ML20245C336
| ML20245C336 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/1989 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rudzinsky S ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| REF-WM-3 NUDOCS 8904270119 | |
| Download: ML20245C336 (1) | |
Text
__
DM/89-025
-1 Dis _tribution: LLWM 89 025
. Central FiledR1W NMSS r/f LLRB r/f LLRB t/f AHenry DMartin MBell JGreeves GLear PLohaus PSurmeier PDR Yes
/ /
PDR No
.V Category: Pro rietary /
/ or CF Only /W/
ACNW Yes /
No
/ /
41 Ms. Suzanne Rudzinskyl Office of Solid Waste (WH-5638)
U.S. Environmental Protection Agency 401 M Street, SW fPR 2 01989 Washington, DC 20460
Dear Ms. Rudzinsky:
We have reviewed the U.S. Environmental Protection Agency (EPA) draft
" Clarification of RCRA Hazardous Waste Testing Requirements for Mixed Waste."
Our only comment on the present content of the draft is that more guidance is needed regarding testing methods to take account of radioactivity.
Specifically, the requirement for a minimum 100. gram sample size for the Toxicity Characteristic Leaching Procedure should be explicitly and visibly stated; this should be followed by a statement that the radioactivity content may make a 100-gram sample highly impractical or even dangerous. These facts should be followed by language explaining what to do (and not do) if a conflict arises.
For example, alternative sample size and/or test procedure requirements could be resolved in the permitting process to reduce the frequency with which such conflicts must be resolved on an ad hoc basis.
Although we would greatly prefer that language addressing this concern be placed in Section II of the guidance itself, we could accept the guidance in its present form if the transmittal letter carried such language instead.
Also, since the draft at present is simply a clarification of EFA requirements, we suggest that EPA issue it independently. We could then disT5bute it to our licensees as we have done in the past with the EPA interim status notice.
As a final note, we greatly appreciate the time and effort you have invested in the draft, and also your gettirg it to us relatively soon for review.
Orisinal sisacd ty Michael J. Bell, ChieNE J BIE Regulatory Branch Division of Low-Level Waste Management and Decommissioning J
Office of Nuclear Material Safety I
and Safeguards SUBJECT ABSTRACT:
LL'M TICKET 89-025; NRC REVIEW & COMMENT ON JOINT GUIDANCE ON WASTE CHARACTERIZATION OFC :LLRB
- LLRB
- LRB
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