ML20041A876
| ML20041A876 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 01/14/1982 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 20179, NUDOCS 8202220622 | |
| Download: ML20041A876 (2) | |
Text
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6 PRODUCTS DIVISION
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Dear Mr. Page:
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Reference:
NRC License SNM-1097, Do Confirming your telephone conversation of Monday, January 11,
- 1982, with WJ
- Hendry, Manager-Regulatory Compliance, General Electric Company has designed and installed a multi-million dollar incinerator facility for the inuineration of low level radioactive waste generated in the GE nuclear fuel manufacturing facility in Wilmington, N.
C.
The facility is nearing completion and has satisfactorily incinerated non-radioactive combustible waste.
On December 15, 1981, we submitted safety demonstration infor-mation to your office as a
requirement for issuance of authorization to operate the iacinerator as requested in our initial submittal in December 1979.
The incineration of low level contaminated waste is an important part of the overall GE waste volume reduction plan and we are quite eager to initiate the new facility operation and to burn boxes of waste accumulated since the previous facility went out of operation in February 1978.
We were very gratified by the publication in the October 16, 1981 Federal Register of a NRC Policy Statement on low level waste volume reduction.
The Policy Statement clearly indicates the NRC intention to expedite the licensing of waste reduction operations.
The policy also states that licensees should take steps to reduce the volume of contaminated wasta.
Consistent with the NRC policy, the overall GE waste reduction plan includes an aggressive program by shop management to rigorously control the volume of waste-destined material entering the fuel operations, to decontaminate as much material as possible so as to avoid burial at a licensed site, and to discipline the loading of the waste boxes so as to maximize their content prior to burial.
We were, therefore, concerned by the NRC requirement of January 8, 1982 to provide environmental information (over and above that i
already submitted) prior to approval of the incinerator license amendment.
Although we understand the NRC concern for the current 82022206722 820114 201D PDR ADOCK 07001113 sul C
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GENER AL O ELECTRIC Mr.
R. G. Page January 14, 1982 Page 2 ground water envirmmental issue, we do not believe that it should be readily correlated to the operation of the GE-WMD incinerator.
Factors which lead us to this conclusion are (1) the incinerator facility is a
replacement for one which had been previously licensed, and (2) there is no apparent technical tie-in between the area of NRC environmental concern and the incinerator operation.
Based on earlier discussions between the NRC and GE related to another license amendment
- request, it is apparent that considerable time may be necessary to resolve the NRC requirements and to negotiate a workable, environmentally-oriented statement in the license.
If license approval is tied to resolution of the current ground water issue and operation of the incinerator is delayed, additional waste boxes will be accumulated contrary to the intent of NRC policy.
We propose that the environmental issue be set aside by the NRC and that the incinerator operation be approved as requested as soon as the safety of the operation can be demonstrated.
We believe that this is a reasonable course of action because it is completely in accord with the NRC Policy Statement of October 16, 1981.
It also permits the environmental concerns to be thoroughly reviewed and considered so that they may be included as necessary in the NRC renewal review of GE-WMD license SNM-1097 which will occur this year.
We are requesting that you give careful consideration to our proposal to meet the March 1,
1982, operating license date for the replacement incinerator as identified in my letter of December 4, 1981.
We should work together to make this happen.
Additionally, I would like to work with you to establish mutual milestones for the SNM-1097 license renewtl activity so that we have a common understanding of what is to be done and the schedule to accomplish these tasks.
This effort now will most certainly enhance the efficiency and quality of finalizing the license renewal.
Very truly yours, GENERAL ELECTRIC COMPANY Charles M. Vaughan, Acting Manager Licensing & Compliance Audits CMV:bmw M/C J26 NSD/SGD-L I
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