ML20155H324
| ML20155H324 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/1996 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Bishop A CANADA |
| Shared Package | |
| ML20155H058 | List: |
| References | |
| NUDOCS 9811100079 | |
| Download: ML20155H324 (3) | |
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ne UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enman.mant
%J May 31, 1996 Ms. A. Bishop. President Atomic Energy Control Board 280 Slater Street P.O. Box 1046, Station B Ottawa, KIP 5S9 CANADA
Dear Ms. Bishop:
I am responding to a letter from Mr. Richard Rawl, dated April 4, 1996, in which he requested that comments on the draft 1996 Edition of the International Atomic Energy Agency's (IAEA's)
- Regulations for the Safe Transport of Radioactive Material," Safety Series No. 6, be forwarded to you.
Many organizations in the United States have contributed to the multi-year effort to complete this edition, 'ncluding our national competent authority, the U.S. Departnerit of Transporta!!c:, as well as the Nuclear Regulatory Connission, other Federal agencies, national laboratories, and industry representatives.
- We agree with Mr. Rawl's letter that Ty values are the(UF ) transport provisions,pe C package stand hexafluoride and the incor Type C package standards were developed to address the air transport of large quantities of radioactive material, with exception for certain low dispersible materials.
Although Type C packaging standards are less rigorous than the United States packaging standards for the air transport of plutonium, the United States has made it clear that, consistent with United States law, any plutonium air transport to, or over, the United States will be subject to the more rigorous United States packaging standards.
Consequently, the United States does not oppose the IAEA Type C or low dispersible provisions.
The United States has, however, repeatedly objected to the draft provisions intended to address the other two principal issues. UF The draft UF regulations would require that cylinders and exemption values.
depleted or less than one percent enriched UF, be subjected to the thermal containing natural, test currently imposed on Type B package designs. The draft radionuclide specific exemption values (activity concentration limits for exempt material, and corresponding activity limits for exempt consignments) were developed to provide dose-based exemptions that harmonized with public dose limits contained in the " International Basic Safety Series for Protection Against Ionizing Radiation and for the Safety of Radiation Sources," Safety Series No.
115.
The United States positions on the draft provisions were expressed through various working papers and during working group and plenary deliberations at Revision Panel !!I, the Standing Advisory Group on the Safe Transport of Radioactive Material (SAGSTRAM), and Revision Panel IV.
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I A. Bishop 2
We are opposed to the draft UF, and exemption value provisions on the following bases that they have not been justified:
We are unable to identify a public health and safety problem with the current provisions.
In hundreds of thousands of shipments that span five decades, we are unable to identify any public health or safety impact attributable to the cu.rrent UF, and exemption value provisions.
Neither the draft UF, nor exemption value provisions provide significant improvement in safety.
The draft provisions would impose new complexity and economic burdens in transportation. The costs of imposing these provisions, particularly for UF would be substantial.
If the use of overpacks is required to meetth,ethermaltest,asmanyintheUF,itedStates.
industry believe, the cost could reach 120 million dollars to the Un This includes the cost of overpacks, incremental equipment, additional manpower requirements, and additional shipping requirements limited to.only one overpacked cylinder per truck, v(ersus two nottruck cargo is overpacked)..
The draft provisions'would decrease harmony between IAEA and Member State transportation regulations. Since neither the UF nor the exemption value provisions are needed for safety, their, adoption in the United States will depend primarily on the provisions' economic merit.
It is our judgment that both provisions would fall a domestic cost / benefit screening because we are unable to identify and quantify sufficient benefit to compensate for their costs. We are concern.J that, after the years of effort on this Edition, we, and perhaps nher Member States, will be forced to adopt domestic UF and exemption value provisions that are incompatible with those of IAEk.
The United States has cooperated, and will continue to cooperate, with the IAEA and the other Member States in issuing Safety Series No. 6.
It is not our intent to obstruct the completion or issuance of Safety Series No. 6.
However, our continuing concern about the magnitude of the impacts from these provisions, and our desire to avoid incompatibility with IAEA regulastons, compel us to disagree with the UF,hausted the review process ava and radionuclide specific exemption provisions. We believe we have ex the auspices of the Transportation Safety Standards Advisory Comittee (TRANSSAC, formerly SAGSTRAM), and that further review through TRANSSAC will not be, fruitful.
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A. Bishop 3
Accordingly, we 1recomend that the 1996 Edition be adopted without the UF or radionuclide specific exemption value revisions. Shouldthedraftprovisions be retained by the Advisory Committee on Safety Standards, we intend to provide a dissenting view regarding these provisions no the Board of Governors, when Safety Series No. 6 is submitted for approval.
Sincerely, MYU Jame.: w i
James M. Taylor i
Executive Director for Operations 8
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