ML20235V167
| ML20235V167 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 02/14/1989 |
| From: | Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Mclaughlin J AFFILIATION NOT ASSIGNED |
| References | |
| CON-#189-8190 OL, NUDOCS 8903100066 | |
| Download: ML20235V167 (2) | |
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,,a Eh w James E. McLaughlin Director, Radiation Safety 2195, West Campus Medical Building 10833 Le Conte Avenue Los Angeles, CA 90024
Dear Mr. McLaughlin:
Your letter of January 26, 1989 to Mr. Adams of the NRC Staff has been referred to me for response.
In your letter you state that, due to a new EPA definition of radioactive lead as " mixed waste," you plan to transfer 4,000 pounds of radioactive lead shot and 1,000 pounds of radioactive lead brick used in the UCLA research reactor to the University's California Broad Scope Radioactive Materials License since the lead can be recycled as shield material.
You also state that you believe this action conforms to the Settlement Agreement and Licensing Board Order dated November 8, 1985.
We do not agree that your proposal conforms to the Settlement Agreement.
In section 2.5 the Agreement states:
By September 30, 1989, all radioactive or contaminated components, equipment, materials and parts associated with or formerly used in connection with the Reactor Facility or otherwise formerly licensed under License R-71 shall have been decontaminated or disposed of or transferred to another qualified licensee other than the University such that there shall be no reactivity or contamination at UCLA associated with the former Reactor facility or License R-71 in excess of
[5 microrem per hour above background at one meter from the unshielded surface] except for the [ concrete building structure and embedded components].
Our interpretation of Section 2.5 of the Agreement is that it prohibits transfer of the lead materials used in the Reactor to the University's State license.
However, it is not clear what difficulties you have encountered in disposing of the lead because of the " mixed waste" definition of EPA. We suggest that you set out the reason for not disposing of the lead and the proposed use of the lead by the University in a request for modification of the Agreement. Section 11 of the Agreement provides for amendment, modification, or supplementation of the Agreement when executed in writing by the parties. To this end, if you deem such modification necessary, you should submit a proposed modification to Section 2.5 to the Committee to Bridge the
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If we may be of assistance to you in resolving this matter, please advise us.
Sincerely, i
Colleen P. Woodhead Counsel for NRC Staff l
cc: Service List 1
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