ML20203E833
| ML20203E833 | |
| Person / Time | |
|---|---|
| Issue date: | 12/12/1997 |
| From: | Hauber R NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | Selph J AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9712170197 | |
| Download: ML20203E833 (2) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.c. 306 & 4001
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\\DEC Yt '51 Mr. Jimmy R. Selph DSSI Radiation Safety Officer Diversified Scientific Ser/lces, Inc.
657 Gallaher ' toad Kingston, TN 37763
Subject:
Applications fo Specific License to import / Export Radioacuve Waste (NRC assigned I, cense numbers IWOO4 and XWOO2)
Dear Mr. Selph:
This is in bri,ig you up to-date on the status of the subject applications and to request the submission of additional information which is necessary for us to complete our review, as follows:
- 1. More specific information regarding the chemical and physical form of the incoming material. Section 110.32(f)(1) requires that the maximum quantity of the material to be imported or exported be specified, along with its chemical and physical form. The material description for wastes te be imported does rnt sufficiently describe the chemical or physical form of the incoming waste. Your application states that incoming wastes will be "... typically liquid, used oil, and/or other combustible materials containing primarily H-3 and C-14, mixed fission product radionuclides, and other contaminants." Please describe the other contaminants, especially those that may be hazardous constituents, and what other types of waste (i.e. non-typical) are planned far shipment.
- 2. Classification of the waste (as defined in 10 CFR 61.55) and route of transit. Section 110.32(f)(5) requests this information, and your application did not provide this. Your application states that the wastes will be destroyed and not disposed, and that therefore the classification requirement is not applica! ie. Part 110 does not state this qualification, however.
Regarding the route of tranc.it, some statement is needed, if only in general terms.
- 3. Clarification of material description. The application states that the imported waste will be " destroyed," but at the same time acknowledges that ash and residue from neutralization of acid forming gases will be returned to Canada as " solids." On the face of it, these materials I
are wastes and wovid fall under all of the provisions of part 110 that apply to wastes, including i
the requirement in 110.42 for receiving country authorization of the retum of the waste. One of the dccuments provided as part of the application states that the retumed material shall meet
~{}fD? N certain " Waste Acceptance Criteria." Unless a defensible rationale is provided for use of the terrn ' solids," as oppesed to " waste," the material should be termed waste and the applicable provisions of Part 110 used to evaluate the export.
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- 4. Agreement by a low-level waste compact or State to accept the material for management purposes or disposal. Section 110.32(f)(6) states that, for proposed import of waste, the status of any agreements by a LLW compact or State to accept the material for managemert purposes should be described. It is not required that /ou, the applicar'. obtain LLW cornpact or State acceptance of the waste for management p srposes, but you are reqund to advise us whether or not any such agreements or unde estandings have already been obtained through your own efforts.
- 5. Clarification as to whether the waste to be imported, ar d the waste to be exported, includes mixed waste. Your application states that the waste will oe received under your RCRA permit; and the description of the waste to be exported may also oe mixed waste.
- 6. Agreement from Ontario Hydro to accept the waste exsected to be returned. Your application contains an internal me norandum from Ontario Hydra stating that the proposed waste for export must be demonstrated to be from Ontario Hydre only. Given that waste processing often involves intermingling of ash from different genorators during incineration, for example, additional information should be provided that demonstrates that Ontario Hydro will be able to accept the waste uxpected to be returned. It is not clear s vhat the position of Ontario Hydro is on this issue, since only an internal memo was provided A letter to DSSI from Ontario Hydro would be helpfulin this respect, if you neod additional clarification regarding the requested informt tion, please call me or Betty Wright at 301415-2344.
Sincerely, Pa rud-l l
Ronald D. Hauber, Director Division of Non-proliferation, Eeports and Multilateral Relations Office of International Programs i
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