ML20141D044
| ML20141D044 | |
| Person / Time | |
|---|---|
| Issue date: | 05/12/1997 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Turner A AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20141D049 | List: |
| References | |
| REF-WM-194 NUDOCS 9705190308 | |
| Download: ML20141D044 (5) | |
Text
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'!%y p*. k UNITED STATES r
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'2 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&O001
%,,, May 12, 1997 l ! 'Mr A. James Turner. Director l Environmental Affairs .
l Ameristeel
- 5100 W. Lemon Street i Suite 312. .
l Tampa, Florida 31328 l
l
Dear'Mr. Turner:
- )
I am writing in res)onse to your letter dated April 10. 1997. regarding a question about the luclear Regulatory Commission's role in the disposal of material discussed in the Branch Technical Position (BTP) entitled L " Disposition of Cesium-137 Contaminated Emission Control Dust and Other Incident-Related Material."
! In your letter, you stated that you currently possess radioactive material rgulting from the inadvertent melting of a source containing Cesium-137
( Cs) at your facility in Tennessee and that, because detection of the
- melting did not occur immediately, some of ths material was transferred to zinc-recovery facilities in Tennessee and Utah. You also indicated that some of the material may be dis)osed of at a Subtitle C facility in a State where ,
,. NRC retains regulatory autlority for the radioactive portion of the material l l (a "non-Agreement State"). Specifically, you requested the NRC staff's view 1 l of your interpretation of the NRC's role with respect to the material disposed i of in a Subtitle C facility in a non-Agreement State. ;
! J l Adherence to all provisions of the BTP is critical to ensuring that the l l material is safely. stored, trec e2. and transported, as well as ensuring that the final waste form and total aa.ivity disposed of in the Subtitle C facility is in compliance with the BTP and will not exceed the potential doses to 1 workers or the public estimated in the BTP. Accoroingly. NRC needs to know whether the limitations on the disposal in the Subtitle C facility discussed i in the BTP are observed, or whether the Subtitle C facility would need to
.obtain a radioactive materials license for the possession of the material.
The material currently possessed by Ameristeel a pears to be the type of !
l material discussed under the BTP. and we are ready to work with Ameristeel. /
L the State of Tennessee, and other Agreement States to promptly review any '/
proposed disposals under the BTP. In addition, we believe that the method "
s described in the penultimate paragraph of your letter will provide some of the information necessary to document the disposal in the g blic record. However, as custodians of the public record and monitor of the Cs source term in such facilities. NRC also needs to be confident that the Agreement States authorizing the transfer to the Subtitle C facility also. adhered to the conditions of the BTP. Therefore, we request that Ameristeel also submit l copies of the Agreement State approvals of your request for disposal for
- inclusion in the public record.
When Ameristeel obtains the appro)riate Agreement State approvals and demonstrates to NRC that all of t1e conditipns discussed in the BTP have been WID SWA l
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l 9705190308 970512
A. James Turner satisfied. NRC staff should be able to accept the disposal of the material in a Subtitle C facility. Also, before proceeding with any actions concerning the material that was transferred to the zinc-recovery process facilities.
Ameristeel must ensure that it is suitable for disposal in a Subtitle C facility.
If you have any questions concerning this letter, or wish to discuss the manner in which the NRC staff will review requests for disposal under the BTP.
please contact Mr. Dominick Orlando at (301) 415-6749.
Sincerely.
.$A jf '
Carl J. Paperiello. Director Office of Nuclear Material Safety and Safeguards l
l
.' As James Turner l- satisfied, NRC staff should be able to accept the disposal of the material in
, a Subtitle C facility. Also, before proceeding with any actions concerning l the material that was transferred to the zinc-recovery process facilities.
Ameristeel must ensure that it is suitable for disposal in a Subtitle C L facility. <
l If you have any questions concerning this letter, or wish to discuss the manner in which the NRC staff will review requests for disposal under the BTP, :
please contact Mr. Dominick Orlando at (301) 415-6749. !
Sincerely, N D 8DJ
- n190!m R ibyp I
Carl J. Pa)eriello, Director Office of luclear Material Safety '
and Safeguards TICKET: '97-180 DISTRIBUTION ,
Central File LLDP r/f NMSS r/f DWM t/f PSobel CPa)eriello MKnapp i l JGreeves RFonner MFederline RBangart CPoland PUB.IC To receive a copy of this document in small box on "0FC:" line enter: "C" 1 Copy without attachment / enclosure: "E" =
< Copy with attachment / enclosure: "N" - No copy
' 'f Path & File Name: S:\DWM\LLDP\DA0\97-180 OSee previous concurrence hg# h,e R/ d/(7 na j OFC LLDP* LLDP* OS(Y LM)Rj Al DWM/) OSP* N#
NAME D0rlando/bg RNelson Nonner MNkey (k RBangart DATE 4/28/97 4/29/97 5/05/97 N/29/97 [5/I/97 05/d/97 .
0FC NMSS NMSS NAME dd CPaperiello DATE 7 // 7] 97 / /97 0FFICIAL RECORD C0FY ACNW: YES X NO Category: Proprietary or CF Only IG . YES NO X LSS : YES NO X Delete file after distribution: Yes X No
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r, , A. James Turner Adherence to all provisions of BTP is critical to ensuring that the material is safely stored, treated and transported, as well as ensuring that the f' 1 waste form and total activity disposed of in the Subtitle C facility is i compliance with the BTP and will not exceed the potential doses to wor s or the public estimated in the BTP. As such NRC can only approve reque s for disposal of this material in a Subtitle C facility when NRC as ade te assurance that all conditions discussed in the BTP have been adhe d to and the potential doses to workers and the public do not exceed tho described under the BTP, If material were disposed of in a Subtitle C cility in a non-Agreement State without specific authorization from NRC RC would need to ascertain whether the Subtitle C facility would need to ob in a radioactive materials license for the )ossession of the material and hether the facility l transferring the material lad violated the conditions o its radioactive materials license or NRC's regulations. l The material currently possessed by Ameristeel appe s to /be the type of material discussed under the BTP and we are ready work with Ameristeel, the l State of Tennessee, and other Agreement States t promptly review any proposed !
disposals under the BTP. If Ameristeel obtain he appropriate Agreement i State approvals and demonstrates to NRC that e conditions discussed in the BTP have been satisfied NRC staff should be ' ble to concur with the disposal of the material in a Subtitle C facility. Iso, before proceeding with any actions concerning the material that was t i process facilities Ameristeel must ensu jransferred that it is to the zinc-recovery suitable for disposal in l a Subtitle C facility. !
If you have any questions concernin his letter, or wish to discuss the manner in which the NRC staff will eview requests for disposal under the BTP, please contact Mr. Dominick Orlan at (301) 415-6749.
Sincerely, Carl J. Pa)eriello, Director Office of luclear Material Safety and Safeguards TICKET: 97-180 DJSTRIBUTION Central File LLDP r/f NMSS r/f PSobel ACNW
, MFederline
'To receive a copy of this docume in small box on "0FC:" line enter: "C" - Copy without attachment / enclosure; "E" -
Copy eith attachment / enclosure 'N" - No copy Path & File Name: S:\D \LLDP\DA0\97-180 CSee previous concurre e 0FC LLDP* [ LLDP* OGC LLD) f N DWM OSP NAME D0rlando/g RNelson dckey DATE 4/28/7 4/29/97 / /97 h/#/97 / /97 / /97
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l 0FC MS NMSS l NAME [MKnapp CPaperiello DATE [ / /97 '/' '/97 I 0FFlCIAL RECORD C0FY
[ ACNW- ES X NO Category: Proprietary or CF Only X l IG . YES NO X L : YES NO X Delete file after distribution: Yes X No
r .'A[JamesTurner ]
Adherence to all provisions of BTP is critical to ensuring that'the material l is safely stored. treated. 'and transported, as well as ensuring that the final waste form and total activity disposed of in the Subtitle C facility is in ,
i compliance with the BTP and will not exceed the potential doses to workers '
the public estimated in the BTP. As such. NRC can only approve requests r ;
disposal.of this material in a Subtitle C facility when NRC as adequate !
.. assurance that all conditions discussed in the BTP have been adhered and l : the potential doses to workers and the public do not exceed those d ribed l under the BTP If material were disposed of in a Subtitle C facil' y in a non-Agreement State without specific authorization from NRC NRC uld need to ascertain whether the Subtitle C facility would need to obtain radioactive )
l materials license for the aossession of the material and wheth the facility '
transferring the material lad violated the conditions of its adioactive materials license or NRC's regulations.
l Because the material. currently possessed by Ameristeel app rs to be the type !
of the material discussed under the BTP and in recogniti of the efforts made l by Ameristeel to comaly with the intent of the BTP: (i. .. the safe disposal of the material) we Jelieve that dis)osal of the mater' 1 should not be delayed and we are ready to work wit 1 Ameristeel to hieve this goal.
Therefore, if Ameristeel can demonstrate to NRC tha all conditions discussed in the BTP have been satisfied. NRC staff should able to. concur with the ;
- dis)osal of the material inla Subtitle C
- facilit . Also, before proceeding ;
wit 1 any: actions concerning the material that transferred to the zinc- i recovery process facilities. Ameristeel must' sure that it is. suitable for disposal in a Subtitle C. facility. > !
If you have any questions concerning this ter, or wish to discuss the l manner in which the NRC' staff will review e !
please contact Mr. Dominick _ Orlando at ( 1) quests 415-6749. for disposal under the Bl?.
l cerely.
Carl J. Pa)eriello. Director Office of luclear Material Safety and Safeguards TICKET: 97-180 DISTRIBUTION Central File LLDP r/f NMSS r/f PSobel ACNW DWM r/f
,^ MFederline
.'To receive a copy of this document i small box on "0FC:" line enter- "C" - Copy without attachment / enclosure; "E" =
"N" No copy
- [ Copy Path tvith
& File attachment Name: S:\DWM\/ enclosure: P\DA0\97-180 0FC 'LLDP [LLDPf/A OGC LLDP DWM OSP-NAME' D0rlaW6[bg / RNe#'$n 1s JHickey DATE- 4/N/97[ 4/#l/97 / /97 / /97 / /97 / /97 1
L OFC NMS/ NMSS l NAME M[ app CPaperiello
- DATE [/ /97 / /97 0FFlCIAL RECORD COFY ACNW: YF .)L NO Category: Proprietary or CF Only i IG : Y NO ,
LSS.: S NO Delete file after distribution: Yes No
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