ML20203N679

Responds to Re Clarification of 10CFR20.203(f)(1) & (2) Requirements.Possibilities for Reducing Burden of Labeling Containers of Dry Radwaste Listed

ML20203N679
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/14/1981
From:	Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Trimble D ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8610170093
Download: ML20203N679 (3)

Text

~ ~

(3)q Str 1 g ggg Docket Nos. 50-313

~

50-368 Mr. David C. Trimble Manager, Licensing Arkansas Power & Light Company P.O. Box 551 Little Rock, Arkansas 72203

Dear Mr. Trimble:

On June 19, 1981, you wrote to the Director of Nuclear Reactor Regulation requesting clarification of 10 CFR 20.203(f)(1) and By letter dated July 13, 1981, to Mr. Cavanaugh you were(2) requirements.

informed that your request was being referred to this. Division for resolution.

Your letter referred to a citation, resulting from the NRC Radiological Assessment Team Appraisal, for failing to label containers of radioactive material in accordance with 10 CFR 20.203(f)(1) and (2).You indicated that although you agree that the specific situation cited was a violation of 10 CFR 20.203(f)(1) and (2), you viewed the requirements to label every container impractical,ofcostly, radioactive material and virtually inside to impossible " Controlled compl Access" at the ANO requested clarification of 10 CFR 20.203(f)(1) and (2)y with. You.therefore allow more flexibility with respect to container labeling requirements. requireme Some degree of flexibility with respect to 10 CFR 20.203(f)(1) and (2) require-ments is allowed through the exceptions provided in 10 CFR 20.203 f (3). If these exceptions do not provide the relief necessary to make your(ra)dioactive materials control program practical to implement, exemptions may be requested in accordance with 10 CFR 20.5,01. .

i You specifically requested a statement regarding (a) the definition of a container and b) the situation or time when labeling must commence.

Since there is no spe(cial definition (dictionary) meaning of the term a of " container" in 10 CFR Part 2 which material is held or carried.gplies; that is a container is "a thing in In general, when the radioactive material is added to it. However, a container should be labeled we appreciate that certain conditions may exist whdre the addition of appropriate information to the label may necessitate some delay. For example, dose rate information may not be added until the container is filled, or the final dose rate information

- may not be 'added until the container ,can be moved to a low-background area for measurement. ~

t In summary, although 10 CFR 20.203(f)(1) and (2) do not provide the " flexibility" you desire, we suggest that you consider the following possibilities for reducing the burden of labeling containers of dry radioactive waste.

consider the possibility of utilizing the exceptions provided in 10 CFRFirst, 20.203(f)(3). Second, consider applying for an exemption, pursuant to 10 CFR 20.501, from the requirements of 10 CFR 20.203(f). In any case.

l _- a. - - - --

B610170093 810914 a PDR ADOCK 0500 g 3 ,j .

David C. Trimblo -

2-to be acceptable, alternative methods of control (such as those suggested by you of color coding and establishing posted local radioactive materials storage areas) must provide worker protection and material controls equivalent to those of the labeling described in 20.203(f)(1) and (2). These alternative methods should assure that exposures are ALARA, and should be formally docu-mented in procedures and included in training. Third, should you find that these approaches do not provide the flexibility you desire, you might consider submitting a petition for rulemaking, pursuant to 10 CFR 2.802. Under this provision, interested persons may petition the Commission to issue, amend or rescind any of its regulations.

Sincerely, Harold D. Thornburg '

Director Division of Safeguards and Radiological Safety Inspection Office of Inspection and Enforcement bec:

J. F. Stolz, NRR R. A. Clark, NRR D. Collins, NRR J. H. Joyner, RI A. F. Gibson, RII R. Greger, RIII G. D. Brown, RIV B. Murray, RIV J. Everett, RIV H. E. Book, RV Record Note: Comments of ELD (Ron Mount /J. Lieberman) and NRR (R. Serbu/

D. Collins) have been incorporated.

j .'( q.

WPU:JD 5520 RRS,5: RSL LJCunningham

.R$l IE LHigginbotham D:5 HDT rg 8/18/81 /2 /81 / 'l/81 / /81 q/j _

ee~

....__.,-.,--.-u - _ . m --- - - , ~ . . _ , - - , . _ . , - y. - - -

Mr. David C. Trimble cc:

Mr. William Cavanaugh, III Senior Vice President - Energy Supply Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Mr. James P. O'Hanlon General Manager Arkansas Nuclear One P.O. Box 608 Russellville, Arkansas 72801 l

Mr. William Johnson I U.S. Nuclear Regulatory Commission I P.O. Box 2090 Russellville, Arkansas 72801 {

l Mr. Robert B. Borsus Babcock & Wilcox Nuclear Power Generation Division Suite 420, 7735 Old Georgetown Road Bethesda, Maryland Mr. Nicholas S. Reynolds Debevoise & Liberman 120017th Street NW Washington, DC 20036 Arkansas Tech University -

Russellville, Arkansas 72801 Honorable Ermil Grant Acting County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 l

Director, Bureau of Environmental i Health Services '

t 4815 West Markham Street I Little Rock, Arkansas 72201 U.S. Environmentai Protection Agency Region VI Office ,

1 ATTM: EIS COORDINATOR 1201 Elm Street First International Building Dallas,-Texas 75270

_- . -