ML20247D071
| ML20247D071 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/1989 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Geidl J ENERGY, DEPT. OF |
| References | |
| REF-WM-3 NUDOCS 8905250153 | |
| Download: ML20247D071 (4) | |
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,,' DM/'DISBRO
. Distribution:
Cent 51WWU405? iip NMSS r/f LLRB r/f LLRB t/f DMartin MBell RBangart JGreeves
.AHenry PLohaus JSurmeier OIG r/f PDR Yes
'PDR No _
Category:
Proprietary /
/ or CF Only /
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'ACNW Yes No.
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Mr. John Geidl, Direc or Office of Coal, Nuclear, Electric and Alternate Fuels MAY 15 79g9 Information Administration
~ Energy (Mai1~Stop2G-090)
EI-50 U.S. Department of Energy 1000 Independence Ave, SW Washington, DC 20585
Dear Mr. Geidi:
We appreciate your hosting the meeting held April 6,1989, to discuss possible
. data gathering by your office on " mixed waste." We strongly endorse such an effort and are taking this opportunity to explain, for the record, why we believe.it is needed.
Basically, in order for us to effectively fulfill our statutory responsibilities under the Atomic Energy Act of 1954 regarding the safe handling, storage and disposal of low-level radioactive waste, it is necessary
~
that we have accurate baseline information on the waste itself. This includes volumes, radioactivity content, and other characteristics.
W waste is a special category and presents many troublesome and cha11engin., segulatory problems.
Because mixed waste is subject to both NRC regulations for radioactivity as well as EPA regulations for hazardous waste, and there is no authorized disposal site, generators presently have no choice other than to store mixed
-waste. Under the Low-Level Radioactive Waste Policy Amendments Act (LLRWPAA),
we expect States and low-level waste compacts to develop'10 to 14 LLW disposal.
sites over the next few years; some site developers are providing for mixed waste and some are not. Therefore, the information we need concerning mixed waste is that which is r.scessary to properly regulate storage (perhaps for extended periods of time) and disposal.
For storage we need to know how much mixed wast'e is generated, how f ast it is generated, and by what licensees, in order to assess the radiological hazards of mixed waste storage. We also need to have basic information on the waste characteristics. This will enable ut to assess the need for and develop the appropriate licensing programs for mixed waste storage.
For disposal, site licensing requires a detailed performance assessment of the engineered and natural barriers guarding against human exposure. For mixed waste, special protective features may be provided to meet EPA regulations.
Therefore, mixed waste hazards analyses must be performed and evaluated j.
separately.
Such an assessment is difficult to perform accurately lacking detailed source term information. The lack of adequate information on mixed waste could therefore jeopardize, through licensing delays, the timely completion of the national program for LLW disposal currently in motion under the LLRWPAA. Significant delays could result in wholesale storage of all LLW Meld l
8905250153 890515
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.4 DM/DISBROW Mr'. John Geidl~ "
in States and compacts where a disposal capacity is not put in place in a
-timely fashion, with potential health and safety ramifications.
From a practical stand)oint there are two other. concerns which are also important. _Under the,.LRWPAA the NRC is obligated to complete its technical review of a LLW disposal site application in 15 months. Without adequate source term information for mixed waste, this will be more difficult and could cause us to. fail to meet the. intent of Congress. Also, site developers may need to provide special facilities for mixed waste. Accurate forecasts of
.' mixed waste receipts and characteristics are, therefore, important to proper design and engineering.
Although we have conducted sample mixed waste surveys ourselves, and industry trade organizations are also conducting work in this area, we are convinced that a concerted EIA effort is appropriate. This is due in large measure to the data gathering capabilities which are unique to EIA, which should enable the assembly of. a more accurate and comprehensive mixed waste data base.
Although we do believe the effort is critically important, we have very limited resources to draw upon to provide staff or monetary support, and would like to discuss the need for inter-agency cooperation at a future meeting.
We also need to work together to define the precise scope for this project, to optimize effectiveness.
Please contact Dan E. Martin of g staff, at 492 0557, for further discussion.
Sincerely, Driginal signed by V
l Richard L. Bangart, Director L
Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards cc: Gale Turi, DOE Betty Shackleford, EPA /0SWER James Disbrow, DOE /EIA SUBJECT ABSTPACT:
LETTER TO DOE JOHN GEIDL RE MW
- SEE PREVIOUS CONCURRENCE OFC :LLRB*
- LLRB*
- LLRB*
- L M
- LLW y,:
NAME:DMartin/es:TJohnson :MBell
- J ee es :RBa'ng3ft :
DATE:04/21/89 :04/21/89 :04/27/89 : //[/89 :03//i/89 :
OFFICIAL RECORD COPY
L DM/.DISBROW
,', Mr. John Geidl \\
l Stateg and compacts where a disposal capacity is not put in place in a timely fashiort with very significant health and safety ramifications.
From a p qtical standpoint there are two other concerns which are also important \\Under the LLRWPAA the NRC is obligated to complete it technical revie.w of a QW disposal site application in 15 months. Without adequate source term information for mixed waste, this may not be feasible and could cause us to fai1 to meet the intent of Congress. Also, site developers must N
provide special fhpilities for mixed waste. Accurate forecasts of mixed waste receipts and characteristics are, therefore, essential to proper design and engineering.
Although we have conduc d sample mixed waste surveys ourselves, and industry trade organizations are a o conducting work in this area, we are convinced that a concerted EIA effor is both appropriate and necessary.
This is due in large measure to the. data ga ering capabilities which are unique to EIA.
Although we do believe the effor(is critically important, we have very limited resources to draw upon to provide taff or monetary support, and would like to discuss the need for inter-agency c peration at a future meeting.
We also need to work together to define the ecise scope for this project, to optimize effectiveness.
Please contac Dan E. Martin of ny staff, at 492 0557, for further discussion.
Si erely, John T. Gr eyes, Acting Director Divisionof%ow-LevelWasteManagement and Decommusioning Office of Nuc1 r Material Safety and Safeguardss cc: Gale Turi, DOE Betty Shackleford, EPA /0SWER James Disbrow, DOE /EIA SUBJECT ABSTRACT:
LETTER TO DOE JAMES DISBROW RE MW
- SEE PREVIOUS CONCURRENCE OFC :LLRB*
- LLRB*
- LLRB
- LLWM
- LLWM
.........................:pgg.g.........................................._
NAME:DMartin/es:TJohnson.:Mffeyl
- GLear
- JGreeves :
DATE:04/21/89 :04/21/89 :T/2'//89:
/ /89 :
/ /89 :
OFFICIAL RECORD COPY I
1)M/DISBROW
[.Nf.JohnGeidl States aqd compacts where a disposal capacity is not put in place in a timely fashion, 9 th very significant health and safety ramifications.
From a pract al standpoint there are two other concerns which are also important. Un er the LLRWPAA the NRC is obligated to complete it technical review of a LLW isposal site application in 15 months. Without adequate source term infor ation for mixed waste, this may not be feasible and could cause us to fail t meet the intent of Congress. Also, site developers must provide special fac ities for mixed waste. Accurate forecasts of mixed waste receipts and characte istics are, therefore, essential to proper design and engineering.
Although we have conducte sample mixed waste surveys ourselves, and industry trade organizations are als conducting work in this area, we are convinced that a concerted EIA effort both appropriate and necessary.
This is due in large measure to the data gath ing capabilities which are unique to EIA.
Although we do believe the effort s critically important, we have very limited resources to draw upon to provide s ff or monetary support, and would like to discuss the need for inter-agency coo erat'?n at a future meeting.
Please contact Dan E. Martin of ray staff, at 2-0557, for further discussion.
S pcerely, John T.
eeves, Acting Director Division Low-Level Waste Management and Decom issioning Office of Nu ear Material Safety and Safeguar s cc: Gale Turi, DOE Betty Shackleford, EPA /0SWER James Disbrow, DOE /EIA
\\
SUBJECT ABSTRACT:
LETTER TO DOE JAMES DISBROW RE MW OFC :LLRB
- LLRB,
- LLRB
- LLWM
- LLWM NAME in/es.
idson :MBell
- GLear
- JGreeves :
DATE
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