ML20132F939
| ML20132F939 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1985 |
| From: | Browning R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Strong T WASHINGTON, STATE OF |
| References | |
| REF-WM-17 NUDOCS 8507190090 | |
| Download: ML20132F939 (2) | |
Text
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ne'r: lc W. .. . . ;; J0 Bunting Mr. Terry P. Strong
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LBHigginbotham Radiation Control Section Department of Social and Health Services gg 4 g [p-y '~/~C T Olympia, WA 98504
Dear Mr. Strong:
In your letter dated December 23, 1984, you commented on the Nuclear Regulatory Connission (NRC) topical report review process and requested responses to several questions.
We agree that the NRC and the State of Washington (WA) need to work together to ensure that waste generators have the maximum flexibility to deal with the
's disposal of their wastes in a manner which meets the requirements of 10 CFR Part
- 61. It is for this purpose that we committed to review topical reports in an effort to provide a single review which would consider each State's license conditions.
We have committed to a very substantial effort because we believe that topical reports should receive a full and complete review which will endure detailed pkblic scrutiny. The high integrity container (HIC) concept is a relatively new one. It is, therefore, important that all questions and concerns are addressed to ensure public acceptance. Because HIC's offer waste generators a great deal of flexibility and HIC's are important to industry, we believe that the performance of credible reviews is essential in light of the scrutiny the reviews will receive when they are completed.
In response to the specific questions in your letter, we are providing the following responses:
- 1. Should HIC's continue to be reviewed under full, exhaustive, 10 CFR 61 criteria for use at existing disposal sites?
Yes. We believe that our reviews should withstand the critical scrutiny of both the public and those industrial organizations which have previously been reluctant to accept the HIC concept.
- 2. Should some s.creening criteria be developed to allow provisional use of HIC's pending the outcome of detailed analyses and reporting required under 10 CFR 617 We believe that the development of screening criteria could be a discussion item between the states and NRC. Another option would be to address individual waste generator problems on a case-by-case basis, in
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4 WM85013/TCJ/1/12/85/1; FEB 6 1985 the manner that we recomended to WA to accept a limited amount of wastes from New England Nuclear.
- 3. Should the NRC continue to encourage the topical report process for 10 CFR 61 implementation?
Yes. The states expect the NRC to assist them in ensuring, through the inspection process, that waste generators are complying with 10 CFR Part
- 61. The topical report process aids inspectors by reducing the amount of time needed for waste management related inspections and by ensuring a consistent level of compliance.
- 4. What . level of detail and assurance must be provided by the applicant to substantiate the topical report application?
We believe that vendors should provide sufficient information in their topical report submittals to enable us to review them against both NRC and state HIC design guidelines. A complete and well documented report is essential for us to perform reviews which can withstand the scrutiny which will be given to it.
We hope these responses have addressed your concerns. We would also appreciatt O the opportunity to meet with you and your staff and discuss how we can better coordinate and improve our topical report review program.
Sincerely, CritinalSigned by I?c':er: E, cm.t..,,,7 Robert E. Browning, Director Division of Waste Management
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