ML20045A286
| ML20045A286 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/1991 |
| From: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Treby S NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20044B495 | List: |
| References | |
| HPPOS-271, NUDOCS 9306100060 | |
| Download: ML20045A286 (2) | |
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MEMORANDUM FOR: Stuart A. Treby, Assistant General Counsel for Rulemaking and Fuel Cycle, OGC FROM:
John E. Glenn, Chief i
- iedical. Academic, and Commercial
-l Use Safety Branch Division of Industrial ind Medical Nuclear Safety, NMSS
SUBJECT:
TECHNICAL ASSISTANCE REQUEST (TAR) FROM REGION I:
DISPOSAL OF LIQUID WASTE INTO ARCTIC OCEAN Enclosed please find the May 28, 1991, letter from Richard F. Rivkin, The University of Maryland System, Center for Environmental and Estuarine Studies, which Region I sent to us as a TAR.
As indicated in Mr. Rivkin's letter, the National Science Foundation is sponsoring a research project i
involving use of carbon-14 (C-14) and tritium (H-3).
This project will take place during a research cruise on a Soviet icebreaker in the Arctic Ocean from July 27 to August 16, 1991. Mr. Rivkin is seeking permission L dispose of about 10 millicuries of H-3 and 40 millicuries of C-14 in the Arctic Oceer.
1 We have several questions about this request:
1.
Does the Nuclear Regulatory Commission (NRC) have jurisdiction to regulate the use of C-14 and H-3 on a Soviet vessel operating in international waters?. If NRC does have jurisdiction, the staff will inform Mr. Rivkin of the need to obtain an NRC license.
If NRC does not have jurisdiction, what go.
nment or agency does have jurisdiction?
We would like to provide appropriate guidance to Mr. Rivki,%
+
2.
Do you believe that the rationale provided by Mr. Rivkin is adequate to justify authorizing disposal of 10 millicuries of H-3 and 40 milli-curies of C-14 at see?
If additional information is needed to make this determination, please identify the type of.information needed.
l 1
We understand that the prohibition against sea disposal in 10 CFR j
20.302(b) is prompted, at least in part, by international treaty.
It 1
is not clear to us how much flexibility we may have in authorizing sea disposal.
From the standpoint of the amount of radioactive material i
involved and the location of the proposed disposal, we believe that the-public health and safety would still be protected if we we're to authorize this disposal at sea, i
l 930610C060 910625 N S4 l~d F DR ORG NRRB
- Prs, D
l M ox g Stuart A. Treby
-2 On the other hand, other licensees have conducted similar studies at sea and NRC has required those licensees to contain the radioactive I
waste and dispose of it af ter they return from their research cruises.
Mr. Rivkin indicates that this cruise will terminate at Nome, Alaska, which does not have truck or rail service to the continental United States.
Based on a telephone conversation with Region I staff, we understand that transfer of the radioactive waste to another licensee in Alaska (e.g., the University of Alaska) may not be feasible because of waste compact considerations.
Mr. Rivkin has, in effect, told us that it would be difficult or inconvenient to return the waste for disposal at the conclusion of the cruise.
He has not provided a compelling reason why sea disposal should be authorized.
One situation that the staff thinks might be an example of a " compelling reason" is that the radioactive waste is explosive and irmediate disposal at sea is a safer alternative that returning the waste to land for disposal.
The materials involved in Mr. Rivkin's project are not explosive.
In view of the July 27 starting date for this research cruise and the possible need to take licensing actions, we would appreciate your reply to this memorandum as soon as possible but not later than June 14, 1991.
If you have any questions about this matter, please contact Patricia Vacca at Ext. 20615.
w4w.aA signed Ryr John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NHSS
Enclosure:
Ltr dtd 5/28/91 Distribution IMAB.446 PCYacca(wp.u q )
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