ML20141D574
| ML20141D574 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/1997 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20141D497 | List: |
| References | |
| SECY-97-096-C, SECY-97-96-C, NUDOCS 9706270259 | |
| Download: ML20141D574 (2) | |
Text
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NOTATION VOTE I
RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DIAZ
SUBJECT:
SECY-97-096 - MEMORANDUM OF UNDERST.AWDING AND INTERAGENCY AGREEMENT BETWEEN THE U.S.
DEPARTMENT OF ENERGY AND THE U.S. NUCLEAR REGULATORY COMMISSION ON THE CLOSURE OF l
HIGH-LEVEL WASTE STORAGE TANKS AT THE j
SAVANNAH RIVER SITE l
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Approved J
Disapproved Abstain yy p
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Not Participating Request Discussion De paper states that "HLW is defined in Appendix F of 10 CFR Part 50, s.nd does j
- COMMENTS, not include ' incidental' waste." However, Appendix F says
"(For the purpose of this statement of policy, 'high-levelliquid mdioactive wastes; means those aqueous wastes resulting from the operation of the first cycle solvent extraction system, or equivalent, and the concentrated wastes from subsequent extraction cycles, or equivalent, in a facility for reprocessing irradiated reactor fuels.)"
l The actual citation for the exclusion of " incidental wastes" is in the Statements of Consideration for the j
Advanced Notice of Proposed Rulemaking that preceded the rulemaking codifying the asove definition. I think it is unlikely that the staff will find a supportable basis for classifying this liquid waste to be " incidental" simply by virtue of its volume. Further, the several 100's of gallons in each tar.k that remains is likely to contain the most highly radioactive solids that have over time settled to the bottom of the tank. None the less, I approve the staff proposal to sign the MOU and IA which do not presuppose any utcome of the staff analysis, subject to the i
jQ attached comments, i
NWTURy
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Release Vote
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Withhold vote
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Entered on "AS" Yes No 4
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9706270259 970619 PDR COMMS NRCC g)
CORRESPONDENCE PDR I
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l-Commissioner Diaz' Comments on SECY-97-096 i
1.
Correct the last sentence in Section 2, paragraph 2 of the MOU. The defirition of HLW in App. F does not mention incidental waste, nor does App. F exclude it.
l 2.
In determining whether it is appropriate and permitted by law to designate the remaining several inches of HLW in the tanks as incidental, the staff should fully address poter,'Ja! risks and doses to workers and members of the public that could result from characterization and alternate disposal of the waste; the similarity or dissimilarity of the remaining liquid to that which has been treated as HLW; and the l
applicable statutes and regulations (e.g., the AEA, the Reorganization Act, the NWPA, the codified version of Part 50 App. F, etc.) goveming NRC responsibility and authority regarding HLW.
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