ML20235W668

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Provides Comments for Task 1 Work Efforts by Us Army Corps of Engineers (COE) Based on COE 870422 Draft Ltr Rept Re Interagency Agreement NRC-02-87-006,FIN D-1071-7.Requests COE to Provide Resources & Technical Support for Task 2
ML20235W668
Person / Time
Issue date: 05/28/1987
From: Kane J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Whalin R
ARMY, DEPT. OF, CORPS OF ENGINEERS
Shared Package
ML20235W585 List:
References
CON-FIN-D-1071-7, CON-NRC-02-87-006, CON-NRC-2-87-6, FOIA-89-96 NUDOCS 8903130128
Download: ML20235W668 (2)


Text

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ItAY t 8 987 Dr. Robert W. Whalin, PE, Technical Director Structures Laboratory U.S. Army Corps of Engineers Waterways Experiment Station P.O. Box 631 Vicksburg, MS 39180-0631

Dear Dr. Whalin:

i We have reviewed the Corps of Engineers (COE) Task 1 Draf t Letter Report dated April 22, 1987, that was provided in response to our Interagency Agreement No.

NRC.02 87 006,. FIN No. D1071-7. On the basis of our review we have provided our comments on tne attachment for Task 1 work efforts by the COE.

We are aware that in the course of the COE's work on Task 2, additional general design criteria have been identified which ncrmally would have been included within the scope of Task 1. Because Task 2 efforts will build on the general design criteria of Task 1, it is not necessary that the additional general criteria now be included in the Final Letter Report for Task 1 since they will be covered in Task 2. The Final Task 1 Report should address, however, the NRC staff coments on the attachment.

The COE's current efforts for Task 2 are extremely important for the NRC to meet its regulatory responsibilities required under the Low-level Radioactive Waste Policy Amendments Act of 1985. We sincerely and urgently ask for the COE's cooperation in providing the resources and technical support that is needed by the assigned COE personnel at this time to satisfactorily complete Task 2 work. Your assistance in this matter will be greatly appreciated.

Sincerely, .

Original Signed By Joseph Kane, PE, Project Officer k031012889030 R

WILLI AnsB9-96 DIA PDR Technical Branch Division of Low-level Waste Management and Decommissioning, HMSS

Enclosure:

As stated ,

cc: Robert Denson Principal Investigator Structures Laboratory Concrete Technology Division

. DISTRIBUTION: (LLWM 87 21)

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SUBJECT:

NRC Staff Review Coments on Task 1 Draft letter Report -

Interagency Agreement No. NRC-02-87-006, FIN No. D1071-7.

REFERENCE:

Task 1 Letter Report, April 22, 1987 from the U.S. Army Corps of Engineers, Waterways Experiment Station," Technical Assistance in Development of Engineering Criteria and Requirements for Alternative Near-Surface Methods for Disposal of Low-Level Radioactive Waste" l REVIEW COMMENTS

1. Section 1.2, Page 1 at bottom. Delete the words " testing laboratories,"

"and fencing" from the paragraph. There are possible conditions at a given site where the failure of these features could result in radiological risk to site personnel or to the public health and safety and therefore, their deletion is recommended from this paragraph.

2. Section 2.3 and 2.4, Page 3. existing two sections should be

- combined into a single section entitled " Construction Materials-Quality and Durability." The word "all" in the first sentence of Section 2.3 should be deleted because only the structures and systems essential for the safe disposal of low-lavel waste are intended to be covered.

3. Section 2.5 and 2.6, Page 4. To be consistent.throughout the report, the words " Performance Objectives" in these sections should begin with capitals.
4. Page 5. A new Section should be added to cover Filter and Drainage Systems and should precede the Section on Waste Cover Systems.
5. Section 2.8, Page 5. To be more consistent with 10 CFR Part 61.51(a) i requirements, we suggest that item C. be changed to " minimizing the contact of water with waste packages during disposal and the contact of percolating or standing water with wastes af ter disposal." We suggest that item e. be changej to " Protection against inadvertent intrusion."
6. All Sections. In recognition that the General Design Criteria (GDC) that are being developed in Task 1 are not part of the regulations and are not legally binding, but are intended to be incorporated into the Standard Format and Content Guide and the Standard Review Plans as guidance to potential license applicants, we suggest the use of the word "should" in place of "shall" where appropriate in each of the GDC Sections.

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