Compliance with 10 CFR Part 61 and Implementation of the Radiological Effluent Technical Specifications (RETS) and Attendant Process Control Program (PCP) (Generic Letter No. 84-12)

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                           WASHINGTON, D.C. 20555

                               April 30, 1984  

TO ALL OPERATING REACTORS AND APPLICANTS FOR OPERATING LICENSES 

Gentlemen: 

SUBJECT:  COMPLIANCE WITH 10 CFR PART 61 AND IMPLEMENTATION OF THE 
          RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) AND 
          ATTENDANT PROCESS CONTROL PROGRAM (PCP) (GENERIC LETTER 84-12) 

This letter is to inform you that the waste manifest provisions of 10 CFR 
20.311 became effective on December 27, 1983. The manifest system is closely
related to certain requirements of 10 CFR Part 61 that place new 
requirements on classification and acceptable foms for low-level radioactive 
wastes being shipped from commercial nuclear power plants to commercial 
disposal facilities. The NRC staff has been made aware of the fact that 
neither the states nor the disposal facility operators currently have 
sufficient resources to assure that all incoming low-level radioactive waste 
is in compliance with these new regulations. Consequently, the NRC has been 
asked to provide reasonable assurance that its licensees are complying with 
all applicable provisions of Part 61. 

During the development of Part 61, the NRC staff determined that compliance 
with the radioactive waste form requirements of Part 61 and the 
certification requirements of 10 CFR 20.311 could be achieved by the 
development and use of a Process Control Program (PCP) as an attendant part 
of the licensee's Radiological Effluent Technical Specifications (RETS). 
This approach was determined to be acceptable by the responsible state 
regulatory agencies that license the disposal sites. It is now apparent, 
however, that many licensees do not yet have approved PCPs and that no 
licensee has a PCP which specifically addresses the new requirements of Part 
61. 

As an interim measure, the responsible state regulatory agencies and the 
disposal site operators have agreed to continue to accept nuclear power 
plant low-level radioactive wastes based upon the NRC staff's assurance that
reasonable progress is being made toward demonstration of full compliance 
with new requirements of Part 61 and Part 20. The NRC staff has been readily
able to offer such assurances for those plants for which there are NRC 
approved and implemented RETS and the attendant PCPs. The NRC staff will 
assume a good-faith effort on the part of these licensees to modify in a 
timely fashion the PCPs to accommodate all new and applicable Part 61 and 
Part 20 requirements. We are prepared to assist, when requested, those 
licensees which presently have approved PCPs to assure that they are 
upgraded to meet the new requirements of Part 61; however, the NRC staff 
cannot offer the same type of assurances for those operating plants which do 
not possess currently approved RETS and PCPs. Prompt action may be necessary 
if radioactive 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-level 
radioactive waste shipments by its licensees. We are prepared to expedite 
the implementation of NRC approved RETS and PCPs for all licensees who 
request assistance. 

If you have any questions concerning this subject, please contact either W. 
Gammill or F. Congel via your Project Manager. 


                              Darrell G. Eisenhut, Director 
                              Division of Licensing 
                              Office of Nuclear Reactor Regulation 
.