ML20105C948

Comment Supporting Proposed Rev to 1983 Staff Technical Position on Radwaste Classification, Technical Position on Concentration Averaging & Encapsulation

ML20105C948
Person / Time
Site:	Beaver Valley
Issue date:	09/15/1992
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC
References
FRN-57FR29105, REF-WM-3 57FR29105, NUDOCS 9209240123
Download: ML20105C948 (2)

Text

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Chief, Rules and Directives Review Branch U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

" Technical Position on Concentration Averaging and Encapsulation," proposed revision to the 1983 Staff Technical Position on Radioactive Waste Classification Duquesne Light Company (DLC) would like to submit the follcwing comments for consideration in response to the Nuclear Regulatory Commission's (NRC) request. A notice of availabiljty of a proposed revision, in part, of the 1983 Staff Technical Position on Radioactive Waste Classification, " Technical Position on Concentration Averaging and Encapsulation," was published in the June 30, 1992 feielpal Rect ist;_qr ( 57 FR29105) .

, The industry generally supports the establishment of standard cr i t.eria to provide consistency in waste classification practices mnroughout the country. Uniformity in approach to low level waste (LLW) classification among the states and NRC is important, especially considering these criteria will be used to distinguish between Class C waste (a state responsibility) and greater-than-Class C waste (a Department of Energy responsibility). However, we have some concerns regarding the criteria proposed by NRC in the draft technical position.

l A major concern is that, for activated or contaminated components and cartridge filters, the proposed revision unnecessarily establishes new isotopic concentration averaging guidelines that are more restrictive than current practices. The propcsed technical i

position restricts the practice of radionuclide concentration averaging within a waste package in a manner that does not appear to be justified given the exposure scenarios and other assumptions that i serve as the basis for 10 CFR Part 61.

i l The Edison Electric Institute Utility Nuclear Waste and Transportation Program (EEI/UWASTE) has developed comments to the proposed technical position. The comments have been prepared with technical support from the Electric Power Research Institute (EPRI) which has evaluated the proposed technical position as part of its i research project on low-level waste radionuclide concentration averaging.

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" Technical Position on Concentration Averaging  !

and Encapsulation," proposed revision to tho l 1983 Staff Technical Position on Radioactive j Waste Classification i I

Page 2 As a member of the EEI/UWASTE Low-Lovel Waste Working Group, we have provided input to the development of the EPRI comments and concur l with them. [

Sincerely, j i  !

} . D. Sieber

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