ML20033A865
| ML20033A865 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/20/1981 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| NUDOCS 8111300043 | |
| Download: ML20033A865 (2) | |
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Docket No. 50-312 b
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Attention: Mr. John J. Mattimoe Assistant General Manager and Chir.f Engineer Gentlemen:
Suoject: Used Charcoal Filter Fkdia Your letter of March 13, 1981 requested that the U.S. NRC, Region V, review and provide guidance concerning disposal options for the contaminated charcoal presently in storage at Rancho Seco. Our response of April 3, 1981 informed you of our request for guidance from NRC Headquarters.
Our headquarters has recently advised us that the development of regulatory guidance <r very low level (or so called "de minimus" level) radioactive waste for nuclear power reactors has been initiated, however ro specific guidance applicable to your concern is presently available.
In publishing proposed 10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste," the Comission recognized the need for a "de minimus" classification of wastes, wastes that would be exempt from Part 61 and would be considered of no regulatory concern (46 FR 38081). The Comission believes, as the Federal Radiation Policy Council has recomended, that such exemptions should be determined on a specific waste basis. Such an exemption has been established by the NRC for certain wastes containing H-3andC-14(10CFR20.306).
In a sepsrate, but related action the Comission recently adopted a " Policy Statement on Low-level Waste Volume Reduction" (Federal Register Notice, Friday, October 16, 1981, page 51100).
This policy calls "on all generators of low-level radioactive waste to reduce the volurne of waste for disposal..." and " considers it desirable that licensees reduce the volume of low-level radioactive waste generated and shipped to comercial waste disposal sites."
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Sacranento ftunicipal Utility District It is unfortunate that specific "de minimus" criteria applicable to power reactor operations are not available at this time. However, in vicu of the Comission's recognized need for "de mininus" criteria and the stated policy on waste reduction, it would be appropriate for you to develop a specific request for alternative means of disposal of this very low level radioactive waste.
10 CFR 20.302 provides the regulatory basis for such a request.
!!e encourage you to nake a specific request, pursuant to 10 CFR 20.302, for an. alternative disposal method for charcoal removed from filters at your facility. As delineated in the regulation, your application should contain sufficient description and analysis to identify and quantify the radiological inpact of your proposal.
If approved, your proposal nay not only be cost effective for you, but would aid in volume reduction of radioactive waste and could likely assist in developing groundwork for future "de ninimus" criteria.
If you decide to nake a reauest, it nay be made directly to the Region V of fice. !!e will assure it is channeled for the aporopriate review.
If you have any questions on this matter, please call Mr. F. Flenslawski (415-943-3757) of ny staff.
Sincerely, y.g.n, g
.KI-R. H. Engelken Regional Administrator cc:
L. Higginbothan, IE:HQ fl. Padovan, ORB 4, NRR bcc:
Df!B/ Document Control Desk (RIDS)
Distributed by RV:
State of CA (Hahn/ Johnson)
Resident Inspector (H. Canter)
Encelken (ltr)