ML20024B869
| ML20024B869 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 01/13/1983 |
| From: | Casey Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hobbs T NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| References | |
| NUDOCS 8307110623 | |
| Download: ML20024B869 (2) | |
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" Return to NMSS/SGFF, Mail Stop 881-SS" DISTRIBUTION:
PDR JAN 131983 Docket file 70-398 x
Case file NMSS r/f SGFF:DPJ 70-398 SGFF r/f s/f CRONO NMCL r/f i
U.S. Departrent of Correrce CNSmith l
National Bureau of Standards GGundersen ATTN: Pr. Thomas G. Hobbs, Chief DWeiss liealth Physics LICobb, IE t
i Roon C125 ATGody, RI Fullding 245
_.. ashington, DC 20234 W
Gentleeen:
The purpose of this letter is to clarify safeguards licensing policy with respect to the inventory requirements of SW1 contained in liquid and solid waste naterials stored at a licensee's site. There has been sone question as to whether waste materials (primarily liquid waste) need to be stored within an FPA/ICA. Additionally, we have required solid wasto containers
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to remato as part of the book inventory and to be verified at the time of
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physical inventory until they are shipped to burial, while liquid waste stored on site was not regarded as a component of inventory.
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To clarify our safeguards licensing criteria relative to weste materials, the following points are being provided for your infornation.
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o Liquid and solid waste materials that have been measured and declared i
as waste discards, but renain on site awaiting final off-site disposition, need not be stored within an ICA or PSA provided the arrangerients satisfy any relevant physical protection, health-safety, and/or international requirements.
o Waste discards (both solid and liquid) stored on site need not be j
subject to the inventory requirements of '10 CFR 70.51(d), (e), or (f),
provided such waste has been formally transferred to a holding account (the waste material has been transferred from the accounting book record to a site holding account record) using a NRC Form 741.
o Weste materials (solid or liquid) which are stored on site, but l
which have not been declared as discards and transferred to a holding account, e:ust be-located within an MBA or ICA and shall be included within the material balances obtained by physical i
inventories. Powever, liquid waste stored in lagoons, ponds, etc, need not be measured at the time of physical inventory, provided the inventory listing value for such liquid waste is based on the surwatinn of waste tank accountability batch reasurements discharged l
to the lagoon, pond, etc. ninus any neasured quantity of SMt renoved j
fron the lagoon.
l 8307110623 830113 PDR ADOCK 07000398 C
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2-JAN 131883 Although the above criteria does not preclude the storage of holding account waste discards within an ICA or NBA, we suggest that they not be stored in such areas, if possible, so as to avoid confusion over which items or materials must be inventoried.
Licensees desiring to take advantage of the criteria stated above should submit a request for an exception to the requinnents of 10 CFR 70.51(e)(2) or 70.51(d) as they pertain to waste discards placed in holding accounts, and/or an exception from 70.51(f)(3)(ii) with respect to liquid waste stored in ponds or lagoons that is not part of a holding account.
Appropriate revisions to the FNMC Plan should be submitted as part of your request.
Additionally, licensees who wish to store holding account waste discard material in an area not designated as an MBA or ICA, and who currently do not have a statement to this effect in their FNMC Plan, should submit a revision to their Plan.
All Plan revisions associated with any of the above mentioned criteria would not qualify as 10 CFR 70.32(c) changes.
It has been determined that all such requests would fall within the " Administrative" category for licensing fee purposes.
1 Sincerely, C. N. Smith, Acting Chief Fuel Facility Safeguards Licensing Branch Division of Safeguards, NHSS T
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