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August 26, 1994 MEMORANDUM FOR:
Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM:
Eric S. Beckjord, Director Office of Nuclear Regulatory Research
SUBJECT:
FINAL RULE ENTITLED, " LOW-LEVEL WASTE SHIPMENT MANIFEST INFORMATION AND REPORTING" Enclosed for information of the Committee to Review Generic Requirements (CRGR) is the final rule package that has been submitted for office The final rule would amend 10 CFR Parts 20 and 61 to.
concurrences.
(1) improve the quality and uniformity of information contained on manifests that are required to control transfers of Low-Level Radioactive Waste (LLW) ultimately intended for disposal at a land disposal facility; (2) establish a set of NRC forms, that serves as a national Uniform Low-level Radioactive Waste Manifest, and captures the information needed to meet NRC, Department of Transportation, State and Compact information requirements; (3) require LLW l
disposal site operators to electronically store container-specific manifest l
information; and (4) require disposal site operators to be capable of submitting reports of stored manifest information on a computer-readable medium (e.g., magnetic disks or tapes).
These amendments will improve implementation of NRC and State regulations on LLW disposal by providing more accurate source-term information.
This information will be used in performance assessments that can be evaluated against the performance objectives of Part 61. Using the Uniform Manifest will not require generators to report information that is not readily and currently available.
Rather, its use will improve the consistency and increase the level of detail over presently reported information, and will require the reporting of other useful and currently available information (e.g., identity of high-integrity containers, when used).
In addition, to support the intent of the low-level Radioactive Waste Policy Amendments Act of 1985, these amendments will facilitate tracking of LLW back to the original generator.
For the same reasons as discussed at the proposed rule stage (see enclosed memo to the Committee dated April 9,1990), this rule does not involve provisions of the backfit rule, as defined in 10 CFR Part 50.109, and no backfit analysis has therefore been prepared. The additional information to be submitted on shipment manifests will not require reactor operators to make any changes in operational procedures.
The additional information is already known by the licensees and needs merely to be reported.
The final rule package includes an analysis of the 40 public comment letters.
Included were five letters from utilities and one from the Edison Electric Institute.
There were no comments on'the Commission's statement that the backfit rule does not apply to the proposed rule (stating the reasons
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Edward L. Jordan 2
mentioned above) and that therefore a backfit analysis is not required. The final rule, and associated forms'and inst,octions, are not substantially i
different in concept and context to.those presented in the Federal Register Notice for the proposed rule.
r Therefore, I am recommending that the final rule proceed without the need for a CRGR review, since we continue to believe the backfit rule does not apply, and there were no public comments to the contrary.
/s/ T. P. Speis for i
Eric S. Beckjord, Director Office of Nuclear Regulatory Research
-Enclosures.
'1.
Commission Paper w/atts.
2.
April 9, 1990 memo from Eric Beckjord to Edward Jordan Distribution:
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