ML20046D375
| ML20046D375 | |
| Person / Time | |
|---|---|
| Issue date: | 08/10/1993 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bullard C AFFILIATION NOT ASSIGNED |
| References | |
| REF-WM-3 NUDOCS 9308180292 | |
| Download: ML20046D375 (2) | |
Text
.
pnncu 25 e
i E
UNITED STATES
, iQ r!
NUCLEAR REGULATORY COMMISSION
\\ x,
,8 WASHINGTON, D.C. 20555-0001 Agg I g jgjg Mr. Clark W. Bullard Professor of Mechanical Engineering Department of Mechanical and Industrial Engineering 140 Mechanical Engineering Building, MC-244 1206 West Green Street Urbana, Illinois 61801
Dear Professor Bullard:
The purpose of this letter is to respond to your letter of July 26, 1993, to Mr. James Kennedy and follow up on the response provided by Mr. William Lahs in his telephone conversation with you on August 3, 1993.
In your letter you asked whether the Nuclear Regulatory Commission had the authority to require tracking information from shippers / recipients of radioactive materials sent for decontamination, processing or long-term storage. As you indicated, the thrust of your question is directed at the issue of data gathering and tracking with regard to shipments of materials that, through processing, segregation, or management, may result in the generation of low-level radioactive waste. NRC's proposal for a " uniform manifest", incorporated into our rulemaking on Low-level Waste Shipment Information and Reporting, provides one approach which we believe addresses this issue, at least in part.
To answer your specific question, NRC does have the authority to require tracking information on all material transfers, and specifically the shipments you refer to, if NRC can justify the need under our authorities.
If such an action was undertaken, the " Transfer" provisions in our regulations in Parts 30, 40, and 70 would likely need to be amended (e.g., Section 30.41). As you know, this is not the approach taken in our ongoing rulemaking action. This i
rulemaking has focused on that part of our current regulations which addresses manifests in the context of transfers for disposal (i.e.,10 CFR 20.311). The 1
reason lies in the fact that the principal NRC need for this rule is to obtain i
information that may prove useful in conducting performance assessments of the waste disposal sites.
In accepting the Forum's request to include the development of a uniform manifest in our rulemaking, our belief was that a uniform waste manifest could be developed which, while addressing our information collection needs, could i
also provide information on the original " generator" of the radioactivity contained in the waste i.e., the entity to whom the waste should be attributed i
in the context of the Low-Level Radioactive Waste Policy Amendments Act of 1985.
This attribution would be accomplished through a form similar to those currently used by the existing disposal sites (e.g., the Manifest Index and Regional Compact Tabulation Sheet). This is the approach that we have attempted to convey in the several presentations on this rulemaking that we have made to the Forum and others. Any alternative approach that would require manifesting of material shipments would likely require a reproposal of the rulemaking.
t M'yo 9308280292 93gggg fSR W^sTe
.[T'y
} g 3
d
/
]
Clark W. Bullard.
As you correctly pointed out in your conversation with Bill Lahs, under our approach, a manifest would only have to be completed by " waste generators",
" waste processors", and " waste collectors", as defined in the proposed rule.
Thus, for material shipments to waste processors, the information on whom the radioactivity should be attributed would not be documented until the processor completed the uniform manifest when the waste containing the radioactivity in the processed material was forwarded for disposal or further processing.
With regard to shipments returned to the waste generator for long-term storage, whether or not the NRC requires the uniform manifest to be completed for the shipment to the processor or for the return to the original waste generator, the States or Compact Commissions could impose use of the manifest if their authorities so permit.
I hope that the above discussion is responsive to your question and clarifies some of the constraints under which our rulemaking is currently proceeding.
Sincerely, WM Y&ULh.LCHAur i
Paul H. Lohaus, Chief Low-level Waste Management Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards DISTRIBUTION: Central File LLWM r/f RBangart WBrach JAustin PLohaus JSurmeier LBell TCJohnson NMSS r/f Mark SmallcBoxes ~in Concurrence Block to' Define Distribution _ Copy Preferents;
~
~
In small Box on "0FC" line enter: C = Cover; E = Cover & En' closure; H = No' Copy b rey 0FC LLDR C-LLDR C
LLDR S
OGJ
[
LLWBhk b
JAustin 'b b k@lk PLoda'uY NAME Wlahs/km MWeber /
\\'/r/93 N
f/ 6/93 k/(/93 2 /h /93 f
N DATE f/(,/93 S:\\LLWMTYPE\\CECILIA\\BULLARD OFFICIAL RECORD COPY 1
In small Box on "DATE" line enter: M = E-Mail Distribution Copy; H = Hard Copy PDR: YES v
NO Category:
Proprietary or CF Only ACNW: YES NO
/
o __
IG: YES NO v
Delete file after distribution:
Yes N
j J
,,,