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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20212H0531999-09-27027 September 1999 Responds to Addressed to DA Cool Re NRC Fees for DOE Subcontractors Performing Sealed Source Recovery Work ML20212H1061999-06-0808 June 1999 Submits follow-up to from J Orban Expressing Concerns Over Issue of Fees Assessed by NRC on Subcontractor to DOE Performing Source Recovery Actions Under Off-Site- Source Recovery Program ML20195F8721998-11-19019 November 1998 Ack Receipt of Correspondence to NRC Re West Valley,New York Facility.Correspondence Forwarded to NRC Staff for Appropriate Action ML20195F8901998-11-0505 November 1998 Requests That National Decommissioning Standards Be Applied to West Valley,Ny Nuclear Waste Site ML20153G5971998-09-25025 September 1998 Ack Receipt of Comments on Science Applications Intl Corp Various Preliminary & Revised Performance Assessments for West Valley & Other Info Provided ML20134C1141996-09-20020 September 1996 Discusses Processes That Could Be Followed to Set a Single Set of Decontamination & Decommissioning Criteria for Western Valley Demonstration Project & Part 50 Licensed Facilities at Western Ny Nuclear Svc Ctr ML20134C1531996-08-14014 August 1996 Requests NRC Guidance Re Process to Set Single Set of Decontamination & Decommissioning Criteria for West Valley Demonstration Project & Part 50 Licensed Facilities at Ny Nuclear Svc Ctr ML20056E2711993-08-14014 August 1993 Discusses Deviation from Regional Dip in Area Between Springville & West Valley,Ny ML20056E2661993-08-14014 August 1993 Forwards Deviation from Regional Dip in Area Between Springville & West Valley,Ny ML20097G6521992-06-10010 June 1992 Forwards Rev 2 to WVNS-TPL-70-12, Test Plan Cement Waste Form Qualification of Sludge Wash Liquids Rev 0 to WVNS-TRO-051, Test Request Sluge Wash Cement-Waste Cores Windows of Composition ML20101F3131992-06-0808 June 1992 Forwards Review & Discussion of Vertical Fractures Reported at Wv Site Working Draft Re DOE Request for Rulemaking on Tru Limits ML20097F5281992-06-0202 June 1992 Responds to DOE Request for Rulemaking on Transuranic Limit in West Valley Demonstration Project Wastes.Requests Copies of Communications Exchanged Between DOE & C & Overall Schedule for Major Steps in Rulemaking ML20096H4181992-05-21021 May 1992 Forwards Rev 1 to Waste Form Interim Qualification Rept Wvdp Stabilized Sludge Wash Cement-Waste & Rev 0 to WVNS-PCP-002, Process Control Plan for Cement Solidification of Sludge Wash Liquid ML20095L5991992-05-0101 May 1992 Forwards Vols 1 & 2 of West Valley Waste Form Qualification Program for Cement Solidification of Sludge Wash Liquid for Info & Comment ML20096C0991992-04-29029 April 1992 Forwards Rev 3 to OSR/GP-1, Wvdp Operational Safety Requirements ML20095J1141992-04-22022 April 1992 Informs of Approval to Commence Phase II Sludge Wash Operations on or About 920427 ML20094S5591992-04-15015 April 1992 Requests NRCs Prescription of Stds to Define Transuranic Waste Per West Valley Demonstration Project Act.Discusses Need for Redefinition & Actions Needed by NRC ML20101R4031992-03-23023 March 1992 Requests NRC Prescription of Stds to Define Transuranic Per West Valley Demonstration Project Act ML20091A5021992-03-18018 March 1992 Forwards Fully Executed RCRA 3008(h) Consent Order Which Becomes Effective 920315.W/one Oversize Drawing ML20090H5331992-03-0808 March 1992 Discusses Future Decision Making Process & Existing Obligations at West Valley & Effects on low-level Radwaste Siting by State of Ny ML20090G5111992-03-0404 March 1992 Forwards DOE Responses to NRC SER W/Recommendations on West Valley,Ny Supernatant Treatment Sys ML20094G6931992-02-25025 February 1992 Forwards Operational Readiness Review Plan for Resumption of Irts Operations,Hlw Treatment Phase II - Sludge Wash. Advises of 920309 Board Meeting & Overview & Summary of Results Will Be Discussed on 920319 ML20100P9831992-02-0404 February 1992 Forwards West Valley Waste Qualification Notebook - Replacement for Use & Info.Notebook Supports West Valley Waste Qualification Program for Cement Solidification of Sludge Wash Liquid ML20092F1571992-01-17017 January 1992 Forwards Inquiry from Constituent,J Kozlowski,Re West Valley Demonstration Project.Constituent Questions Radiation Leakage from Cansiters at Site ML20091K6551992-01-14014 January 1992 Requests That State of Ny Energy R&D Authority,Doe & NRC Examine Possible Conflict W/West Valley Demonstration Project & Possible NRC Concerns from NRC Licensing Standpoint Re Const of Commercial LLW Facility ML20086F5391991-12-0303 December 1991 Ack Receipt of Transmitting, Vitrification Control Room Design Plan. Concerns Raised That Maint Personnel Not Involved in Conceptual Design Meetings ML20085H6271991-10-15015 October 1991 Forwards Rev 6 to Wvns SAR-004, Supernatant Treatment Sys. DOE Approves Rept ML20079K3191991-10-11011 October 1991 Forwards Rev 7 to TR/IRTS-5, Operational Safety Requirements ML20083F3551991-10-0101 October 1991 Forwards Official Update of Info to Be Entered Into West Valley Waste Qualification Notebook,Per 910829 Meeting ML20079G7101991-09-30030 September 1991 Forwards Rev 4 to WVDP-043, Oil,Hazardous Substances & Hazardous Wastes Spill Prevention,Control & Countermeasures Plan ML20083D3281991-09-20020 September 1991 Responds to Request for Items 1,2 & 3 of 910718 Closeout Meeting ML20083C2241991-09-18018 September 1991 Extends Invitation to Participate in Operational Readiness Review Planning for West Valley Irts Operations - Sludge Wash ML20082K4701991-08-22022 August 1991 Forwards Rev 0 to TR-IRTS-11, Fissle Matl Mass Balance Across Lwts Evaporator & Rev 3 to WVNS-SAR-005, SAR for Liquid Waste Treatment Sys ML20091C2141991-07-26026 July 1991 Forwards DOE West Valley Project Operational Readiness Review Plan for Resumption of Integrated Radwaste Treatment Operations,High Level West Treatment Phase II - Sludge Wash ML20082E9291991-07-23023 July 1991 Provides Documentation & Data Discussed W/Nrc During 910603-06 Meeting & Interface Meeting W/Region I on 910516- 17.Viewgraphs Encl ML20076D4031991-07-19019 July 1991 Forwards Run Rept,Integrated Radwaste Treatment Sys, Campaign 21,901031-910111 ML20079B1121991-06-10010 June 1991 Forwards Wvns SAR-004,Rev 6,Draft A.4, SAR for Supernatant Treatment Sys (STS) for Review.Operational Safety Requirements/Technical Requirements Applicable to STS Encl Also ML20024G9811991-05-14014 May 1991 Forwards Waste Form Qualification Program for Cement Solidification of Sludge Wash Liquid. ML20077D1921991-04-30030 April 1991 Forwards West Valley Nuclear Svcs Co,Inc Response to Comments from 910122 NRC Visit to Evaluate Vitrification Project Const ML20081G8601991-04-29029 April 1991 Requests Written Concurrence W/Understanding on Confirmation of Compliance W/Land Disposal Restrictions for Storage & Treatment of high-level Radioactive Mixed Waste at West Valley Demonstration Project ML20073H0991991-04-25025 April 1991 Discusses West Valley Demonstration Project Completion & Closure of Western New York Svc Ctr.Concurs & Welcomes NRC Participation as Cooperating Federal Agency for Project Completion & Site Closure Environ Impact Statement ML20073K8701991-04-25025 April 1991 Concurs & Welcomes NRC Participation as Cooperating Federal Agency Re Project Completion & Site Closure EIS Prepared Jointly by DOE & New York State Energy Research & Development Authority ML20073L3581991-04-19019 April 1991 Forwards Integrated Radwaste Treatment Sys Campaign 20 Run Rept,For Info ML20077D1981991-04-19019 April 1991 Advises That Concrete Const Activities Appear to Be Adequate & Final Product Acceptable Re Response to Comments for 910122 NRC Visit to Evaluate Vitrification Project Const ML19325F3831989-11-0909 November 1989 Forwards Draft Rev 0 to WVDP-078, West Valley Demonstration Project Site Specific Plan, for Review & Comments by 891124 ML20247E5541989-03-16016 March 1989 Forwards Rev 2 to Operational Safety Requirement Manual TR/IRTS-7, Operational Safety Requirements ML20245E9991989-01-26026 January 1989 Informs of Conclusion That West Valley Demonstration Project Appropriately Focused & Results Favorable,Per 890123-24 Meeting ML20195K1621988-11-29029 November 1988 Provides Supplemental Qualification Data Re Cemented Low Level Waste Form & Reaffirms Project Position on long-term Mgt of Subj Waste ML20206J4251988-10-0303 October 1988 Forwards Rept Summarizing Status,Progress & Expenditures of West Valley Demonstration Project for Quarter Ending 880630 in Response to H.R.97-177 Requirement ML20154J8831988-05-20020 May 1988 Forwards Addl Comments on Draft Progress Control Plan for West Valley Demonstration Project.Doe 880516 Reply & Encl Respond to All NRC Concerns Re Low Level Cement Waste Form 1999-09-27
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20212H1061999-06-0808 June 1999 Submits follow-up to from J Orban Expressing Concerns Over Issue of Fees Assessed by NRC on Subcontractor to DOE Performing Source Recovery Actions Under Off-Site- Source Recovery Program ML20195F8901998-11-0505 November 1998 Requests That National Decommissioning Standards Be Applied to West Valley,Ny Nuclear Waste Site ML20134C1531996-08-14014 August 1996 Requests NRC Guidance Re Process to Set Single Set of Decontamination & Decommissioning Criteria for West Valley Demonstration Project & Part 50 Licensed Facilities at Ny Nuclear Svc Ctr ML20097G6521992-06-10010 June 1992 Forwards Rev 2 to WVNS-TPL-70-12, Test Plan Cement Waste Form Qualification of Sludge Wash Liquids Rev 0 to WVNS-TRO-051, Test Request Sluge Wash Cement-Waste Cores Windows of Composition ML20101F3131992-06-0808 June 1992 Forwards Review & Discussion of Vertical Fractures Reported at Wv Site Working Draft Re DOE Request for Rulemaking on Tru Limits ML20097F5281992-06-0202 June 1992 Responds to DOE Request for Rulemaking on Transuranic Limit in West Valley Demonstration Project Wastes.Requests Copies of Communications Exchanged Between DOE & C & Overall Schedule for Major Steps in Rulemaking ML20096H4181992-05-21021 May 1992 Forwards Rev 1 to Waste Form Interim Qualification Rept Wvdp Stabilized Sludge Wash Cement-Waste & Rev 0 to WVNS-PCP-002, Process Control Plan for Cement Solidification of Sludge Wash Liquid ML20095L5991992-05-0101 May 1992 Forwards Vols 1 & 2 of West Valley Waste Form Qualification Program for Cement Solidification of Sludge Wash Liquid for Info & Comment ML20096C0991992-04-29029 April 1992 Forwards Rev 3 to OSR/GP-1, Wvdp Operational Safety Requirements ML20094S5591992-04-15015 April 1992 Requests NRCs Prescription of Stds to Define Transuranic Waste Per West Valley Demonstration Project Act.Discusses Need for Redefinition & Actions Needed by NRC ML20101R4031992-03-23023 March 1992 Requests NRC Prescription of Stds to Define Transuranic Per West Valley Demonstration Project Act ML20090H5331992-03-0808 March 1992 Discusses Future Decision Making Process & Existing Obligations at West Valley & Effects on low-level Radwaste Siting by State of Ny ML20090G5111992-03-0404 March 1992 Forwards DOE Responses to NRC SER W/Recommendations on West Valley,Ny Supernatant Treatment Sys ML20094G6931992-02-25025 February 1992 Forwards Operational Readiness Review Plan for Resumption of Irts Operations,Hlw Treatment Phase II - Sludge Wash. Advises of 920309 Board Meeting & Overview & Summary of Results Will Be Discussed on 920319 ML20100P9831992-02-0404 February 1992 Forwards West Valley Waste Qualification Notebook - Replacement for Use & Info.Notebook Supports West Valley Waste Qualification Program for Cement Solidification of Sludge Wash Liquid ML20092F1571992-01-17017 January 1992 Forwards Inquiry from Constituent,J Kozlowski,Re West Valley Demonstration Project.Constituent Questions Radiation Leakage from Cansiters at Site ML20091K6551992-01-14014 January 1992 Requests That State of Ny Energy R&D Authority,Doe & NRC Examine Possible Conflict W/West Valley Demonstration Project & Possible NRC Concerns from NRC Licensing Standpoint Re Const of Commercial LLW Facility ML20085H6271991-10-15015 October 1991 Forwards Rev 6 to Wvns SAR-004, Supernatant Treatment Sys. DOE Approves Rept ML20079K3191991-10-11011 October 1991 Forwards Rev 7 to TR/IRTS-5, Operational Safety Requirements ML20083F3551991-10-0101 October 1991 Forwards Official Update of Info to Be Entered Into West Valley Waste Qualification Notebook,Per 910829 Meeting ML20079G7101991-09-30030 September 1991 Forwards Rev 4 to WVDP-043, Oil,Hazardous Substances & Hazardous Wastes Spill Prevention,Control & Countermeasures Plan ML20083D3281991-09-20020 September 1991 Responds to Request for Items 1,2 & 3 of 910718 Closeout Meeting ML20083C2241991-09-18018 September 1991 Extends Invitation to Participate in Operational Readiness Review Planning for West Valley Irts Operations - Sludge Wash ML20082K4701991-08-22022 August 1991 Forwards Rev 0 to TR-IRTS-11, Fissle Matl Mass Balance Across Lwts Evaporator & Rev 3 to WVNS-SAR-005, SAR for Liquid Waste Treatment Sys ML20091C2141991-07-26026 July 1991 Forwards DOE West Valley Project Operational Readiness Review Plan for Resumption of Integrated Radwaste Treatment Operations,High Level West Treatment Phase II - Sludge Wash ML20082E9291991-07-23023 July 1991 Provides Documentation & Data Discussed W/Nrc During 910603-06 Meeting & Interface Meeting W/Region I on 910516- 17.Viewgraphs Encl ML20076D4031991-07-19019 July 1991 Forwards Run Rept,Integrated Radwaste Treatment Sys, Campaign 21,901031-910111 ML20079B1121991-06-10010 June 1991 Forwards Wvns SAR-004,Rev 6,Draft A.4, SAR for Supernatant Treatment Sys (STS) for Review.Operational Safety Requirements/Technical Requirements Applicable to STS Encl Also ML20024G9811991-05-14014 May 1991 Forwards Waste Form Qualification Program for Cement Solidification of Sludge Wash Liquid. ML20077D1921991-04-30030 April 1991 Forwards West Valley Nuclear Svcs Co,Inc Response to Comments from 910122 NRC Visit to Evaluate Vitrification Project Const ML20073H0991991-04-25025 April 1991 Discusses West Valley Demonstration Project Completion & Closure of Western New York Svc Ctr.Concurs & Welcomes NRC Participation as Cooperating Federal Agency for Project Completion & Site Closure Environ Impact Statement ML20073K8701991-04-25025 April 1991 Concurs & Welcomes NRC Participation as Cooperating Federal Agency Re Project Completion & Site Closure EIS Prepared Jointly by DOE & New York State Energy Research & Development Authority ML20073L3581991-04-19019 April 1991 Forwards Integrated Radwaste Treatment Sys Campaign 20 Run Rept,For Info ML19325F3831989-11-0909 November 1989 Forwards Draft Rev 0 to WVDP-078, West Valley Demonstration Project Site Specific Plan, for Review & Comments by 891124 ML20247E5541989-03-16016 March 1989 Forwards Rev 2 to Operational Safety Requirement Manual TR/IRTS-7, Operational Safety Requirements ML20195K1621988-11-29029 November 1988 Provides Supplemental Qualification Data Re Cemented Low Level Waste Form & Reaffirms Project Position on long-term Mgt of Subj Waste ML20154J8831988-05-20020 May 1988 Forwards Addl Comments on Draft Progress Control Plan for West Valley Demonstration Project.Doe 880516 Reply & Encl Respond to All NRC Concerns Re Low Level Cement Waste Form ML20151G3561988-04-14014 April 1988 Notifies of NRC 880503-04 Visit to Plant to Review Activities Underway Re Low Level Liquid Waste Treatment. Provisional Agenda Encl ML20234F4311986-06-0202 June 1986 FOIA Request for Documents Re Listed Facilities,Including Risk Diversion Analyses or Repts Prepared from 741101-761231 That Discuss Risk That Plutonium Could Be Diverted from Facilities ML20202G0031986-05-26026 May 1986 FOIA Request for Documents Re Disposition of project- Generated Waste at DOE West Valley Demonstration Project. Documents Identified on App B Denied in 860411 Response. Documents Should Be Forwarded & Made Available in PDR ML20128C0421985-06-10010 June 1985 Forwards West Valley Demonstration Project Sar,Vol 1, Project Overview & General Info & West Valley Demonstration Project Sar,Suppls. Documents Prepared by West Valley Nuclear Sys Co,Inc in Support of Other SARs ML20127G9541984-12-0303 December 1984 FOIA Request for Memos,Documents,Repts & Correspondence Re Migration of radioactively-contaminated Kerosene at NRC Licensed Burial Ground at West Valley,Ny ML20114A8031984-07-10010 July 1984 FOIA Request for All Correspondence of 1982-83 Between Util & NRC Re Shipment Routes for Irradiated Fuel Between Former Reprocessing Plant at West Valley & Facilities ML20113D8141984-06-27027 June 1984 FOIA Request for Documents Re Shipment of Fuel Assemblies from Western Ny Nuclear Svc Ctr to Bnwl Occurring May-Jul 1978 ML20080P3311983-09-30030 September 1983 Requests Consideration of 2.206 Petition Directing NRC to Determine Whether License Amend Required for Each Util Wishing to Ship Irradiated Fuel from West Valley,Ny ML20080G9801983-09-0909 September 1983 Requests Institution of Proceedings to Modify,Revoke or Suspend Facility Ols,Per 10CFR2.206 ML20080D4311983-08-24024 August 1983 Contends That Shipment of Irradiated Nuclear Fuel from West Valley Reprocessing Plant Back to Respective Utils Hazardous & Unnecessary.License Amend,Safety Evaluation & Pertinent Repts Should Be Submitted Before Decision ML20078G1931983-06-27027 June 1983 FOIA Request for Documents Re Costs & Const of & Improvements to Western New York Nuclear Svc Ctr,West Valley,Ny ML20071A3721983-02-10010 February 1983 Forwards Amend 13 to Indemnity Agreement B-29,per 830112 Request.Amend Reflects NRC Order Terminating NFS Authority ML20028C1171982-11-18018 November 1982 Requests Confirmation That Util May Receive & Store at plant,114 Spent Fuel Assemblies Discharged from Plant Currently Located at West Valley 1999-06-08
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l Department of Ensrgy l- -
4 l Germantown, MD 20874-1290 !
June 8, 1999 i l
i Mr. Donald A. Cool, Director
- Division ofIndustrial and -
Medical Nuclear Safety Office of Nuclear Material Safety-and Safeguards j U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001-9
Dear Mr. Cool:
I am writing to follow up to the letter of April 16,1999, from James E. Orban of our Albuquerque Operations Office (enclosed). That letter expressed concem over the issue of fees ;
assessed by the U.S. Nuclear Regulatory Commission (NRC) on subcontractors to the l Department of Energy (DOE) performing source recovery actions under the Off-Site Source ,
Recovery (OSR) program. .
To review, the OSR program developed out of the letter agreement of April 7,1992, and the subsequent draft Memorandum of Understanding. Since that time, our offices have worked closely together to respond to approximately 15 requests to accept scaled sources for management. In addition, we recently completed a pilot program which recovered 56 americium / beryllium neutron sources from high priority licensees. Cte of the purposes of the pilot program was to test out various methods for DOE to collect sources. In particular, we had our prime contractor for the OSR program, the University of Califomia operating the Los Alamos National Laboratory, subcontract the work of packaging and transporting the sources.
. The reason we used a subcontractor was to keep costs down compared to using our prime contractor to do this work. Our goal is to try to recover sources at the lowest possible cost.
-The first issue concems the exemption from NRC regulation for activities conducted by DOE prime and subcontractors under 10 CFR 30.12. In using a subcontractor for the OSR program, DOE does not wish to invoke the exemption available under 10 CFR 30.12. Invoking the exemption requires DOE to essentially regulate the subcontractor through the terms of the !
contract, which in this case defeats the purpose of using a subcontractor. We would haye utilized our prime contractor for this work had we wished the contractor to be exempt. DOE is specifically requiring a licensed subcontractor to perform the work under this program and we are not extending the exemption of 10 CFR 30.12 to the subcontractor.
4 i
Since the subcontractor in this case was an Agreement State licensee, the issue of reciprocity arose when they performed work outside the state. Under 10 CFR 150.20, a fee is required for an o Agreement State licensee performing work outside the state. Under the OSR program, DOE is l recovering sealed sources which are a DOE responsibility under the Low-Level Radioactive l
Printed with soy ink on recycled paper 9909300207 990927 PDR ADOCK 05000201 P PDR
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7 J
' Waste Policy Amendments Act of1985 (Public Law 99-240) Under the pilot program referred to above, we were specifically taking sources from licensees which were recommended by the )
NRC as high priority licensees due to issues concerning their ability to maintain control of.the
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material in the long term. The fee provisions under 10 CFR 150.20 work against the program's j efforts to keep costs down and remove sources from high priority licensees.
J DOE would like to propose a waiver of the fee provisions under 10 CFR 150.20. We believe a waiver is appropriate for two reasons. First, DOE is taking sources from licensees who, in j general, are no longer active and have storage-only licenses. Many are paying reduced fees or no 1 fees. DOE is also taking sources prioritized based on risk, which we have worked closely with l your office to determine the risk ranking. Therefore, when DOE takes a source, it is typically from a licensee where there is a concern regarding their ability to control the material. These licensees require increased regulatory oversight by NRC or Agreement States. When DOE takes the source, the licensee typically terminates their license. Therefore, in taking sources, DOE is 4 reducing the number of problematic licensees requiring regulatory oversight, which in the long term saves NRC and Agreement States money.
A second reason we believe a waiver is appropriate is to keep costs to the taxpayer down. Since ,
DOE and NRC are both Federal agencies, we would simply be trading tax dollars back and forth which in itself costs money due to administrative burden. We believe it would be simpler and more cost effective to simply waive the fee.
Therefore, we are formally requesting your consideration to waive the fee requirements of )
10 CFR 150.20 when DOE uses a subcontractor in carrying out the mission of taking sealed i sources which are a DOE responsibility under Public Law 99-240.
If you have any questions, please contact me at (301) 903-7100, or have a member of your staff contact Robert Campbell at (301) 903-7127.
Sincerely,
/ I YA4AA O) W & i J mes A. Turi cting Associate Deputy Assistant Secretary for Waste Management 1 Environmental Management Enclosure cC'
- 3. Orban, AL ,
J. Grimm, AL J