NUREG-1199, Comments on NUREG-1199, Std Format & Content & NUREG-1200, Std Review Plan, Re Guidance for Preparation of License Application for Low Level Waste Disposal Facility.Both Documents Overly Detailed & Stringent
| ML20212P903 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1987 |
| From: | Kerr W Advisory Committee on Reactor Safeguards |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| RTR-NUREG-1199, RTR-NUREG-1200 ACRS-R-1241, NUDOCS 8703160325 | |
| Download: ML20212P903 (2) | |
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. , #o UNITED STATES
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n NUCLEAR REGULATORY COMMISSION
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E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS o b [ WASHINGTON D. C. 20555 g ,. , J March 9, 1987 1
Mr. Victor Stello Executive Director for Operations U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Mr. Stello:
SURJECT: ACRS COMMENTS ON " STANDARD FORMAT AND CONTENT" (NUREG-1199)
AND " STANDARD REVIEW PLAN" (NUREG-1200), GUIDANCE DOCUMENTS
- FOR THE'PPEPARATION OF A LICENSE ~ APPLICATION FOR A LOW-LEVEL WASTE DISPOSAL FACILITY During the 323rd meeting of the ACRS March 5-7, 1987, we met with the NPC Staff to discuss " Standard Format and Content" (NUREG-1199) and -
" Standard Review Plan" (NUREG-1200), guidance documents for the i
prepa ra tion of a license application for 'a low-level waste disposal facility.' These documents were also discussed during a meeting of the ACRS Subcommittee on Waste Management on February 19 and 20,1987. On the basis of this review, we offer the following comments.
In general, we conclude that both of these documents are overly detailed
] and stringent. Both require applicants to submit information and to j develop capabilities that do not appear.to be warranted by the public l
- health risks associated with a low-level radioactive waste disposal !
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While too detailed in some respects, the reports are not clear enough in others (for example, in the definition of a " buffer zone"). They contain requirements that may exceed current technical capabilities (such as the verification of the class of a given waste sample, and a determination of whether it contains hazardous toxic chemicals). They
, also contain discussions of certain topics (such as environmental monitoring) that are so dispersed throughout the reports that they are difficult to follow. Compounding these problems is the fact that, while these two reports cite International' Comission on Radiological Pro-1 tection (ICRP) Publication 30 as the basis for associated radiation dose assessments, the referenced NRC regulations,10 CFR Part 61, are based on ICRP Publication 2 and the standards for radiation protection as prescribed in 10 CFR Part 20.
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. Mr. Victor Stello' 2 Executiva Director for Oparations We recommend that the NRC Staff simplify and clarify these two docu-ments. It may be useful in this effort for the NRC Staff to rev_iew any comparable U. S. Environmental Protection Agency reports prepared for i the reyiew of facilities for the disposal of toxic chemical wastes.
' Sincerely, I
William Kerr Chairman p.
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