ML20210P403
| ML20210P403 | |
| Person / Time | |
|---|---|
| Issue date: | 10/24/1986 |
| From: | Roles G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Reinecke R ABB IMPELL CORP. (FORMERLY IMPELL CORP.) |
| References | |
| REF-WM-53 NUDOCS 8702130382 | |
| Download: ML20210P403 (4) | |
Text
MT 24 M WM-53/GWR/8/22/86/1 WM Record File M 1 Picicct j [ _
Royce Reinecke PM I Impell Corporation Technology Park / Atlanta
~ Distribution-333 Research Court
- m__ f Norcess, GA 30092 O _
2Q_
Dear Mr. Reinecke:
/
Our review of the WASTETRAK topical report has included our perusal of the May 1984 draft report, supplementary information provided to us via your March 18 and July 25 letters, the WASTETRAK users manual, and the WASTETRAK programmers guide. Based on these submittals, we see no major reason at this time why the WASTETRAK system could not be used as an acceptable method for classifying wastes based on user-input isotopic or dose rate data, and preparing manifests E
for shipments to low-level waste disposal sites. We would therefore like to provide you with a summary of the remaining steps that have to be undertaken by F--
our respective organizations to complete the topical report review. This L
~
summary may be considered in two parts:
1.
Unresolved Issues 2.
Procedures for Completion of an SER and the Final Topical Report We also have a number of suggestions for improvements to WASTETRAK. Each of these items is individually discussed below.
Unresolved Issues Our review of your draft topical report plus the supplemental information referenced above has indicated some unresolved issues (enclosed) regarding the design and use of the WASTETRAK system.
Resolution of these issues, which in many cases are merely matters of clarification, is required prior to our finalization of the SER and acceptance of the WASTETRAK system. We would appreciate your assistance in the prompt resolution of these issues.
Procedures for Completion of an SER and Final Topical P.eport Our procedures provide for preparation of a document called a " staff evaluation report" (SER), which sets forth the basis for approval of the adequacy of the topical report for referencing by licensees. This SER will address the issues discussed in the " Waste Classification Topical Report Review Considerations,"
which we forwarded to you as an enclosure to our December 16 letter. The SER 8702130382 861024 PDR WASTE WM-53 PDR
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will also set forth the. scope of the WASTETRAK system plus identify any major limitations. We believe that this is necessary in order to clarify to potential users and NRC inspectors what the WASTETRAK program will and will not do. The particular items identified would be subject to separate NRC inspection procedures independent of the topical report.
The SER would be issued under the condition of satisfactory completion of the final topical report and would conclude with the determination that there are no, or insignificant, environmental considerations. A negative declaration to this effect, and referencing the conclusions in the SER, would be prepared and published in the Federal Register. The final SER will also be provided to the States of South Carolina, Nevada, and Washington. ' These States may issue certificates of compliance for use of the WASTETRAK system at disposal sites in their states based on the NRC SER and on their own site-specific requirements.
We are interested in prompt completion of this SER.
In the meantime, you should begin preparation of a final topical report on the WASTETRAK manifesting system. Some general information on the preparation of the final topical report is enclosed, entitled " Procedure for Review of Topical Reports on Solidification Agents, High Integrity Containers and Computer Codes on Waste Classification" (July 1984 Review Procedures). The most important concepts and concerns, however, seem to be as follows:
- 1. The final topical report should be separated into a proprietary and a nonproprietary version. The nonproprietary version will be placed in the NRC public document room.
- 2. The final topical report should describe.the WASTETRAK system in detail, and should as a minimum include the information provided in the draft i
topical report, plus any updates or changes to the WASTETRAK system since i
the preparation of the draft topical report.
You should note that we consider the draft topical report to be deficient in the level of detail l
that it provides regarding the design and use of the WASTETRAK system.
Our review could hardly have proceeded without information obtained from I
the users manual and programmers guide.
- 3. The final topical report should at a minimum address the issues discussed in the July 1984 Review Procedures, the " Waste Classification Topical Report Review Considerations."
(A copy of this document has alrerdy been provided to you.) A copy of the computer program that implements the 3
features discussed in the final topical report should be provided as I
either an appendix or attachment. The system users manual and programmers guide should be attached or referenced.
DFC :WMEG
- WMEG NAME :GRoles
- MTokar DATE :10/
/86
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WM-53/GWR/8/22/86 4. The final topical report should be prepared so that it includes a title page, abstract, introduction, body, and references. The NRC SER will be inserted into the final report, prior to publication, immediately following the title page.
"There has been limited experience in preparation of topical reports for waste
' classification and shipment manifesting computer systems. Therefore, we suggest that your staff work closely with us during your preparation of the topical report in order to eliminate misunderstandings and to resolve potential problems at an early date.
For your information, we have enclosed an outline of a final topical report prepared for an earlier waste classification system.
(This topical report was prepared prior to preparation of the July 1984 Review Procedores, but is nonetheless representative of the types of subject matter to be addressed.) We would appreciate your provision of your schedule for preparation of the final topical report. Your schedule should provide for our review of the final topical report outline plus at least one draft version of the complete final report.
Suggestions for WASTETRAK Improvements In our review of WASTETRAK, we have naturally taken note of certain limitations of WASTETPAK which are inherent in its design and scope. As an obvious example, the WASTETRAK system is not designed,to assist the user in storing, manipulating, and correlating the results of radiochemical analyses, and s
determining scaling factors. Thus, licensee prw edures for performing such activities cannpt be based partially on an aproved topical report but must be inspected on a, plant-by-plant basis independent of the WASTETRAK topical report. A'nother example outside the scope of WASTETRAK involves characterization and classification of neutron-activated reactor components.
For such waste >the PASTETRAK system would be essentially limited to manifest preparation.
Within the overall scope o'f WASTETRAK, howevre, we have identified a number of improvements to the system whichswe believe would further assist the WASTETRAK user in complying with NRC regulations and state license conditions. These suggested improvements are enclosed for your consideration.
As noted above, we are interested in prompt completion of our review. Your cooperation in this regard will be needed.
Should you desire it, we are able 0FC :WMEG
- WMEG 0____:____________:____________:____________:____________:____________:____________.___________
NAME :GRoles
- MTokar 0-___:____________:____________:____________:.___________:____________.____________.___________
DATE :10/
f86
- 10/ /86
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_4-to discuss these items with you at your convenience. We do suggest a meeting with you soon after you begin preparation of the final topical report, in order to clarify its scope and content.
I can be reached at 301-427-4791.
f-G. W. Roles Engineering Branch Division of Waste Management, NMSS s
Enclosures:
1.
Unresolved WASTETRAK Issues 2.
July 1984 Review Procedures.
3.
RADMAN TP Outline.
4.
Suggested Improvements to the WASTETRAK System.
. Distribution:
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