ML20057D854
| ML20057D854 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1993 |
| From: | Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hirsch D COMMITTEE TO BRIDGE THE GAP |
| Shared Package | |
| ML20057D855 | List: |
| References | |
| REF-WM-3 NUDOCS 9310060074 | |
| Download: ML20057D854 (2) | |
Text
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WASHINGTON, D.C. 20555-0001 SEP 141993 Mr. Daniel Hirsch, President Committee To Bridge The Gap 1637 Butler Avenue, Suite 203 Los Angeles, California 90025
' Dear c
In response to your September 1,1993 letter, I have had my staff look into your question on the projected volumes and activities associated with low-level decommissioning wastes. As you correctly point out, Timothy Johnson and Gary Roles, in their 1989 paper, estimated that the activities of Class A. B.
and C low-level decommissioning wastes would range from 114,000 Ci for the reference pressurized water (PWR) reactor to 295,700 Ci for the reference boiling water reactor (ref. Table 7).
Since the portion of the U.S. Ecology License Application you submitted is apparently based on this information, we believe that the 14.4 million curie value cited in the application incorrectly included the activity from Greater-than-Class C (GTCC) waste. The 14.4 million curie estimate can be derived by using the ratio approach described in the paper, and applying the resultant sum from the four reactors to the total PWR activity estimate provided in the 1989 paper (i.e., 4.9~million curies for the reference 1175 MWe facility (including GTCC activity)). As you may be aware, the Low-level Radioactive Waste Policy Amendments Act requires the Department of Energy to dispose of GTCC waste in an NRC-licensed facility.
From the few pages of the Environmental Impact Report that you provided, the estimate of 4,269 Ci for the activity of low-level waste projected at the Ward Valley site, principally from Humboldt Bay and Rancho Seco, certainly could be reasonable when one considers the impacts of both decay. time (see Table 9 of the 1989 paper) and waste management approach (i.e., what fraction of non-fuel bearing activated hardware, internal to the pressure vessel, will be sent to the Ward Valley facility).
Your request for information on concentration averaging is timely in that we have just noticed in the Federal Reaister the availability of a proposed Branch Technical Position on this subject.
I have enclosed a copy of the position together with the letter transmitting it to our licensees and airo to those who had commented on our initial proposal which was noticed on June. 30, 1992.
With regard to the definition of high level waste, the NRC recently concluded that the principles for waste classification are well established and can be applied without revision to our regulations. This was stated in a Federal
)
Reaister notice that denied a petition from the States of Washington and Oregon pertaining to the Hanford tank wastes (58 FR 12342; dated 3
March 4, 1993). Thus, we continue to use the source-based definitions that j
have been in place for sometime. We continue, however,'to follow with i
interest ongoing efforts by the National Council of Radiation Protection and
) j Measurements, the Institute for Energy and Environmental Research, and others, i
to develop a risk-based waste classification system.
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SEP 141993 Daniel Hirsch Finally, the most up to date document that I am aware of regarding the normal operational disposal of irradiated components is a Department of Energy report, " Greater-Than-Class C Low-level Waste Characterization:
Estimated Volumes, Radionuclide Activities, and Other Characteristics", DOE /LLW-114, dated August 1991 (contact R. A. Hulse at EG&G Idaho, Inc.). Appendices F and G of this document contain information on irradiated hardware which you may find useful.
I understand that this document is currently being updated.
I hope this information responds to your questions and information needs.
If I can be of further help, please write or call me at (301) 504-2560.
Sincerely, OdghaiSigned By John H. Austin, Chief Decommissioning and Regulatory Issues Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
D. Kunihiro, NRC RV R. Junkert In small Box on "0FC:" line enter: C = Cover E = Cover & Enclosure N = No Copy 0FC LLDR f-LLDR /, h byB 4
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