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S NUCLEAR REGULATORY COMMISSION
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Gregg S. Larson 0 2 Igj Convenor, LLW Forum c/o Afton Associates, Inc.
403 East Capitol Street Washington, DC 20003
Dear Mr. Larson:
Thank you for your letter of November 5,1993, informing the Chairman of the position of the LLW Forum regarding the importance of finalizing the uniform manifest rulemaking and manifest forms, as proposed. As you are aware, the NRC proposed manifest was acceptable to the Department of Transportation (DOT), but the industry had serious objections to its format, and wished to maintain formats being used by the current low-level waste disposal facility operators. Therefore, interactions with the DOT have been undertaken to determine the suitability of the in-use manifests.
Based on comments raised i
at the June 15, 1993 public meeting, we believe that this issue requires resolution prior to our publication of a final rule and imposition of a uniform manifest. As discussed in my August 23, 1993 letter to you, a letter has been sent to DOT outlining the current situation, and asking for their decision on the suitability of the format of existing manifests for meeting 1
D0T shipping paper requirements. We understand that DDT is drafting a response.
In addition to DOT's views on the potential manifest formats, our final rule is dependent on finalization of their Hazardous Materials Regulations (proposed rule dated November 14, 1989 -- 54 FR 47454). We, therefore, a)preciate your corresponding letter to DOT informing them of the priority of t1e uniform manifest rulemaking. We are proceeding to finalize our rule, forms and instructions while awaiting the aforementicned DOT actions.
We appreciate your input and support and look forward to your continued I
interaction.
Sincerely, Eri eckjor IDirector Off of Huclea Regulatory Research 9704000055 970327
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,o,2y,,,y, soy NRC/ DOT INTERACTIVE MEETING ON THE UNIFORM MANIFEST PRELIMINARY SCOPING MEETING March 8,1993
- Procedure for Finalization of the Uniform Manifest Rule current status of the rulemaking resolution ofissues with DOT next draft and its availability timetable for completion Interactive Meeting purpose of meeting scheduling of meeting attendance facilitation agenda Outstanding Issues / Content of the Rule a
Invited NRC Office of Nuclear Material Safety and Safeguards Mike Weber Bill Lahs NRC Office of Nuclear Regulatory Research Mel Silberberg Mark Haisfield Afton Associates,Inc.
M. A. Shaker Holmes Brown Lori Tripoli J
i TROXLER November 30, 1994 g,
FOR Mr. Leonard Slosky Executive Director Rocky Mountain Low-Level Waste Board 1675 Broadway Suite 1400 Denver, CO 80202 3
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Dear Mr. Slosky:
We are writing in response to your letter dated October 18, 1994 i
regarding export requirements of the Rocky Mountain Compact.
We would like to clarify that when an owner of a portable nuclear gauge returns the device to Troxler, they are not sending us
" waste".
They are simply returning a piece of equipment to Troxler which we are licensed to possess under our North Carolina radioactive materials license.
We agree with the position i
f expressed by Mr.
Sher Bahadur of the U.S.
Nuclear Regulatory Commission in the attached letter (addressed to Mr. Todd Lovinger) 4 which indicates that there are no manifesting requirements when radioactive material (not considered waste) is shipped from one user to another or if the manufacturer intends further Use of the sealed source.
Troxler is a responsible manufacturer with a Radiation Safety Department trained to handle the technical as well as administrative aspects of the return of our equipment.
We have nearly 40 years experience in this area with no problems in the past.
We feel that the position of the U.S. NRC is in the best interest of the health and safety of the general public.
policy and regulations should make it as easy as possible for owners of equipment to return radioactive materials not considered as waste to the manufacturer of the equipment. The Rocky Mountain Compact's policy places the burden of responsibility on Troxler customers and makes it more difficult for Troxler to oversee the safe return of equipment.
The current unresolved policy requires immediate clarification as it is an obstruction of business at present.
Troxler has pending trade-ins and customers who are un-trained in completion of export documentation who will be attempting to comply.
These customers, under the current policy, will be required to execute forms which previously have not been required for equipment containing non-waste radioactive materials.
Troxler Electronic Laboratories,Inc.
- Troxler International, Ltd.
3008 Comwalus Road, P.o. Box 12057, Research Triangte Park, North Carohna 27709, U.SA Telephone 919/549 8661, Cable Trome6ec, Telex 6844902 TRoXL UW
- FAX 919/549-0761
E, page 2 November 30, 1994 Mr. Slosky We expect this will cause confusion and an unnecessary expense for all involved.
We request that the requirement for an export permit be dropped immediately so that we can successfully complete our business transactions in the Rocky Mountain Compact states.
We will appreciate your immediate attention to this matter.
please do not hesitate to contact us if we can be of assistance.
Sincerely, TROXLER ELECTRONIC LABORATORIES, INC.
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Michael R. Dishman Suzanne Troxler Babcock Corporate Radiation Safety Officer Vice-prmident of Administration cc:
Mr. Sher Bahadur Mr. Todd Lovinger
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