ML20154P333
| ML20154P333 | |
| Person / Time | |
|---|---|
| Issue date: | 11/15/1979 |
| From: | Rich Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TASK-TF, TASK-URFO NUDOCS 9810220295 | |
| Download: ML20154P333 (2) | |
Text
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UNITED STATES -
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'n NUCLEAR REGULATORY COMMISSION l
h WASHINGTON, D. C. 20555
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November 15, 1979 MEMORANDUM FOR: John Surmeier
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Licensing Process and Integration Branch Division of Waste Management L
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'FROM:
R. Dale Smith, Chief Low-Level Waste Licensing Management Branch Division of Waste Management
SUBJECT:
S.1821 " NUCLEAR WASTE MANAGEMENT AUTHORITY" Following are our comments on the subject Bill:
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. In general, we support the estebiishment of a senerete euthority to assume responsibility for the planning, development, management, u
operation, and care of high-level and TRU disposal sites. There d
are strong arguments, however, for state sponsored LLW dispo' sal i
sites.
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The Bill is unclear with respect to the responsibility of the authority l
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.regarding the disposal of LLW.
LLW is included within the definition j
- of nuclear waste (see Section 103 (5) on page 5) although many of the sections following Section 103 which use the term " nuclear waste" i
f appear to only relate to HLW, spent fuel and TRU waste.
Do the authors intend that these sections should also apply to LLW7 (for example, see 1
Sections 101 (9) and (11) (a), 302 and 305).
Several of the latter sections use the specific terms HLW, spent fuel and TRU waste in place of the ganeral term " nuclear waste".
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a Section 201 (c)(1) addresses the "ecquisition of existino nuclear waste W
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-facilities not owned by the United States".
Is this section intended a
to include acquisition by the authority of the existing and any new 0
commercial sites? If so, this and other sections should specifically j
-spell out responsibilities regarding' acquisition of LLW sites and the t
I authority's role and responsibility with respect to further operation-ij decomissioning; post-operational maintenance, surveillance and monitor-(
ing;. and collection and dispersement of funds for such activities.
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'k Section 404, the only section specific to LLW, does not address these
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aspects although they seem to be generally covered by other sections (e.g., Sections 303, 305, 308, 501, 503 and 506).
I have outlined q
below, the specific responsibilities, etc. we believe the authority should have regarding LLW disposal:
1.
Responsibility for all existing DOE and any new defence and non-l l
l defense wastes and sites.
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s John Surmeier F j
2.
Ability to accept title to and cwn both existing and new sites i
used for disposal of commercial waste. This authority should not be " exclusive" but should allow states to own comercial i
sites during the operating phase with subsequent transfer of 1
i ownership responsibility to the Authority at site closure.
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3.
Ability to collect, hold and disperse funds for operations, j
maintenance, remedial action, surveillance and monitoring of sites.
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Emergency Authority to site, design and operate sites 3to provide j
for contingency storage or disposal capacity for commercial wastes.
With respect to NRC regulation, we believe NRC and the Agreement States should continue to license the commercially operated sites whether they
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L are sited on land owned by the Federal or State Government.
NRC regulatory authority over sites operated by the Authority for defense, nondefense and
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" emergency" commercial wastes should be implemented as set out in l
b Recommendations 1 and 2 of the report " Regulation of Federal Radioactive 9
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) Waste Actiyities", NUREG-0527.
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\\DL 4 The definitions of TRU and LLW on page 6 (Items 7 and 8) use the 10 i
nanocurie per gram limitation.
This limit may be subject to change based on our regulations development effort and these definitions should reflect that NRC will be defining TRU and LLW.
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The definition of nuclear waste in Section 302 and 305 should specifically 9
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exclude LLW.
In Section 302, we do not want LLW from foreign reactors
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jmpar_ted for disposal. fin Section 305, we do not consider 100 year 6
fretreivability for'LLW to be practical even for storage.
4 We agree with the need for the LLW plan as described in Section 404.
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N LLL R.
ale Smith, Chief Low-Level Waste Licensing Management Branch s
Division of-Waste Management i
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