ML19341C096
| ML19341C096 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1981 |
| From: | Mussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Hazle A COLORADO, STATE OF |
| References | |
| NUDOCS 8103020025 | |
| Download: ML19341C096 (3) | |
Text
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UNITED nTATEs NUCLEAR REGULATORY COMMISSION e
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Mr. Albert J. Hazle, Director N'f 88/g 10
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Radiation and Hazardous Wastes Control Division E
Colorado Department of Health Y
4210 East lith Avenue Denver, Colorado 80220
Dear Mr. Hazle:
This is in regard to your letter dated December 11, 1980 commenting on our review of the Colorado radiation control program. Our responses to your specific comments are as fullows:
1.
The statement that Colorado's uranium mill effort will require an estimated 12 to 18 person-years is based on the NRC criteria for uranium mill states (see Sec. 34a.). The key points of the criteria regarding personnel are discussed in the report and if read in that context, we believe our comment will be understood. As the criteria applies to the Colorado situation the report states, "It was emphasized that the criteria includes all effort at the State level, including not only radiation control but the environmental report review effort by other State agencies.
In addition, the 12 to 18 person-years figure does not account for the effort which has already been spent on some license actions."
2.
I believe we agree that the comments provided to you during our September 1979 review on deficiencies to the Kaman license were significant. Unfortunately, at the time of the review, our reviewer did not find a copy of the renewal application in the file and there was no~ documentation showing that the Division had been in contact with Kaman, We were puzzled because in your September 26, 1980 letter to us, you indicated that "This application had been reviewed, and our comments back to Kaman were in for typing during the (NRC) review."
However, in your December 11, 1980 letter you state that "...a formal written response to the license application has not been written." We plan to follow-up the State's actions in the case in the next program review.
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Mr. Albert J. Hazle 3.
Our report has been corrected to indicate that the search was for radium sites rather than uranium sites.
4.
Our report will be amended to indicate that the prohibition on the disposal of radioactive waste in Section 25-11-202 of the Colorado radiation control act applies only to transuranics capable of producing radiation e posures with acute effects.
5.
Our report will be amended to indicate that Part 3 of the Colorado radiation control act " Disposal of Uranium Mill Tailings" relates only to Title I of P.L.95-604.
6.
The statement that Colorado spends approximately $480 per license for -the materials program was based on information provided by you during our program review, i.e. the 7.5 person-years of effort devoted to the materials program by the Radiation and Hazardous Waste Division. You may recall that upon our request you were unable to pr9 vide an estimate of the staffing effort being provided by other State agencies. More detailed information on the level and availability of assistance provided by other State agencies will be needed to support processing as an amendment to the agreement for uranium mills. We will contact you separately on this matter.
7.
The section on Laboratory Support will be amended to indicate that the Division of Laboratories provides only wet chemistry.
8.
Please note that the figure of 1.6 person-years applies to our previous (1979) review.
Item 2.
" Comment" is simply a restatement of the comment contained in our October 25, 1979 letter to Dr. Traylor. The figures on Page 10, of course, apply to the current 1980 review.
9.
In discussions with your sta'ff, we stated that the NRC has changed its policy with regard to requestirig copies of applicable permits from mill applicants. The NRC staff no longer requests such permits.
We stand by our other comment regarding the Pioneer Uravan license.
One practice is to include selacted copies of correspondence or other documentation in our reports as necessary to support certain findings and conclusions.
o Mr. Albert J. Hazle 3-
- 10. We agree that if information regarding the said filtering devices was provided, the reviewer would not have made the recommendation concerning confirmatory measures. The State should confirm the information given by the R. F. Facility.
- 11. We take note that the Division has hired two additional health physicists and one additional secretary.
We appreciate your comments.
Sincerely, Qt w ttan D. A. Nussbaumer Assistant Director for State Agreements Program Office of State Programs cc:
F. Traylor R. Arnott NRC Public Document Room L
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