ML20136C627

Responds to IE Bulletin 79-19.Low Level Waste Is Packaged in Accordance W/Burial Criteria Established by Agreement States

ML20136C627
Person / Time
Site:	Dow Chemical Company
Issue date:	08/31/1979
From:	Langner R DOW CHEMICAL CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20136C633	List: IR 05000264/1974001 IR 05000264/1976003 IR 05000264/1977001 IR 05000264/1977003 IR 05000264/1978002 ML20136C627 ML20136G988 ML20136H011 ML20136H026 ML20136H041 ML20136H172 ML20136H183 ML20136H228 ML20136H275 ML20136H316 ML20136H379 ML20136H410
References
FOIA-85-483 IEB-79-19, NUDOCS 7910010281
Download: ML20136C627 (2)

Text

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MIDLAND, MICHIGAle 44643 August 31, 1979 0

Mr. James G. Keppler, Director US Nuclear Regulatory Commission a

799 Roosevelt Road Glen Ellyn, IL 60137 l

Dear Mr. Keppler:

This letter is in response to IE Bulletin No. 79-19 concerning the packaging of low level radioactive waste for transport and burial. The Dow Chemical Company concurs with efforts of the Nuclear Regulatory Commission to improve the status of safe packaging and transport of low level radioactive waste for burial. However, the thrust of the Nuclear Regulatory Commission effort should be towards correcting the abusers of the transport and burial legal system.

The Dow Chemical Company has and will continue to comply with all Nuclear Regulatory Commission and Department of Transportation regu-lations regarding packaging and transport of low level radioactive waste. We maintain a current set of license requirements placed on the ,

waste burial fim by those Agreement States in which The Dow Chemical l Company's low level radioactive waste is buried. Our low level radio-active waste is packaged in accordance with the burial criteria established  !

by the Agreement States. .

By law, a burial finn is required to maintain public burial records for inspection. Therefore information pertaining to waste buried by The Dow Chemical Company is a matter of public records and can be extracted from said records.

l Pursuant to Item 9 of IE Bulletin No. 79-19, The Dow Chemical Company i provides the Nuclear Regulatory Commission with the following infonnation: l 3

1. The Dow Chemical Company shipped 745.5 ft of low level radio-active waste to Barnwell. South Carolina on April 19, 1979. No burial shipments were made in 1978.

2. The burial shipment contained 16.279343 Curies. The major isotopes in the shipment were carbon-14 and tritium.  ;

3. Liquid low level radioactive waste was solidified by Dow media. l

- Dow media is a Chem-Nuclear Systems Inc. (CNSI) recognized i solidification process that results in a material meeting the burial standards of CNSI.

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Mr. James G. Keppler 2 August 31, 1979 The Nuclear Regulatory Commission should investigate the packaging and transport operating procedures of those offenders who do not comply with the law rather than burdening those licensees who package and transport low level radioactive waste properly. The Dow Chemical Company has operated within the confines of the Federal Regulations and therefore, should not be subject to a " paper harassment" that is unnecessary, unwarranted and most important, unproductive for the industry.

Sincerely, .

llh'hf "f Ralp R. Langner, Chairman Radiation Safety Committee Health & Environmental Science 1603 Building 517/636-4344 bjd cc: Nuclear Regulatory Commission, Office of Inspection and Enforcement, Division of Fuel Facility and Materials Safety (nspection, Washington, DC 20555 l

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