ML20044B220
| ML20044B220 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hutchinson D EG&G IDAHO, INC. |
| References | |
| FRN-53FR21550, FRN-57FR14500, RULE-PR-71 AD33-1-037, AD33-1-37, NUDOCS 9007180149 | |
| Download: ML20044B220 (8) | |
Text
___ - -.
o! GW/129
-1 r
JUL I i 1990 Dave Hutchinson
- EG&G Idaho, Inc.
1580 Sawtelle-Street P.O. Box 1625 Idaho Falls, Idaho 83415-2411
Dear Mr. Hutchinson:
Attached are concents on an example uniform manifest for low-1cyc1 waste (LLW) shipraents. We believe it to be a good first draft which will be of use to the 1
NRC. The. draft manifest and request for comments were provided to us by June 13 letter from Mr. Reuben Alvarado, Lonvener of the Host State Technical Coordinating Connittee for Low-Level Waste Disposal (TCC).
. Because of time limitations, we did not subject the draf t manifest to a rigorous, agency-wide review.
For example, we did not obtain in a legal review of the manifast.
Rather, the review of the manifest was principally conducted by Mr. G. Roles of ny staff, who can be telephoned at 301-492-0595.
The review was coordinated with staff from NRC's Office of Research.
e We understand that the TCC intends to petition NRC to include a uniform manitest form as part of the ongoing NRC rultnaking on LLW manifesting and i
reporting.
Please note our belief that including the uniform manifest in-the i
existing rulcuaking effort will delay its promulgation.
Some delays will result form the legal and procedural implications of the change in the scope of the current rulemaking effort. Other delays will result form the need for close cocrdination with interested parties.such as State and Federal
_ e note that the Department of Transportation has regulatory agencies.
W
.recently proposed amended regulations that, when prcmulgated in a final form, will significantly change the information that must be reported on shipping papers.
i Sincerely, (SIGNED) RICHARD L. BANGART Richard L. Bangart, Director ~
Division of Low-Level Waste Management and Decommissioning
Attachment:
Comnents on draf t manifest cc: Mr. Reuben Alvarado, Convener Host State Technical Coordinating Connittee -
LLWM 90-129 Distribution:
Centra 1 M 1 @ '
NMSS r/f LLRB r/f GRoles RBoyle =
JAustin PLohaus JGreeves RBangart
- JSurmeier
'LLRB t/f JLepre MHaisfield PReed M M1 Category:
Proprietary or CF Only PDR' YES ACNW YES Lv -
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SUBJECT ABSTRACT:
COMMENT ON DRAFT UNIFORM MANIFEST
- SEE PREVIOUS C0)lCURRENCE
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GW/1'29c 1-Dave Hutchinson
- EGLG Idaho, Inc.
1580 Sawtelle Street P.O. Box 1625 Idaho Falls, Idaho 83415 2411
Dear Mr. Hutchinson:
Attached are coments on an example uniform manifest for low-level waste shipments. The draft manifest and request for connents was provided to us by June 13 letter from Mr. Reuben Alvarado, Covener of the Host State Technical Coordinating Comi'. tee for Low-Level Waste Disposal (TCC).
Although we believe that the TCC has assembled a good first draf t of a uniform nenifest, we have identified sorae concerns as noted in the attachment.
Because of time limitations, we did not subject the draft manifest to a rigorous, agency wide review.
For example, we did not'obtain in a legal review of the manifest.
Rather, the review of the manifest was princi) ally conducted by Mr. G. Roles of ry staff. The review was coordinated witi staff frcm NRC's Office of Research.
If you' have questions, Mr. Roles can be telephoned at 301-492-0595.
Sincerely, Richard L. Bangart, Director Dipision of Low-Level Waste Management
,/and Decommissioning
/
Attachment:
/
Cor.ments on draf t manifest
/
cc: Mr. Reuben Alvarado, Covener Host State Technical Coordinating Connittee
-LLHM 90-129 Distribution: Central Filef Fd NMSS r/f LLRB r/f GRoles Boyle JAustin-PLohaus JGreeves RBangart-JSurmeier LLRB t/f JLepre i
PDR YES NO Category: Proprietary or CF Only.'
.ACHW YES N0 SUBJECT ABSTRACT:
COMitENT Oh DRAFT UNIFORM MANIFEST
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DATE: 6 / 6 /90
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OFFICIAL RECORD COPY
A.
Comments on Oraft Uniform Manifest General Comments
-1. On November. 14,-1989 (54 FR 47454), the Department of Transportation (DOT) issued a proposed regulation that amends the requirements in 49 CFR Part 172 for information on shipping papers accompanying shipments of radiocctive materials.
These amendments should be reviewed for their impact on the proposed uniform manifest.
For example, the proposed amendments require that shipping papers express the activity in a shipment of radioactive material in either Systeme International (SI) units (e.g.,
Becquerals) or both SI units and customary units (e.g., Curies).
The proposed amendments also require that shipping papers identify new classes of low specific activity material and surface contaminated objects, and-indicate when the shipment is consigned as exclusive use.
Fissile materials will be identified in a simpler manner than under current 00T regulations.
00T staff members have expressed concerns to us that the draft manifest may not meet existing 00T requirements for shipping papers.
Their concerns are that although the DOT-required information on proper-
. shipping name and hazard class is.provided on the first page of the manifest, most of-the radionuclide identities and quantities are provided on the second page.
Thus, one could not pick up the manifest and immediately determine the hazard represented by the shipment.
John Gale (366-4488) or Mike Wangler (366-4498) of D0T's Office of Hazardous Materials Transportation may be contacted for amplification of these and 9
possibly other concerns.
- 3. The uniform manifest was apparantly drafted by starting with the U.S.
Ecology (USE) manifest form plus the USE instructions for filling out this y
manifest form, and then adding requirements.
Although we agree that the USE manifest is a good starting point -- it contains features such as index code lists that make it easier to transfer the information on the manifest to computer recordkeeping. systems -- it is also important to note j
that the manifest should be applicable to all shipments of waste destined f
for a disposal facility operated by any licensee.
Specific Comments We have attempted to use the words " manifest form" when specifically referring to the document itself.
Otherwise, these comments generally refer to the set of instructions accompanying the manifest form.
- 1. Item 1 of' cover sheet.
We note that the' manifest proposes the use of shipper (or broker) identification numbers, user permit numbers, and shipment identification L
Attachment y
4
' ' ~
2 numbers for all shipments of LLW.
The logistics of assigning and monitoring these numbers may prove to be more complicated than that implied by the instructions.
To avoid confusion and duplication, we see the need for a uniform numbering system applicable to all licensees.- Otherwise, some licensees such as brokers and processors may need to obtain a different identification number from each Compact, a situation that can lead to mistakes and confusion about the use of the proper identification number. We also note that identification numbers may not always be assigned by a State.
NRC may have licensing authority for some or all operations at a disposal facility.
- 2. Item 5 of the cover sheet.
We don't understand-why the " originating" carrier is specified.
Because it appears that inclusion of this adjective may confuse waste shippers, we suggest that it be deleted.
For example, waste may be sent to a broker's facility and then to the disposal facility.
The carrier shipping the waste to the broker may be different from that shipping the waste to the disposal facility, in which case the cover sheet could be read as instructing the broker to identify the wrong carrier.
- 3. Item 6 of the cover sheet.
.This requirement is apparently included to meet the requirement in 49 CFR paragraph 172.203 (d) (vii) for shippers to identify packages approved by the U.S. Department of Energy (00E) or by NRC by noting the' package identification marking as prescribed in the applicable DOE or NRC approval.
To avoid the possibility that the user of the manifest will indicate a manufacturer's serial-number. or some similar identifier, we suggest that the cover sheet include a parenthetical reference to'the 00T requirement.
- 4. Item 7 of the cover sheet.
This feature of the manifest is apparently included to meet 00T requirements in 49 CFR-sections 172.202 and.172.203 However, to our knowledge DOT regulations-do not require that shippers idardify the quantity of hazardous material specifically by weight.
Rather, the DOT regulations provide the option.of indicating the quantity of hazardous material "by weight, volume, or as-otherwise appropriate."
(See 49 CFR paragraph 172.202 (a) (4).).
- 5. Item 8 of the cover sheet.
The phrase "has been amended" in reference to 10 CFR 20.311 can be deleted.
At this time section 20.311 has not been amended, and in any case, the phrase adds no information.
- 6. Item 9 of the cover sheet.
The certification required by section 20.311 goes beyond packaging and labeling.
Rather, the certification is to include waste classification, description, packaging, marking, and labeling.
(See paragraph 10 CFR 20.311 (c).)
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- 7. Item A below item 12 of the cover sheet.
As an aside, we might mention that manifests generally contain more than one manifest number.
Shippers assign manifest numbers to waste shipments so that they can track the material they send offsite.
But there is nothing to preclude one shipper from using the same numbering system as another, which means that there are no guarantees that two manifests will not be numbered alike.
Therefore, disposal _ facility operators also assign their own manifest
-i numbers when the shipment arrives at the disposal site.
Chem-Nuclear calls
.this number an arrival survey number while USE calls it a Bates number.
These numbers should also be noted on each page of the manifest.
- 8. Item 14 of the continuation page.
We. agree that the type of container should be specified.
But to ensure that the information can be used for analysis and other applications, we strongly suggest referring to an index list.
The index list would be applied in a i
similar manner as the index list used for the waste description (item 22 on manifest).
Use of an index code would slightly reduce the width of the manifest column, which is desirable because some of the other columns are too narrow, particularly that for the chemical description (item 25).
- 9. Item 15 of the continuation page.
We don't understand the need to routinely report the volume of the container to the nearest hundredth of a cubic foot.
For some packages -- e.g., boxes, liners -- the volume may be difficult to measure.
Even for standard packages l
such as 55 gallon drums, we understand that there can be observable differences l
in container dimensions deper. ding upon the manufacturer.
These differences can l
probably result in variations in volume exceeding 0.01 fta.
In any case, we L
can't see that accuracy to the nearest hundredth of a cubic foot.is needed to
. assure protection of public health ar.d' safety.
(However, if a determination is l
made.that guidance is needed on waste volumes, then we believe that such guidance should be subject to a Regulatory Guide or technical position rather I
than t. rule.)
- 10. Item 16 of the cover sheet.
1 As in the above comment, we don't understand the need to report the weight of a container of waste to the nearest' pound.
- 11. Item 17 of the cover sheet.
To our knowledge, neither NRC nor DOT assign approval numbers for waste l
containers.
The reference may be to the DOT designation for some packt (e.g., 7A), in which case we aren't sure why item 17 is needed.espec-
,y if the waste container is adequately described by item 14 on the continual 1on page.
Therefore, we suggest deleting this item and using the freed column space to expand the available space for item 25.
It may be appropriate, however, to consider developing a numerical system to identify the manufac-turers and models for high integrity containers.
(See comment number 19.)
p 6
1 4
We believe that it is less confusing to use the word " container," rather than
" package," when referring to a waste container.
" Package" has connotations associated with DOT transportation regulations.
A reusable shipment cask, for example, is' a package according to DOT regulations.
- 12. Item 22 of the continuation page.
It would be useful to identify whether a container of ion-eachange resins contains cation, anion, or mixed exchangers.
Also, we note that some activated metals may be generated by accelerators rather than nuclear reactors.
- 13. Item 23 of the continuation page.
We believe that it would be appropriate to list specific types of solidification (and stabilization) media.
A requirement to list specific solidification media using an index code would appear to be a straightforward extension of the existing general requirement in section 20,311 to identify the solidification media.
One wants the information because releases from solidified wastes may differ depending upon the solidification media, and also because one would want to assess the extent of the possible hazard should a problem develop with a particular media.
However, we don't understand why there should be a general requirement to list sorbent media.
In environmental
' assessment calculations, no credit is normally given to absorbents to retard radionuclide release.
- 14. Item 24 of the continuation page.
It appears to us that item 24 requires essentially the same information as item 23.
Therefore, item 24 may be deleted.
- 15. Item 25 of the continuation page.
Although we believe that improvements should be made in.the detail in which the principal. chemical form of the waste is described, we also believe that the phrase "as accurately as possible" can be interpreted to mean an extremely onerous regulatory requirement. We believe that a balance needs to be struck
.against the need to describe the waste and the need to avoid excess paper work.
We suggest use of a phrase less likely to be misinterpreted, coupled with:
examples.
For example, if the waste consists of activated metal components (waste description 25 on the manifest form), then the principal chemical-form could describe the type of component - control rod blades, instrument strings, etc.
We also= note that the available space in the manifest form for this item
~is too small.
The column should be considerably widened.
In addition, we note that the manifest essentially requires that animal carcasses must always contain lime.
Although we recognize that this may be current practice, the wording implies that including lime is a de facto regulatory requirement applicable to all shipments of animal carcasses.
However, there also may be other ways to package animal-carcasses.
In addition, the instructions indicate that the shipper should indicate chelating agents present in amounts greater than either 0.1% by weight or 0.1%
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5 by volume.
The Part 20 regulations only require the former.
What is the i
justification for requiring the latter?
Finally, the word " chelating" is misspelled on the manifest form.
- 16. Item 28 of the continuation page, j
Again, the requirement to " list all radionuclides present in the package" can be interpreted as an extremely onerous requirement.
Taken literally, one would have to report a single atom of a radioactive species in a saste package.
It would be more appropriate to merely require that the radionuclides in the waste j
l be listed.
The criteria for determining the lower limits of detection and i
reporting should then be given in a guidance document. -(inis is cuirent practice.) We also suggest care in requiring use of official DOT j
j abbreviations.
The' wording could be interpreted as requiring gippers to j
always abbreviate the radionuclide carbon-14, for example, as C.
But the structure of the manifest is such that it would be easier, and probably more legible, to abbreviate the radionuclide as C-14.
- 17. Items 30 and 31 of the continuation page.
1 The second sentence in item 30 appears to make more sense as the second sentence of item 31.
Similarly, the second sentence in item 31 appears to make more sense as the second sentence of item 30.
j
- 18. Item 35 on the manifest form.
1 The column width should be greatly reduced and the saved space used for another l
column such as that for item 25, chemical form.
i
- 19. Item 36_of the continuation page.
-We suggest indicating the HIC manufacturer and model number.
As noted above, it may be appropriate to develop a numerical code for HIC manufacturers and model numbers.
Such a number could be similar to that used to identify j
packages' approved by DOE or NRC for transportation of radioactive material pursuant to 49 CFR 173.203 (d) (vii).-
1
- 20. Item B of " Processed Waste Continuation Sheet."
i In the second sentence, "its" refers to the waste container _rather than to the waste.
Principal is misspelled as principle.
We suggest that a phrase such as "the principal physical form of the waste" would be clearer,
- 21. General comment.
i' Increasingly, to reduce exposures to workers, nuclear reactor licensees routinely decontaminate plant' systems using a process such as Lomi, Can-Decon, i
or Citrox. _The wastes from these processes generally contain chelating agents and can be difficult to solidify.
We suggest that it may be appropriate to specifically identify wastes from a large-scale decontamination process.
For these special wastes, certain additional information could be obtained such as
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.6-ithe identity of the decontamination process and the weight percent loading.
-This information is known by the waste generator but to our knowledge is not routinely reported on manifests.
(Additional background information pertaining to this comment'can be obtained from Dr. Phillip Reed of the NRC Office of Research.
His telephone number is 301-492-3879.)
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