ML20248H604
| ML20248H604 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1989 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| REF-WM-3 NUDOCS 8910110289 | |
| Download: ML20248H604 (2) | |
Text
-
'. [ 216.2/GWR/9/18/89
, y,.
p Distribut'ioni LLWM 89-087-CentralWMF# 2/lf R NMSS r/f
~ LLRB r/f' _
'_ f
'GRoles TJohnson MBell HPeterson-PLohaus 4
t pr, AKRoecklien" DJSurmeier PLohaus LLRB t/f JLepre JGreeves RBangart m
f
'PDR
. Lyes? s/,4/-
No
//
Pr r etary or CF Only g/
~ACNWJ % Yes /~7 No K
~
' SUBJECT ABSTRACT:
RESPONSE TO SEPT 6, 198 MEMORANDUM ON DECOMMISSIONING RULE' s
"i
' MEMORANDUMIFOR: ' Lee H. Bettenhausen 0U 0 5 79g9 iL.
- Nuclear Materials Safety Branch Division of Radiation Safety s
and_ Safeguards, RI FROM:
Michael J. Bell, Chief Regulatory Branch Division of Low-Level Waste Management
{~
and Decommissioning, NMSS
SUBJECT:
RESPONSE TO SEPTEMBER 6, 1989 MEMORANDUM ON DECOMMISSIONING RULE.
We have reviewed your _ calculations and proposed use of certain specific activity values for depleted uranium and californium-252. We generally agree with your approach, although we have observed.a typographical error on Table 2 for depleted uranium.
(The specific activity should be 3.6E-7, not 3.6E-74.)
We suggest citing.the reference for the half-lives used in your calculations.
Your memorandum, however,. raises the issue of. internal consistency in NRC regulations. The specific activity values in the footnotes to Part 20, Appendix B, were calculated at different times and by different persons than those in Part 71, Appendix A.
Nonetheless, the values should be consistent.
We also note that Cf-252 is not the only isotope for which the Part 71 specific activities differs from those that can be calculated using available literature. We checked an arbitrary isotope, Ni-63, and calculated a specific activity of 57 Ci/g, not 46 Ci/g (assuming a half-life of 100 years).
We plan to request the Office of Research to review the derivation of the Part 20 and Part 71 values with the aim of making the two regulations consistent, or at least explaining the differences.
Our review was conducted by G. Roles (492-0595).
Or13 ml SiSned b7 1
in01Uul J. BEL Michael J. Bell, Chief Regulatory Branch Division of Low-Level Waste Management l
and Decommissioning, NMSS L
- SEE PREVIOUS CONCURRENCE m
0FC :LLRB*
- LLRB*
NAME:GRoles/es :TJohnson :MBe11 DATE:09/26/89 :09/26/89:/2/[85
/d 0FFICIAL RECORD COPY 8910110289 891003 PDR WASTE
/
WM-3 PDC hkW**J ik{kk
~
216.2/GWR/9/18/89
...
- Dis,tribution: LLWM 89-087 Central File #
NMSS r/f LLRB r/f GRoles TJohnson MBell HPeterson PLohaus j
AKRoecklien JSurmeier PLohaus LLRB t/f JLepre i
JGreeves RBangart PDR Yes
/w/
No
/ /
ProRaietary or CF Only /p: /
j ACNW Yes / /
No
/v/
j SUBJECT ABSTRACT:
RESPONSE TO SEPT 6, 1 8
EMORANDUM ON DECOMMISSIONING RULE MEMORANDUM FOR:
Lee H. Bettenhausen Nuclear Materials Safety Branch Division of Radiation Safety and Safeguards, RI
,/
FROM:
Michael J. Bell, Chief DivisionofLow-LevelWasteManah'ement Regulatory Branch and Decommissioning, NMSS
/
RESPONSETOSEPTEMBER6,1989MEMgRkNDUMONDECOMMISSIONINGRULE
SUBJECT:
We have reviewed your calculations and prop'osed use of certain specific activity values for depleted uranium and, californium-252. We generally agree with your approach, although we have observed a typographical error on Table 2 for depleted uranium.
(The specific activity should be 3.6E-7, not 3.6E-74.)
We suggest citing the reference for the half-lives used in your calculations.
Your memorandum, however, raises the issue of internal consistency in NRC regulations. The specific activity' values in the footnotes to Part 20, Appendix B, were calculated at different times and by different persons than those in Part 71, Appendix A.
Nonetheless, the values should be consistent.
We also note that Cf-252 is notjthe only isotope for which the Part 71 specific activities differs from those t, hat can be calculated using available literature. We checked an arbitrary isotope, Ni-63, and calculated a specific activity of 57 C1/g, not 46 (/g (assuming a half-life of 100 years). Given that Part 20 is now under re ision, it may be an appropriate time for Research to review the derivation off he Part 20 and Part 71 values with the aim of making the two regulations onsistent, or at least explaining the differences.
Our review was conducted by G. Roles (492-0595).
/
/
J Michael J. Bell, Chief l
Regulatory Branch Division of Low-Level Waste Management and Decommissioning, NMSS OFC :LL
- LLR
- LLRB NAME:G 96
- TJo s n :MBell DATE:9/7fgg
- gf/g89 :
/ /89 :
6 6
0FFICIAL RECORD COPY
____-___-______-________m