ML20137M170
| ML20137M170 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1995 |
| From: | Morrison D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Ashley Roberts TRANSPORTATION, DEPT. OF |
| Shared Package | |
| ML20007F933 | List:
|
| References | |
| FRN-60FR15649, FRN-60FR25983, RULE-PR-20, RULE-PR-61 AD33-2, AD33-2-018, AD33-2-18, NUDOCS 9704080024 | |
| Download: ML20137M170 (2) | |
Text
'
e xecg gNd J- [- 84 UNIT .3 STATES j *
,jf NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 4 001 g
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- November 14, 1995 Mr. Alan Roberts Associate Administrator for Hazardous Material Safety, RSPA Department of Transportation 400 Seventh Street, SW Washington, DC 20590
Dear Mr. Roberts:
The purpose of this letter is to request your concurrence that the Nuclear Regulatory Commission's (NRC) Uniform Low-Level Radioactive Waste Manifest and accompanying instructions satisfy amended Department of Transportation (DOT) shipping regulations, " Hazardous Materials Transportation Regulations; Compatibility with Regulations of the International Atomic Energy Agency" issued in final on September 28, 1995 (60 FR 50292). In previous letters to you on May 10, 1991, September 30, 1992, and August 23, 1993, we discussed the NRC's rulemaking that mandates the use of an NRC Uniform Manifest for transfers of low-level radioactive waste. The NRC Uniform Manifest captures the requirements of NRC for information and tracking, DOT for shipping papers, States and Low-Level Radioactive Waste Compact Commissions, and disposal facility operators.
The NRC's final rule, " Low-Level Waste Shipment Manifest Information and Reporting" (60 FR 15649; dated March 27, 1995), which references use of the NRC Uniform Manifest, is enclosed for your information. The effective date of the NRC rule and required use of the NRC Uniform Manifest is March 1,1998, or earlier at the discretion of users. The effective date of the DOT rule is April 1,1996, in general, and April 1,1997, for required reporting in SI units. Because the effective date of the NRC rule is after the effective date of the DOT rule, we see no conflict in implementation of the two rules.
The NRC staff has coordinated this rulemaking with DOT since the earliest stages of developing a uniform manifest. Before issuing the proposed rule, D0T reviewed the rulemaking package, and concurred with the shipping paper portion of the NRC Uniform Manifest (NRC Form 540) that was developed to accompany the proposed rule. The NRC final rule, forms, and instructions were based on DOT regulations, including the proposed changes issued by DOT on November 14, 1989 (54 FR 47454). We also remained cognizant of changes 00T was considering in preparing its final rule. Because the NRC's final rulemaking is similar to the proposed rulemaking, which DOT had already reviewed, the NRC believed it was prudent to wait until promulgation of DOT's final rule before seeking DOT's concurrence.
In reviewing the DOT final rule, we noted one relatively minor inconsistency with the NRC instructions and the DOT rule. This inconsistency does not affect the NRC Uniform Manifest forms. The DOT rule no longer requires a listing of all radionuclides but will accept radionuclides that represent 9704080024 970327 PDR PR ,
20 60FR15649 PDR j
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+. .
Alan Roberts 2 )
I 95 percent of the hazard (il 172.203(d)(1) and 173.433(f)). The NRC !
instructions for completing the Uniform Manifest forms currently state (see l page 9, item 15) that all radionuclides present in the package be listed. We ,
will revise the NRC-instructions, when they are next updated, to be fully i consistent with DOT regulations. We intend to make other minor updates, as a !
result of current testing, to both the Uniform Manifest forms and the ,
instructions. These changes will be'done consistent with the implementation j
, schedules of the two rules. l We would appreciate your comments and concurrence by December 29, 1995. j Please respond to the U.S. Nuclear Regulatory Commission, Mail Stop T 10F12 {
Washington, DC- 20555-0001. ;
-In closing, we appreciate the support that DOT, and particularly John Gale, has provided in the development of our final rule and forms. Ir you have any ,
questions or if we can be of assistance, please contact Mark Haisfield of my 4 staff at 301-415-6196. l i
Sincerely, ;
T
, /s/ David L. Morrison i David L. Morrison, Director Office of Nuclear Regulatory Research l
Enclosures:
- 1. NRC's Uniform Low-level Radioactive Waste Manifest
- 2. Instructions for Completing NRC's Uniform Low-Level Radioactive -
Waste Manifest
- 3. Final NRC Rule Distribution:
RDB/Subj/rdg FCostanzi RAuluck DOCUMENT NAME:(R0BERTS. FIN) i .
- N* = No copy f' To seleeve a sepy of thi. docum.nt,6ndesete in the boa: "C' = Copy wahout attachenent/ enclosure "E" = Copy wdh a hrnent/ enclosure 0FFICE DRA* lC NMSS* l DRA* lC OffWr ' IC j)(tES ff NAME MHatsfield Wlahs .
TMartin /AM6rris DMorris6h DATE- 10/20/95 10/20/95 11/02/95 II /'; /95 // / /3/95 0FFICIAL RECORD COPY (RES File Code) RES
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