ML20247B234
| ML20247B234 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/1989 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 8909120400 | |
| Download: ML20247B234 (2) | |
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g yg AUG 2 31989 MEMORANDUM FOR: Carlton Kammerer, Director State, Local, and Indian Tribe Programs Office of Government and Public Affairs FROM: Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
NMSS COMMENTS ON DRAFT CONNECTICUT LLRWDF SITE SELECTION PLAN The LLWM staff has reviewed portions oT the subject document relative to NRC regulatory requirements. These sections included: Chapter 3. Site Selection Requirements; Chapter 4. Definition of Site Selection Criteria; Char.ter 5.
Disposal Technology Selection Criteria; and portions of Appendix A, including 10 CFR 61.50 requirements and Combined NRC-EPA Siting Guidelines for Disposal of Mixed Waste.
The staff evaluated the proposed criteria, which were developed to reflect NRC regulatory requirements, to ensure that the criteria did in fact address the intent and scope of the regulatory requirement. The staff evaluated the criteria developed to reflect the combined NRC-EPA siting guidelines to ensure that they were consistent with and provide enhancement to criteria developed to address NRC regulations. The NRC staff did not evaluate the responsiveness of the criteria to requirements of U.S. EPA or any other agency which may have regulatory or oversite responsibility regarding a low-level weste disposal facility in Connecticut. j In general.the staff finds the Site Selection Plan to be comprehensive and l4 responsive to NRC regulatory requirements. The narrative and accompanying Table and appendices demonstrate an understanding of NRC regulations and compliance thereto on the part of the State of Connecticut. Document authors have done an adequate job in cross referencing the various criteria among l themselves and relating them back to the specific regulatory requirements J reflected in the various criteria. We would caution however that some of the criteria are redundant. This is due no doubt to the redundancy within the ,
various regulatory requirements they are in response to. Our general suggestion l for improvement would be to limit.the number of selection criteria by developing a single criterion in each category that is responsive to the most j restrictive requirement within the category.
The LLWM staff has the following specific comments:
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74 AUG 2 3 039 SALOMON 2
Cr. 2A1 This criterion should be stated either in comparative terms (eg.
permeability lower than ....) or in quantitative terms (eg.
permeability less than 10E-6 cm./sec)
This comment also applies to Cr. 2A2 and 2G1.
Cr. 2D1 This criterion should be expanded to key into natural resources specific to Connecticut which are to be avoided.
Cr. 2F Caution should be exercised in applying these criteria. If they are structured in a way, as is inferred from the document and conversations with the authors, so as to exclude disposal within the 100 year floodplain, then they are acceptable. Please keep in mind however, that the NRC 100 year floodplain criterion vis a vis disposal is exclusionary.
Cr. 2H1 It should be kept in mind that this criterion is only acceptable for a disposal facility which is primarily above grade.
Thank you for the opportunity to comment. If you have any questions about the contents of this letter please don't hesitate to call me.
(SIGNED) JOHN T.GREEVES Richard L. Bangart, Director
[: Division of Low _ Level Waste Management and Decommissioning, NMSS DISTRIBUTION: (LLWM89-068)
Central File //()pPLohaus RLBengart MBell JShaffner JLepre {
JGreeves JJSurmeier NMSS r/f RJStarmer LLOB r/f !
l PDR Yes /
PDR No / Reason: Proprietary / / or CF Only / /
ACNW Yes // No / /
SUBJECT ABSTRACT: (LEWR 89-068) TECTASSISTANLE REQUEST FM STATE OF CT A s /7 _
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@ ATE :08/ 2.3/89 :08/JJ/89 :08/8/89 :08/1$/89 : 8Af/89 : / /89 : / /89 0FFICIAL RECORD COPY )
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