988 letter from B qblitz, DOE, to Knapp.) Because this planned transfer of responsibility could occur before information in an electronic format is available from new disposal facilities, the possibility of operation of a national LLW data system by an entity other than DOE should be addressed more directly.
l.
2.
Earlier comitments to the rulemaking, either in earlier SECY papers or in NRC's five-year plan, should be referenced in the Comission Paper.
l 3.
Page 9 of the Paper (and p. 21 of the FRN) refers to a lack of disposal capacity for wastes from the State of Vermont, because of a failure by Vermont to comply with the governor certification provisions of the Amendments Act. This is not completely accurate. Although a number of States and entities have been barred from disposal at the Richland and p
Barnwell facilities, disposal capacity-is available at the Beatty facility-L until the end of 1992. We understand, however, that the-Vermont legislature has not yet approved the conditions of the disposal contract L
with Nevada. Although-Vermont licensees are currently storing LLW, L
temporary disposal capacity should eventually be available.
4.
On page 6 of the FRN, the second paragraph indicates that the Forum meets at least four times a year and is funded by DOE pursuant to the Amendments Act. We understand that although DOE originally funded the convocation of the Forum on a quarterly basis, starting in CY 1990 DOE only funds three meetings a year.
5.
On page 27 of the FRN, the second paragraph repeats the existing Part 20 requirement to identify the person transporting the waste "to the disposal facility." We suggest that the requirement shouldn't be limited to shipments to the disposal facility, but should be applicable to all shipments of LLW. The broadened requirement would be consistent with existing practice.
(Also change paragraph A(4) on p. 51 of the FRN.)
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.I Department of Energy Weeningpon, DC 30646
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e Mal olm'Knapp I
gg Division of Weste Management-
.U.S. Nuclear Regulatory Comission l
P SE4' Washington,'O.C. 20555
Dear Dr. Knapp:
F We understand that the Nuclear Regulatory Commission may be considerinapromulgationiofarulethatwouldrequire(NRC)levelwastedata low-to be furnished to the C8mmission and to Agreement State agencies in machine readable form.- We support this effort to improve accountability in
.the management of low-level waste.
~The NRC
- have bee,n frustrated for years by the difficulty in obtaining reliableth information on waste disposed at Government-owned,he proposed l-comercially operated low-level waste disposal-sites.
We believe that t provide significant benefits without imposing onerous new administrative burdens on State agencies or private entities.
In reaching this conclusion we note that many waste shippers, in preparing
-theircurrentshippinomanifests,leonatypewriter,wordprocessor,o that would-be requirea by this ru already " key in" much of the information Lin house computer. system. Following:that step data management efforts:in the three States with current 1 r operating dispo, sal sites vary markedly.
one case, the site ' operator re;nypes a portion of the' shipping manifest datt In into its own computer system, then provides a subset of the data in machine readable form to the State regulatorr agency, in another the site
. operator already has made arranaemen;us with its customers,to provide it shipping data in machine readable form. However it furnishes only paper L-copies of the shipping manifest to the State regu,latory agency.
We would not support this effort to improve low-level data management if we believed that the burdens of compliance outweiched the potential benefits to be gained. We have concluded, however that the proposed rule would not-significantly increase the level of efforl that goes into data collection, and may-even lessen the burdens of data management system-wide.
It is likely that disposal site operators would comply with such a regulation by requiring all their' customers to capture the manifest data in machine readable fom at the time they prepare the paper copy of their manifests.
This would not entail sophisticated data processing techniques, and as we have noted, many already do this.
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While.we support the p posed rulemaking, we are concerned that the L
proposed approach may s op short of requirin reement State agencies that would receive such disposal data to provide h data to the NRC for inclusion in a national database. Much of the rationale that would be
/f788 l oleman rovided b NRC for such a rulemakin would likely be based upon the need or compre ensive data about waste d sposed nationwide. Therefore, we 1-encoura you to explore wa s to ensure that there would be full 20 l
partici tion in the nation 1 database.
lit We expect that our Low-Level Radioactive Waste Management'Pr ran will have d 88 the resources to develop and maintain a computer system that ill support development of the national database. The long-term goal of the program however is eventuall to pass along responsibilities for management of,
coenorcIallygenerat low-level waste includin organizations and agencies that may be, created b data management, to the States and compacts to foster cooperation for the management of the ation's low level waste.
Current activities and future plans of our low-level waste proiram may be affected by the progrest of NRC in improving the collection anc management of informaSion on low-level waste.
Please kee L
of this effort and let us know if we can help.p us inferined of the progress Sincerely, 1
John E. Baublitz l
Acting Director i
i Office of Remedial Action i
and Waste Technology Office of Nuclear Energy NE-24:JColeman:1p:34728:8/5/88 IBM 82180023 DIST.
i Subject NE-24 rdr Coleman rdt NE-13(5)
Baublitt suspense bec:
- u. 5 ; berry, EGAG CORRESPONDENCE REVIEWER: AP l
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