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Question: Who will be regulated by R313-26 and need a permit to transport waste within the State of Utah for disposal?
Answer: Anyone sending waste to EnergySolutions needs a permit access the site for eventual disposal of waste.
Question: What materials transported for disposal will be regulated by R313-26?
Answer: All radioactive waste categories or types will be regulated by the Generator Site Access Permit and all radioactive waste generators, waste processors and waste collectors will require a permit to access the EnergySolutions facility.
Question: Will the name on the permit be allowed to change with new ownership?
Answer: On a case by case basis the Executive Secretary may transfer a Generator Site Access Permit in accordance with new ownership (R313-26-3-8).
Question: If a waste processor or waste collector has a "site access permit," will this eliminate the generator's need to have a "site access permit"?
Answer: If the generator is using a permitted waste processor's or waste collector's services, the generator will not need to obtain a "site access permit."
Question: Will the form that will be prescribed by the Executive Secretary be available for review and comment?
Answer: No, the application form is not part of the "Rule Making."
Question: Is there a prescribed format for the certification? Is a memo sufficient?
Answer: The Generator Site Access Application is the prescribed format for the certification process. A memo will not be sufficient.
Question: Is it 30 working days or 30 days prior to waste shipment that applications must be received by the Executive Secretary?
Answer: 30 calendar days.
Question: Is an approval letter required prior to shipment, or can shipment occur 30 days after the Executive Secretary's receipt of application without approval?
Answer: EnergySolutions will not accept waste from any generator without a generator site access number.
Question: Will permit fees be the same for waste generators, waste processors and waste collectors? Will the permit be based on actual or estimated values?
Answer: Permit fees are not the same for Waste Processors, Waste Collectors and Generators. Waste Processors and Waste Collectors are assessed $5,000 annually. Generators will be assessed $500 for 1000 cubic feet or less and $1,300 for 1001 cubic feet or more of radioactive waste. The permit is based on estimated values.
Question: Will the permit fees assessed at each level be based on forecasted volumes in the permitted year? If so, and the forecasted volume increases to the next classification level, how will the increased permit fee be assessed? If the permit fee assessment is based on past disposal volumes, then what if a generator site does not ship the same volume of waste during the permitted year? (R313-26-3-4).
Answer: If the volume increases then the generator will be billed for the additional volume. If the volume decreases, then a refund will be given. The permit will be based on estimated volume. For example, if Generator A sends 400 cubic feet and obtains a permit for $500 (1000 cubic feet or less) and later sends another 700 cubic feet within the permit term, the generator will be billed another $800. If Generator B sends 900 cubic feet and pays $1300 for a large volume permit, and ships no more waste during the permit term, the generator would be refunded $800.
Question: Will waste generators who are also waste processors or waste collectors have to obtain two permits?
Answer: Yes.
Question: Will the permit number be listed in the shipping documents? Will a copy of the permit be required to accompany the waste shipments?
Answer: The permit number will be listed in the shipping documents. The permit number must accompany the waste shipments, but a copy of the permit is not required to accompany the waste shipments.
Question: Could the manifest be given via e-mail?
Answer: Yes.
Question: Could an advance notice of shipments consigned for disposal in Utah be provided instead of providing notice prior to the shipment arriving at the disposal site?
Answer: Yes, however, the manifest must also be provided not more then 30 thirty days prior to departure and before the shipment arrives at the disposal site.
Question: Does the Corps policy coordinating general shipment plans with the disposal facility meet the prior notice requirement?
Answer: No. The manifest must be provided to the Executive Secretary. The manifest must be provided prior to the shipment arriving but not more then 30 days prior to the shipment's arrival at the disposal facility.
Question: Will the State of Utah accept a faxed copy of the manifest?
Answer: Yes.
Question: Will the waste processor, waste collector or generator receive an approval number or letter?
Answer: Yes. A permit number will be provided to those who are approved.
Question: What means will be used to ensure the State of Utah has been successfully notified?
Answer: A permit number will be assigned to those who receive a permit.
Question: Please specify where generators and brokers must go to get permit status reports and what organization will be responsible to maintain and provide this information.
Answer: Permit status information can be obtained using a personal access number through the e-Utah web-site. An e-mail as well as a registered letter will be sent when a permit is about to expire. The Division of Radiation Control's Generator Site Access Program will maintain the permitting process and will also have access to program information.
Question: Will a generator, waste processor or waste collector have recourse against Radiation Control, if Radiation Control does not respond within a timely 30 day time-frame?
Answer: No. The Division of Radiation Control should easily respond within 30 days.
Question: Can e-mail be used to apply for the generator site access permit?
Answer: Yes through the e-Utah website.
Question: Clarify (R313-26-2 and R313-26-3) the fees for out-of-state generators, waste processors and waste collectors.
Answer: The permit fees are the same and applicable to everyone regardless of geographic location.
Question: Will the Federal Government be considered in violation, if a carrier used by the Federal Government is in violation?
Answer: Whoever is permitted by the Executive Secretary will be responsible for permit violations and will be held in violation.
Last Updated: November 30, 2004
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