U.S. Nuclear Regulatory Commission
Use of Hydro Nuclear Service Dry Active Waste Disposal
Title: Use of Hydro Nuclear Service Dry Active Waste
See the memorandum from J. G. Partlow to J. A. Hind dated
June 14, 1985, and the enclosed memorandum from L. J.
Cunningham to L. R. Greger dated May 17, 1985. If the
equipment performs per Hydro Nuclear's description and is
operated according to their instructions, there appears to
be no problem with licensee use for sorting of dry active
waste. The health physics position was written in the
context of 10 CFR 20.201, 20.301, and 20.302, but it also
applies to the "new" 10 CFR Part 20, Sections 20.1501,
20.2001, and 20.2002.
In response to the Region III memorandum dated May 21,
1985, OIE needs to point out one clarification. That is,
the NRC staff has not yet formally evaluated the Hydro
Nuclear System. Our understanding is that Hydro Nuclear
will submit a topical report to NRC for review in the near
future. Upon completion of this review, we will send you a
copy of the staff's review.
In the meantime, our position is that if the equipment
performs according to Hydro Nuclear's description and is
operated according to their instructions, we see no problem
with licensee use. However, the licensee should contact
NRR if it plans to dispose of any waste containing
detectable amount of radioactivity pursuant to 10 CFR
20.302 [or 10 CFR 20.2002].
In other words, we have no objections to the use of this
equipment provided that it is properly operated, as
intended by Hydro Nuclear, and that all waste determined to
contain detectable licensed material is disposed of as
radioactive waste in accordance with the provisions of 10
CFR 20.301 [or 10 CFR 20.2001]; thus, meeting the intent of
IE Circular No. 81.07.
Regulatory references: 10 CFR 20.201, 10 CFR 20.1501
Subject codes: 9.3, 9.7