ML23003A808
| ML23003A808 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/28/2022 |
| From: | Broussard B State of TX, Commission on Environmental Quality |
| To: | Dennis Galvin NRC/NRR/DORL/LPL4 |
| References | |
| Download: ML23003A808 (3) | |
Text
From:
Brad Broussard <brad.broussard@tceq.texas.gov>
Sent:
Monday, November 28, 2022 12:24 PM To:
Dennis Galvin Cc:
Alisha Stallard; Ashley Forbes; Chance Goodin; Gulay Aki; Hans Weger; Srinath Venkat; Melanie Wong; Adam Schwartzman; Jennifer Dixon-Herrity; Krista Kyle
Subject:
[External_Sender] RE: Draft EA for TCEQ Review/Comment Regarding South Texas Project Alternate Disposal Request
- Dennis, Please see comments below.
The Texas Commission on Environmental Quality (TCEQ) quickly reviewed the Nuclear Regulatory Commissions (NRC) draft Environmental Assessment (EA) for an alternate disposal request from South Texas Project Nuclear Operating Company (STPNOC) and has the following comments:
Throughout the document the waste in question is identified as Very Low-Level Waste (VLLW).
Because this is an undefined term, any waste categorized as VLLW would still be considered Low-Level Radioactive Waste (LLRW) and subject to regulations regarding that type of waste.
Currently Texas does not have any Class I or Class II Industrial Landfills permitted to accept waste characterized as LLRW or VLLW. Page 11 of the EA references 25 TAC §289.251(l)(1) and 25 TAC §289.251(l)(2). Its not clear how these references apply. If the intent was to reference attached graphics for exempt material, then the citation will need to be corrected to 25 TAC §289.251(e)(1) and 25 TAC §289.251(e)(2), which are the rules that would be used to exempt this waste and which reference the tables in 25 TAC §289.251(l)(1) and 25 TAC
§289.251(l)(2) for the exemption concentration limits. If the material in question is exempt in accordance with 25 TAC Chapter §289.251(e)(1) and (2), then it is strongly encouraged to identify this material as exempt by rule and not VLLW in the EA.
Page 15 of the EA states Doses calculated by the licensee and provided in the submittal confirmed that doses associated with the transport and disposal would be less than 1 mrem per year. If the material in question, is in fact, exempt under Texas regulations then an evaluation of doses to members of the public is not necessary. Including this as part of the EA may indicate to the reader that this material is not exempt and lead to confusion in the future as to the true classification of the waste.
The NRCs EA provides discussions and analysis of transportation. Transportation is not under the jurisdiction of TCEQ so no comments will be provided on that topic. The agency that oversees the transportation of radioactive material in the State of Texas is the Texas Department of State Health Services.
Let us know if you have any questions.
Thanks Brad
From: Dennis Galvin <Dennis.Galvin@nrc.gov>
Sent: Thursday, November 17, 2022 3:03 PM To: Brad Broussard <brad.broussard@tceq.texas.gov>
Cc: Alisha Stallard <Alisha.Stallard@tceq.texas.gov>; Ashley Forbes <ashley.forbes@tceq.texas.gov>;
Chance Goodin <chance.goodin@tceq.texas.gov>; Gulay Aki <gulay.aki@tceq.texas.gov>; Hans Weger
<hans.weger@tceq.texas.gov>; Srinath Venkat <srinath.venkat@tceq.texas.gov>; Melanie Wong
<Melanie.Wong@nrc.gov>; Adam Schwartzman <Adam.Schwartzman@nrc.gov>; Jennifer Dixon-Herrity
<Jennifer.Dixon-Herrity@nrc.gov>
Subject:
Draft EA for TCEQ Review/Comment Regarding South Texas Project Alternate Disposal Request Hello Brad and Others, I am the project manager for South Texas Project. Please see the attached for your review and comment the Environmental Assessment and Finding of No Significant Impact related to the South Texas Project alternate disposal request dated November 4, 2021, as supplemented on December 3, 2021, August 19, 2022, and November XX, 2022. The proposed alternate disposal request would allow the disposal of specific low-level waste generated at South Texas Project, Units 1 and 2 at Texas Class 1 and 2 industrial landfills.
Please note that the NRC staff is anticipating a supplement next week from South Texas Project that would clarify the radionuclides covered by the request. The NRC staff expects this supplement to have no impact on the environmental assessment.
Please provide any comments by November 28, 2022. The staff is working to complete the review by December 9, 2022, which requires the environmental assessment to be provided to the Federal Register the week of November 28, 2022.
- Thanks, Dennis Galvin Project Manager U.S Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 301-415-6256
Hearing Identifier:
NRR_DRMA Email Number:
1880 Mail Envelope Properties (DM5PR1301MB2011390D1C3B7E2BD3C57F30BA139)
Subject:
[External_Sender] RE Draft EA for TCEQ ReviewComment Regarding South Texas Project Alternate Disposal Request Sent Date:
11/28/2022 12:23:35 PM Received Date:
11/28/2022 12:23:50 PM From:
Brad Broussard Created By:
brad.broussard@tceq.texas.gov Recipients:
"Alisha Stallard" <Alisha.Stallard@tceq.texas.gov>
Tracking Status: None "Ashley Forbes" <ashley.forbes@tceq.texas.gov>
Tracking Status: None "Chance Goodin" <chance.goodin@tceq.texas.gov>
Tracking Status: None "Gulay Aki" <gulay.aki@tceq.texas.gov>
Tracking Status: None "Hans Weger" <hans.weger@tceq.texas.gov>
Tracking Status: None "Srinath Venkat" <srinath.venkat@tceq.texas.gov>
Tracking Status: None "Melanie Wong" <Melanie.Wong@nrc.gov>
Tracking Status: None "Adam Schwartzman" <Adam.Schwartzman@nrc.gov>
Tracking Status: None "Jennifer Dixon-Herrity" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Krista Kyle" <Krista.Kyle@tceq.texas.gov>
Tracking Status: None "Dennis Galvin" <Dennis.Galvin@nrc.gov>
Tracking Status: None Post Office:
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