NRC Generic Letter 1984-12

NRC Generic Letter 1984-012: Compliance with 10 CFR Part 61 & Implementation of Radiological Effluent Technical Specifications (RETS) Attendant Process Control Program (PCP)

ML031150707
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	04/30/1984
From:	Eisenhut D G Office of Nuclear Reactor Regulation
To:
References
GL-84-012, NUDOCS 8405010084
Download: ML031150707 (2)

UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555April 30, 1984TO ALL OPERATING REACTORS AND APPLICANTS FOR OPERATING LICENSESGentlemen:

SUBJECT: COMPLIANCE WITH 10 CFR PART 61 AND IMPLEMENTATION OF THERADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) ANDATTENDANT-PROCESS ICONTROL PROGRAM (PCP) (GENERIC LETTER 84-12)This letter is to inform you that the waste manifest provisions of 10 CFR20.311 became effective on December 27, 1983. The manifest system is closelyrelated to certain requirements of 10 CFR Part 61 that place new requirementson classification and acceptable forms for low-level radioactive wastes beingshipped from commercial nuclear power plants to commercial disposal facilities.The NRC staff has been made aware of the fact that neither the states nor thedisposal facility operators currently have sufficient resources to assure thatall incoming low-level radioactive waste is in compliance with these newregulations. Consequently, the NRC has been asked to provide reasonableassurance that its licensees are complying with all applicable provisions ofPart 61.During the development of Part 61, the NRC staff determined thatcompliance with the radioactive waste form requirements of Part 61 and thecertification requirements of 10 CFR 20.311 could be achieved by the develop-ment and use of a Process Control Program (PCP) as an attendant part of thelicensee's Radiological Effluent Technical Specifications (RETS). Thisapproach was determined to be acceptable by the responsible state regulatoryagencies that license the disposal sites. It is now apparent, however, thatmany licensees do not yet have approved PCPs and that no licensee has a PCPwhich specifically addresses the new requirements of Part 61.As an interim measure, the responsible state regulatory agencies and thedisposal site operators have agreed to continue to accept nuclear power plantlow-level radioactive wastes based upon the NRC staff's assurance thatreasonable progress is being made toward demonstration of full compliancewith new requirements of Part 61 and Part 20. The NRC staff has been readilyable to offer such assurances for those plants for which there are NRCapproved and implemented RETS and the attendant PCPs. The NRC staff willassume a good-faith effort on the part of these licensees to modify in atimely fashion the PCPs to accommodate all new and applicable Part 61 andPart 20 requirements. We are prepared to assist, when requested, thoselicensees which presently have approved PCPs to assure that they are upgradedto meet the new requirements of Part 61; however, the NRC staff cannot offerthe same type of assurances for those operating plants which do not possesscurrently approved RETS and PCPs. Prompt action may be necessary if radio-active waste shipments from these plants are to continue without interruption-8405010084

-2-The NRC staff will make every effort-to avoid any interruption of low-levelradioactive waste shipments by its licensees. We are prepared to expeditethe implementation of NRC approved RETS and PCPs for all licensees who requestassistance.If you have any questions concerning this subject, please contact eitherW. Gammill or F. Congel via your Project Manager.rwe G. E senhut, DirectorDivision of icensingOffice of Nuclear Reactor Regulation