ML20027C000
| ML20027C000 | |
| Person / Time | |
|---|---|
| Issue date: | 09/21/1982 |
| From: | Martin J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Harris S HEALTH PHYSICS SOCIETY |
| References | |
| FRN-46FR38081, REF-WM-4, RULE-PR-61 NUDOCS 8210120147 | |
| Download: ML20027C000 (2) | |
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202/KSO/82/09/10 2 1 1982 U " d' W gz3 4f Saul J. Harris, Chairman Committee on State and Federal Legislation Health Physics Society 400 Mansion House Center, Apartment 1901 St. Louis, M0 63102
Dear Mr. Harris:
In your letter to Chairman Nunzio J. Palladino dated August 30, 1982, you expressed concern about your first impression of the final version of 10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive I
Wastes" as proposed in SECY 82-204 and under review by the Commission.
As you are probably aware, your letter was submitted too late to be docketed and considered as a comment in formulating the rule.
Nevertheless, we wanted to better understand your concerns and clarify your impressions.
Based on discussions with my staff, we understand that your main concern as Conmittee Chairman and as Chairman of the Health Physics Society (HPS)
Task Force on De Minimis is the de minimis issue. The de minimis issue involves the need for determining one or all of the following for licensee use in managing low _ level radioactive wastes: levels for disposal options less restrictive than Part 61 disposal, levels of no regulatory concern, or de ninimis limits. As we noted on page 30 of SECY_82-204, we agree with you that there is such a need and plan to address the issue over the next few years. Let me assure you that we remain committed to these plans.
I i
Even though the f;nal rule is under review by the Commission, we still have the opportunity to make editorial changes that would clarify our intent and help people better understand the rule. As your letter demonstrated, the discussion of the de minimis issue on pagas 30 and 31 of SECY_82_204 may have been unclear regarding pe,titions for rulemaking and editorial changes may be needed to clarify our intent. Certainly, licensee organizations and persons other than licensees can submit petitions.
Preferably, such petitions should address waste streams common to a number of licensees, not just one, and we did not intend to solicit thousands of petitions from individual licensees. A statement in 520.311 that emphasizes that the new section would apply only to transfers for disposal at Part 61 facilities may also be needed to clarify our intent that the provisions of the section do not apply to alternative methods of disposal not involving disposal at a Part 61 C :
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i facility.
The efforts of your Committee and the HPS Task Force can be of great help to us. We solicit your input on specific waste streams to consider for less restrictive disposal methods or for disposal without regard to radioactive content. He encourage your efforts to coordinate t
and provide liaison for the various groups and agencies addressing the de minimis issues. We look forward to working with the HPS and groups such i
as yours as our low level waste program continues.
l Sincerely, Original Signed by John B. Martin John B. Martin, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards.
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