Use of Hydro Nuclear Service Dry Active Waste Disposal
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