ML21061A325
| ML21061A325 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/2021 |
| From: | Priya Yadav NRC/NMSS/DDUWP/LLWB |
| To: | Stephen Koenick NRC/NMSS/DDUWP/LLWB |
| Shared Package | |
| ML21061A326 | List: |
| References | |
| NUREG/BR-0204 | |
| Download: ML21061A325 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 3, 2021 MEMORANDUM TO: Stephen Koenick, Chief Low-Level Waste and Projects Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Signed by Yadav, Priya FROM: Priya Yadav, Project Manager on 03/03/21 Low-Level Waste and Projects Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF FEBRUARY 11, 2021, TELECONFERENCE REGARDING THE IMPLEMENTATION STATUS OF NUREG/BR-0204 REVISION 3 AND ASSOCIATED NRC FORMS On February 11, 2021, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public teleconference where the NRC staff provided industry representatives, licensees, waste generators, and vendors a status update regarding the implementation of NUREG/BR-0204, "Instructions for Completing NRC's Uniform Low-Level Radioactive Waste Manifest, Rev. 3, and the associated revisions to the Uniform Waste Manifest (UWM) Forms (NRC Forms 540, 541 and 542).
The teleconference was noticed on the NRCs public website on January 19, 2021, and the notice and meeting agenda is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21035A351. The NRC staffs presentation is available in ADAMS at Accession No. ML21039A763.
During this teleconference NRC staff provided background and a summary of the changes that were made to the guidance document and the UWM forms between Revision 3 and Revision 2.
NRC staff also provided examples and answered questions on how to implement the guidance relating to the use of data flags, scaling factors, and lower limit of detection (LLD) values in waste classification calculations.
NRC staff stated that no additional changes would be made to the UWM forms or the guidance instructions beyond what was published in June 2020, prior to the delay of implementation that industry requested and that NRC announced in a September 30, 2020 Federal Register Notice (85 FR 61576).
CONTACT: Priya Yadav, NMSS/DUWP 301-415-6667
S. Koenick Staff indicated it was seeking stakeholder feedback if industry would be ready to implement NUREG/BR-0204, Rev. 3 and the revised UWM forms by June 1, 2021, with a 90-day implementation period to allow a transition time between revisions. Several commenters stated they would be ready to complete implementation of the forms by September 1, 2021. Several other commenters discussed waste characterization challenges with respect to hard-to-detect radionuclides.
NRC staff discussed that generators may electronically reproduce the NRC version of the forms that will be posted to the NRC Forms Library, https://www.nrc.gov/reading-rm/doc-collections/forms/index.html, however, if they are using the NRC version of the forms they need to include the Paperwork Reduction Act (PRA) required statements such as the Office of Management and Budget Clearance number, the expiration date, and the PRA statement. NRC staff indicated that generators should check with the receiving waste disposal or waste processing facility if that facility is located in an Agreement State, as the state regulators may be maintaining their own Agreement State equivalent versions of the NRC forms (equivalent to the original documentation in respect to content, clarity, size, and location of information).
Several stakeholders asked questions about implementing the guidance in NUREG/BR-0204, with respect to data flags, generic scaling factors, and LLDs and expressed interest in further interactions with the NRC regarding LLD methodology for the hard-to-detect radionuclides. A stakeholder from the Electric Power Institute (EPRI) confirmed the status of the NRC review of the EPRI report entitled, Development of Generic Scaling Factors for Technetium-99 and Iodine-129 in Low and Intermediate Level Waste (dated November 2015) (ML18172A263) was on hold unless the technical research needs of the industry require that they reopen the NRC review process.
NRC staff collected questions to post answers to as Frequently Asked Questions on the NRC website https://www.nrc.gov/waste/llw-disposal/llw-pa/llw-uwm.html. Staff stated they plan to continue interacting with stakeholders regarding challenging issues in waste characterization such as the use of generic scaling factors and the methodology for using LLDs in waste classification calculations.
The transcript of the meeting is available at Accession No. ML21061A030. No comments were received from any state regulators in attendance.
Enclosure:
List of Attendees ADAMS Accession No.: ML21061A325 DISTRIBUTION:
Karen Pinkston Bo Pham James Adler Aida Rivera-Varona Steve Garry Patricia Holahan Ian Irvin David Cullison Stephen Bell David Pstrak Brenda Miles Chris McKenney
S. Koenick Attendee List NRC Patricia Holahan Karen Pinkston Christepher McKenney Stephen Koenick Priya Yadav Ian Irvin Aida Rivera-Varona Marlayna Doell Steven Garry Stephen Bell Adam Schwartzman Micheal Smith Cynthia Barr Rhex Edwards Kim Conway Mike Kunowski Allegra Chilstrom (court reporter)
Regulators Jalynn Knudsen Phil Klevorick Gregorio Rosado Members of Industry/Public Cameron Pelzer Coleman Miller Tommy Courtemanche Daniel Shannon Heather Sullivan Amaryl Morie Thomas Kalinowski Ronnie Olson Jeff Ginsburg Marc Pawlowski Sherry Frenette Amanda Spalding David Kania Sandra Koss Chris Shaw Mike Casey Michael Wiskerchen Dylan Long Bret Rogers Greg Haught Vern Rogers Colt Greer Keri Gonzalez Diane DArrigo Thaddeus Mountain Martin Karr Mike Cecalupo Voshihiko Horikawa Ryan Grudzien Janet Aremu-Cole Kurt Fogleman Tim Martinson James Leonard Kay Cumbow Janet Schlueter Abhijit Sengupta Karen Kim-Stevens William Doolittle Glen Vickers Enclosure