ML20203F427
| ML20203F427 | |
| Person / Time | |
|---|---|
| Issue date: | 12/12/1997 |
| From: | Hauber R NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | Selph J AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9712170377 | |
| Download: ML20203F427 (2) | |
Text
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j NUCLEAR REGULATORY COMMISSION o
WASHI**GTON, D.C. *am naat 49.....
- DEC WE7 Mr. Jimmy R. Selph DSSI Radiation Safety Officer Diversified Scientific Services, Inc.
657 Gallaher Road Kingston, TN 37763
Subject:
Applications for Specific Licenses to import / Export Radioactive Waste (NRC assigned license numbers IWOO4 and XWOO2)
Dear Mr. Selph:
Thls is to bring 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 to be imported does not 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 for 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 classification requirement is not applicable. Part 110 does not state this q application states that the wastes will be destroyed and not disposed, and that therefore the y
Regarding the route of transit, some statement is needed, if unty in general terms.
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- 3. C!anfication 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 scid forming gases will be retumod to Canada as " solids." On the face of it, these materials are wastes and would fall under all of the provisions of part 110 that apply to wastes, including d'l J 5'7 the requirement in 110.42 for receiving country authorization of the retum of the waste. One of the dnuments provided as pari of the application states that the retuined material shall meet certain Maste Acceptance Criteria." Unless a defensible rationale is provided for use of the t*rm " solids," as opposed to " waste," the material should be termed waste and the applicat.:e 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 management purposes should be described. It is not required that you, the applicant, obtain LLW compact or State acceptance of the waste for management purposes, but you are required to advise us whether or net any such agreements or understandings have already been obtained through your own efforts.
- 5. Clarification as to whether the waste to be imported, and the waste to be exported, includes mixed waste. Your application states that the waste will be received under your RCRA permit; and the description of the waste to be exported may also be mixed waste.
- 6. Agreement from Ontario Hydro to accept the waste expected to be returned. Your a.pplication contains an internal memorandum from Ontario Hydro stating that the proposed waste, for export must be demonstrated to ta from Ontario Hydro only. Given that waste processing often involves intermingling of ash from different ge nerators during incineration, for example, additionalinformation should be provided that demor,strates that Ontario Hydro will be able to accept the waste expected to be returned it is not clear what 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 helpful in this respect.
If you need additional clarification regarding the requested information, please call me or Betty Wright at 301-415 2344.
Sincerely, OrifM0%jby r
Ronald D. Hauber, Director Division of Non-proliferation, Exports and Multilateral Relations Office of International Programs DISTRIBUTION:
l Licensa files Central Files: T-3 C3 (IP-2A-8)
OIP Desk Officer JKennedy, NMSS TRothschild, OGC PDR DCS4iiWiie OIP r/f DOCUMENT NAME: G:\\ EXPORTS \\DSSIO1.LTR To receive a copy of this document, indicate in the box: "C" = Copy without enclosures *E" = Copy with enclosures
- N' = No copy OFFICE O,1f/NF#R l
OlP/NEMR l NAME A4 %IVfIQht:rjg RDHauber M DATE if/p/97 7
12/t 97 i'
OFFICIAL RECORD COPY I
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