ML20207N164
| ML20207N164 | |
| Person / Time | |
|---|---|
| Issue date: | 10/21/1987 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20205F142 | List:
|
| References | |
| FOIA-88-361 NUDOCS 8810180535 | |
| Download: ML20207N164 (3) | |
Text
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MEMORANDUM FOR: Victor Stello, Jr. l Executive Director for Operations i l
l FROM. Hugh L. Thompson. Jr.. Director i Office of Nuclear Material Safety !
and Safeguards l 1
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SUBJECT:
REYlEW OF RESN!K0FF REPORT ENT!TLEO. 1IVING WITHOUT LAN0 FILLS I i !
. Marvin Resnikoff recently wrote a report on Low-level Radioactive Weste Disposal !
i entitled, Livine Without Landft11s ,
i Early in the development of this report we were asked to participate in the j i pro ect and review an outline of the report. At that time we responded that it j J wou d be inappropriate for us to participate in the project. We were later r
< offered an opportunity to review a draft report. We provided broad comuments l
! following a limited review in June 1987. We concluded that major revisions ;
i would be needed to make the report an objective one. While the final report l 1 attempts to address most of our earlier comments (see pp. 87-88 of the attachet j i report's. it contains major statements and conclusions with which we disagree. l
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These statements and conclusions involve some of the fellowing areas: .
l a. The use of the term "hazardous life" which is defined as 100 times the I t maximum permissible concentration values in 10 CFR Part 20.
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- b. Discussion of changes made between the publication of the 10 CFR Part 61 {
l I proposed and final rules. l i
- c. That all low level wastes should be stored at nuclear power plant sites, i
! d. That many low level wastes currently suitable for disposal under 10 CFR Part 61 should be reclassified as high-level waste. {,
j e. That above ground storage with eternal vigilance is needed to protect !
j public health ard safety,
'i In order to be prepared to respond to the anticipated public and Congressional consents on the Resnikoff document, we will review the report focusing on the !
j major issues Mr. Resnikoff has raised. We anticipate this review to be completed i l
on November 30, 1987. The staff contacts for this review are T. C. Johnson !
(x74720)andG. Roles (x747g1). j 1
, M Neth L Nepest,4. )
I h L. W. Jr. Directee Of ice of Nuclear Material Safety )
and Safeguards I i
Enclosuret i Report entitled, i Livine Without Landfills 1
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- l golg 800914.
RESNIKC68-341 PDM L i
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i DDAFT PEVIEW PLAN RESN!kOFF PTPORT j A. Objectivl l
- 1. Frovide a review of Living Without landfills sufficiert to respcnd cuickl,v to external com ents and cuestions. j l
- 4. Provide a 1012 page sumary of the PRC coerents. l l 8. Preposed Review l
The proposed review censists of a detailed aralysis of the major issues ;
raised in tiving Withcut landfilis. Points of minor disagreement would :
nct be addretted. Our coments would ccrsist of the followir.g: ;
- 1. Identific.ation of r.ajor statements or conclusions with which we I disagree, j I
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- i. Discustice of why we disagree. This discussion should present in ,
l detail our analysis with data or information supporting our position. i
- 3. Presentation of cur conclusion based on our analysis of the data or l inferr.ation, j C. Products The products would include a detailed set of comments on the major issues in Living Witbeut landfills containing the information in item B above and ,
e sumary document of IN2 pages. !
i D. Interactions f
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Within WPLL review of specific sections would be requested from LLTB. !
G. W. Roles and T. C. Johnson would provide coordination and LLRB review.
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Review of specific sections wuld also be reouested froe INNS. RES, SP ;
and NRR. Any legal issues raised in the review of the document would be i forwarded to OGC for comment, I
linformation and references not fully documented in living Without landfillo i would be reouetted in writing from E. Resnikoff. (These reouests would no", !
be espected to delay our review or product preparation.) l l
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l E. Resources WMLL planned resources are estiPated to be as follows:
PE: C staff-weeks TP: 2 staff-weeks These resources would be needed for the detailed rLview and tocumentatior, of ecmaents. These resource levels would affect other current activities ,
as follows:
LLRB: 1. Precaration of the LLW data base ruleraking justificaticn [
would be delayed one month, s
- 2. Review of the Impell topical report would be delayed one I month.
- 3. Preparation of a Thompson briefing er decommissioning would be delayed one month.
- 4. A planned meeting with CPA to discuss remaining mixed weste I loint activities would '.*e delayed cne month. j LLTB: To te Determined l F. Schedule
- 1. Review initiated 10-19-87
- 3. Oraft comments prepared 11-06 87 '
4 Letter to Resnikoff requesting additional inforwation, if needed 11-09.h7 1
- 5. Cerr.ent package completed 11-20 87 l
- 6. Summary documer.t draf t prepared 11 20 87 i
- 7. Summary document completed 11-30 87 i n
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