ML20133C621
| ML20133C621 | |
| Person / Time | |
|---|---|
| Issue date: | 12/26/1996 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Wallo A ENERGY, DEPT. OF |
| References | |
| REF-WM-3 NUDOCS 9701080013 | |
| Download: ML20133C621 (6) | |
Text
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' Dr,. Andrew Wallo, Director Air, Water and Radiation Division EH-41 U.S. Department of Energy Washington, DC 20585
Dear Dr. Wallo:
Per your request to the members of the Interagency Steering Committee on Radiation Standards, Mixed Waste Subcommittee, Nuclear Regulatory Commission staff has reviewed the document entitled "ALARA Analysis of Radiological Control Criteria Associated with Alternatives for Disposal of Hazardous l
l Wastes." Due to resource constraints, the NRC staff was only able to review the report itself, and did not review the information presented in the appendices.
In general, the staff felt that the report was clearer and more " readable" than the first draft of the report.
The staff's principal concern with the report was whether possession of radioactive material, at any of the levels discussed in the report, would require a non-Department of Energy (D0E),
Subtitle C permitted, hazardous waste disposal facility to obtain a Nuclear Regulatory Commission or Agreement State radioactive materials license.
However, because NRC has not yet established codified dose limits for unrestricted use of properties contaminated with radioactive material, the staff cannot, at this time, determine whether the non-DOE facility would also need an NRC or Agreement State license to possess the radioactive component of the mixed waste.
The staff's specific comments on the report are enclosed.
If you have any questions, please contact Nick Orlando at (301) 415-6749.
Sincerely, if3 John T. Greeves, Director Division of Waste Management ISD M Office of Nuclear Material Safety and Safeguards
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,o December 26, 1996 Dr. Andrew Wallo, Director Air, Water and Radiation Division EH-41 U.S. Department of Energy Washington, DC 20585
Dear Dr. Wallo:
i Per your request to the members of the Interagency Steering Committee on Radiation Standards, Mixed Waste Subcommittee, Nuclear Regulatory Commission staff has reviewed the document entitled "ALARA Analysis of Radiological Control Criteria Associated with Alternatives for Disposal of Hazardous Wastes." Due to resource constraints, the NRC staff was only able to review the report itself, and did not review the information presented in the appendices.
~
In general, the staff felt that the report was clearer and more " readable" than the first draft of the report. The staff's principal concern with the report was whether possession of radioactive material, at any of the levels discussed in the report, would require a non-Department of Energy (DOE),
Subtitle C permitted, hazardous waste disposal facility to obtain a Nuclear Regulatory Commission or Agreement State radioactive materials license.
However, because NRC has not yet established codified dose limits for unrestricted use of properties contaminated with radioactive material, the staff cannot, at this time, determine whether the non-DOE facility would also need an NRC or Agreement State license to possess the radioactive component of the mixed waste.
The staff's specific comments on the report are enclosed.
If you have any questions, please contact Nick Orlando at (301) 415-6749.
Sincerely,
[JohnT.Greeves, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated
1 i
NRC STAFF COMMENTS ON DOE's ALARA l
ANALYSIS OF RADIOLOGICAL CONTROL CRITERIA l
dated October 1996 j
General Comments i
1.
Possession of the radioactive material comprising the radioactive component of the mixed waste may require a non-Department of Energy (DOE), hazardous waste disposal facility to obtain a Nuclear Regulatory 4
Commission or Agreement State radioactive materials license.
- However, because NRC has not yet codified dose limits for unrestricted use of i
proprerties contaminated with radioactive material, the staff cannot, at j
this time, determine whether, in all cases, the non-DOE facility would
]
also need an NRC or Agreement State license to possess the radioactive However the radionuclide concentrations l
component of the mixed waste.,Sr and g listed under RCC Level 2 for Th are in excess of the j
unrestricted use limits for soil in NRC's Fuel Cycle Directive FC-83-23 l
(attached). Absent a specific exemption from the Commission's approved l
unrestricted use criteria, waste in excess of these limits would need to be disposed of in a licensed low-level radioactive waste disposal facility.
j 2.
The doses associated with RCC level 3 are in excess of those that NRC j
has found acceptable in developing guidance to allow the disposal of a j
specific mixed waste stream in a non-licensed, Resource Conservation and Recovery Act (RCRA) permitted, Subtitle C disposal facility.
Currently, NRC is developing a technical position on the disgsal of electric arc j
furnace (EAF) dust contaminated with Cesium-137 (
Cs) in RCRA permitted facilities. This technical position contemplates the disposal of a specific waste stream in a non-licensed disposal facility, because the potential dose to a member of the public is sufficiently low.
The maximum activity of radioactive material that would be acceptable under thetechnicalposigonis130picocuriespergramforstabilizedwaste and is limited to Cs.
In addition to concentration limits, the technical position limits the total activity in any one RCRA permitted facility to 1 Curie.
These limits ensure that the maximally exposed individual does not receive a dose in excess of 1 millirem / year.
NRC currently anticipates that RCRA facilities accepting contaminated EAF dust in accordance with the technical position would not be required to obtain an NRC radioactive materials license.
The doses resulting from the activities contemplated under RCC Level 3 are 20 mrem /yr, which is in excess of fhe criteria established in the technical position for the 1
disposal of Cs in a RCRA permitted facility.
i I
Enclosure l
F l
Sagr,jfic Comments 1.
pp 1.2 - The origin of the 20 millirem " limit" discussed in the third paragraph is not clear and, as this limit is not found in current Nuclear Regulatory Commission criteria for protection of members of the 4
i public the reader may be confused unless the origin of the limit is specified.
1 2.
pp 1.3 - Delete the word "ill" from the first sentence of the fourth paragraph as the public would be protected from all effects of radiation.
1 3.
pp 1.4 - The rationale for the distances from the points of release for l
the airborne pathway should be indicated in the third paragraph.
l 4.
pp 2.1 - Please include "or Agreement State authority" after "(NRC)" in l
the fifth paragraph as the Agreement State may be the regulatory j
authority that issued the radioactive materials license.
i S.
pp 2.2 - Several additional commercial mixed waste treatment firms, other than those discussed in the report, are discussed in DOE-LLW/240
" Commercially Available Low-Level Radioactive and Mixed Waste Treatment Technologies" October 1996.
DOE-LLW/240 should be reviewed to determine i
whether the firms listed in it should be included in the RCC.
Another option would be to simply reference this report.
4 i
6.
pp 3.1 - The first 2 paragraphs in Section 3.1 should be included in the i
Introduction section as it provides a better summary of the RCC concept j
than the current text.
7.
pp 3.1 - The phrase " classified and" should be deleted from the first j
sentence of last paragraph as the classification of the material discussed in the RCC report may have been established by statute (Low-4 1
Level Radioactive Waste Policy Amendments kt) and herefore may not be subject to change.
8.
pp 3.3 - Suggest deleting inost of the text in Sections 3.3 and 3.4 that discuss the magnitude of the values for each RCC level and replace it with a statement about the total range of values because discussing the range of values for each radionuclide is confusing.
For example, change thefourthsentenceinSectiong.3to"Themagnitudeofthevgluegrange from thousandths of pCi/gm for Co to hundreds of pCi/gm for H, Ni and "Zr. "
9.
pp 3.3 - The intent of the statement about the restrictions on source j
material is unclear.
Suggest deleting the last sentence as the intent is unclear and the derivation of the activity concentrations may be in j
error.
l 10.
pp 4.4 - The use of the term " fertile" in the second paragraph is unclear.
As fertile is not commonly used when referring to reactor fuel, suggest deleting the word.
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11.
pp 5.1 - Replace the word "eight" with " ten" in the fourth paragraph as ten radionuclides are included in table 5.1.
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- Dr,. Andrew Wallo, Director Air, Water and Radiation Division a
EH-41 U.S. Department of Energy Washington, DC 20585
Dear Dr. Wallo:
Per your request to the members of the Interagency Steering Committe on Radiation Standards, Mixed Waste Subcommittee, Nuclear Regulatory C mmission staff has reviewed the document entitled "ALARA Analysis of Radio gical Control Criteria Associated with Alternatives for Disposal of H ardous Wastes." Due to resource constraints, the NRC staff was only le to review the report itself, and did not review the information present d in the j
appendices, j
In general, the staff felt that the report was clearer a more " readable" than the first draft of the report. However, because t)te radionuclide levels contemplated under Radiation Control Criteria 2 and 3,4xceed the NRC's criteria for exempting a facility from the requiremejit to obtain an NRC or Agreement State radioactive materials license, it yould be unlikely that a commercial Subtitle C facility would be able to accept mixed waste without i
first obtaining a license. Therefore, it appears that the Subtitle C facility would have to remain under the regulatory authdrity of the Department of Energy. The staff's specific comments on the' report are enclosed.
/
j If you have any questions, please contact / Nick Orlando at (301) 415-6749.
/
/
Sincerely,
/
John T. Greeves, Director
/
Division of Waste Management i
/
Office of Nuclear Material Safety and Safeguards
/
Enclosure:
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