ML19352A042
| ML19352A042 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1981 |
| From: | Cunningham G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Goller K NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19352A039 | List: |
| References | |
| FRN-44FR70408, REF-10CFR9.7, RULE-PR-60 NUDOCS 8102250570 | |
| Download: ML19352A042 (2) | |
Text
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p ascoqk UNITED STATES
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FE3 4 19 81 hSOPMDi.M KR: Karl R. Goller, Director Division of Siting, Health and Safeguards Standards Office of Standards Develo p t FBCN:
Guy H. Cunningham, III Director & Chief Counsel Regulations Division Office of the Executive Legal Director SUEJECT:
SECY-81-48, 10 GR PAIE 60 (LICENSIN3 PROCEDGES FOR DISPOSAL OF HIGi-IEEL RADIOACIIVE WASTES)
We have no legal objection ;o the proposed staff paper reflecting the changes discussed at the cmmission uneting of January 26.
In our opinion, however, the treatz:ent of conditions to be included in the construction authorization could be sinp1ified by naking the following changes to prior text.
Rule (SECY-81-48, p. 63) 60.32 Conditions of construction authorization.
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(c) The construction authorization will [ explicitly} state those features of the repository cited in the application deeced by the em mission to be so essential'to the prote: tion of the public health and safety that they any not be altered during subsequent construction [without prior approval frczn the rmmission]
except in accordance with an amendment to the construction authorization.
Statanant of Considerations (SECY 81-48, p. 22) g.
Conditions of Construction Authorization A new paragraph 60.32(c) has been set fortn in the final rule which states that there will be a set of conditions which are of sufficient importance that the DOE cannot deviate from than without having obtained an amenchent to the construction ~ authorization.
l P6lONosto Enclosure B
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h ere m y also be conditions which provide for other, though less suostantial, forms of Cor:=1ssion involvement. For exacole D Ccay be recuirec to notiTf the.NBC either in acvance of or within a specified time af ter caking certain kinds of devEtIons frczn the
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plans cescribed in its aro11 cation.
Ane concitions coulc speciiv, further, that IO"c. refrain frcxn i=ulecenting such deviations without NRC aporoval.
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,P Guy'H. Cunningham,7 Director'& Chief Counsel Regulations Division Office of the Executive Legal Director O
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Enclosure B