View source for IA-88-361, Advises That Resnifoff Rept Sent to States of Sc,Wa,Nv.Ky,Il & Ny.Rept Contains Many Factual Errors & Incomplete & Misleading Info from Refs Quoted.Suggests That Recipient Consider Publishing NRC Rebuttal to Subj Rept as NUREG

{{Adams
| number = ML20207N173
| issue date = 11/24/1987
| title = Advises That Resnifoff Rept Sent to States of Sc,Wa,Nv.Ky,Il & Ny.Rept Contains Many Factual Errors & Incomplete & Misleading Info from Refs Quoted.Suggests That Recipient Consider Publishing NRC Rebuttal to Subj Rept as NUREG
| author name = Nussbaumer D
| author affiliation = NRC OFFICE OF GOVERNMENTAL &amp; PUBLIC AFFAIRS (GPA)
| addressee name = Knapp M
| addressee affiliation = NRC OFFICE OF NUCLEAR MATERIAL SAFETY &amp; SAFEGUARDS (NMSS)
| docket = 
| license number = 
| contact person = 
| case reference number = FOIA-88-361
| document report number = NUDOCS 8810180539
| package number = ML20205F142
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 3
}}

=Text=
{{#Wiki_filter:.    . .                                                                                 .
: 2. ',
      .       f> "8kg                                 UNITED STATES
* I**
j      y     .
NUCLEAR REGULATORY cOMMisslON Wh pggq r 3               .;                        WASWNGTCN. D. C. 20$$$                                                                   a; }.
g                                                                                                                            (~...        .,                            .
           ''''.....'                                NOV 2 41987                                                  '8 7 " g.                               -
u MEMORANDUM FOR:        Malcolm R. Knapp, Director Division of Low-level Waste Mana and Decomissioning FROM:                  DonaldA.Nussbaumer,0                              ant Director for State Agree                   Isi      ogram State, Local end 1
an Tribe Programs                                                                             '

==SUBJECT:==
REVIEW OF THE RESNIK0FF rep 0RT As per Mrs. Schneider's discussion with your staff, copies of the subject report were sent to the States of South Carolina, Washington, Nevada, Kentucky, Illinois and New York. It is our understanding that South Carolina and Illinois are preparing coments and will be forwarding them to us.
The report contains many factual errors and incomplete *,nd misleading informa-tion from the references quoted. Due to staffing cor',traints, only a cursory review was performed.      It is unfortunate that such d Npert is distributed at a time when the States and the public need accurate infornation and objective analyses in order to make responsible decisions regarding low level waste management and disposal. }!e suggest you consider publishing the NRC staff rebuttal to this report as a NUREG for the public benefit.
Our coments were discussed with Mr. Roles on November 18, 1987.                                                If you have any question please contact Mrs. Schneider at 492-9893.
a 1 g:fe.
                                                               ,                                                   Li..       . . . _.
                                                                                              -.          ,y.......
                                                                                  ' ' e,.c.. .WNn7ek-. -
a /. : :...< . =.                   .-..u.-
i 1
                                                                                                                                                                         )
8810100537 800916 PDR      FOIA                             -                                  -
RESNIKOO8-361      PDR I

t
* e COMMENTS ON L(VING WITHOUT LANDFILLS
: 1. Page 37. The first paragraph states that Illinois is investigating tne pcssibility of DOE assuming responsibility for perpetual cart of the
(' site. Since the State of Illinois became an Agreement Stcte in .1une 1, 1987, this is no longer an option since only sites licensed by NRC are eligible for transfer to DOE.
: 2. Page A1.       Under the Richland/Beatty discussion, the statement is made that there is no attention paid to elimination void spaces.               Since at least 1983, at Beatty there has been orderly olacement of waste in the trench. Also there was no requirement for elimination of voids until the promulgation of Part 61 in January 1983, which does not apply to existing site except on a case-by-case basis.
: 3. Page 41.       The discussion states that a serious disadvantage common to both Beatty and Richland is transportation impacts. There is no support-
{f-ing information to support this claim.
                                                                                                                       )
4     Page 41. The last sentence in this discussion on the western site states 1
               /      "Through 1974 aver 140 billion gallons of liquid waste containing about 5                        I million curies have been discharged into the ground at Savinnah River, Idaho and Hanford." The statement does not apply to the operation of the comrercial low-level waste disposal facility at Hanford but to the activities of DOE, thus misleading the reader.
l

t e1-                .
2-
: 5.      Page 50. The discussion on Juarez Scenario is another example of y/ misleading and incorrect information. The report implies that low level waste was breached to retrieve stainless steel. The source in question was a cobalt teletherapy source utsed for treating cancer oatients that was taken from a warehouse and not low level waste. The amount of cobalt is incorrect and the doses to the extremities were never substantiattd.
6      Page 51 and 64         The amount of tritium and carbon-1/, allowed to be w/.       disposed via sanitary disposal is incorrect under the discussion of BRC and storage buildings.                                              .
i
: 7.      Page 67. The information on the contaminated prod Jcts brought into Los Alamos National Laboratory is incorrect. It was a shipment of rebar and
       '         not table legs that was detected leaving the site after making a wrong turn into the site.
kWT'M       $ h~#          -
O#
4CCC          hwitEG -IIC~di                                                                     ,
bCh)    t hd' hI
                                             -       _}}