ML20002B380

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Forwards Rept to Governor Re NRC & DOT Agreement to Shift Emphasis from Surveillance to Enforcement.Restructured Program Will Have State Focus on Enforcement Action Against Violators of RAM Transportation Regulations.W/O Encl
ML20002B380
Person / Time
Issue date: 11/24/1980
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Riley R
SOUTH CAROLINA, STATE OF
References
NUDOCS 8012110476
Download: ML20002B380 (3)


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The Honorable Richard W. Riley g

Governor of South Carolina X

Columbia, South Carolina 29211 M

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Dear Governor Riley:

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The State of South Carolina has been a partner with the U.S. NuDear "

Regulatory Commission (NRC) and the U.S. Department of Transportation (DOT) since 1977 in the surveillance of the transportation of radioactive materials. This letter is to invite your personal consideration of a significant next step.

Since 1973, the NRC and DOT have been sponsoring a joint contractual program whereby States undertake the surveillance of radioactive natorial (PRi) transportation within their jurisdiction. The program provides data on various aspects of PRi transport. This data aids in assessing impacts to public and worker safety, determines degrees of compliance with relevant regulations, locates patterns of FR4 transport, and identifies areas of deficiency.

Currently there are nine States ur. der contract, and the enclosed report provides a detailed review and prospectus of the entire program and the individual States' efforts.

As the enclosed report indicates, the DOT and the NRC have recently This agreed to shift the emphasis from surveillance to enforcemer.t.

change is the next step toward greater effectiveness.

In the restructured program, States will cantinue to collect data and survey the transportation of radioactive materials, but will also focus upon enforcement action against violators of RA*i transportation regulations.

Enforcenent actions will be taken by the State under State regulations, which will include, by adoption, relevant portions of the Federal hazardous material regulations from Title 49 of the Code of Federal Regulations relative to motor l

carrier and PRi transportation st fety.

As a participant in the transportation surveillance program for the past three years, the State of South Carolina has demonstrated interest and capability in dealing with the transportation of radioactive materials.

Through such further cooperative efforts and an emphasis on enforcement, An enforcement-oriented we hope to further improve safety in this area.

program will also promote and encourage uniform State and Federal regula-tions concerning PA1 transport, will increase the regulatory effectiveness of State and Federal agencies, and will develop and utilize State regulatory c

resources.

The first step in getting the enforcement-oriented program underway will l

l.e a pilot program with several States. This will involve contractual agreements between the NRC, DOT, and these States whereby the States will develop and use adequate surveillance and enforcement rechanisms concerning the transport of PRt. He estimate that Federal funding per m i. y,,iii be in..% C 0,C%, vc high;r, ri a, Opcding cn the o400)%.o.f york. involved.

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DJ4A~AAMKJ2Jtdd/ENT FRtNTINCi Of FICC: 1979-289409

John T. Collins TLL 633 To place these apparent inconsistencies in perspective is appro-priate.

On the assumption that SDS processing of the radioactively contaminated wster will commence July 1, 1981, che total contamina-

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tion to be fixed is approximately 462,500 curies (exclusive of H-3).

Using the decontamination factors of the Oak Ridge report and the SDS as currently configured, a total of approximately 462,400 curies i

will be fixed on the SDS resins. This capture ratio is repre-sentative of the fixing of 99.98% of the radionuclides that are presently in solution. The fixing of these contaminants is representative of a significant improvement in the potential for jeopardy to the public health and safety.

i Furthermore, as you are aware, the SDS incorporates the capability for a relatively wide range of processing options.

For example, in the event that SDS process effluent contains crace radionuclides j

that are in concentrations considered to be excessive, several options for further processing exist. They are:

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1.

Return SDS effluent to the reactor containment building.

2.

Provide shielded storage for SDS effluent water, e.g.,

RCBTs.

3.

Polish SDS effluent utilizing EPICOR II.

4.

Reconfigure resin loadings of SDS cation beds and polishing bed for removal of the trace contaminants.

Specific processing options, and che details associated with these options, will be provided in our revised TER.

Enclosed, with this letter, are our responses to one of your questions forwarded l

on November 7, 1980. Additional responses will be forwarded as the information becomes available.

Sincerely, i

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'. Hovey Vice-President and Director, TMI-2 GKH:LJL: dad Enclosure 1

cc:

Bernard J. Snyder 4

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2, w-ENCLOSURE 1 John T. Collins TLL 633 COMMENT 1 Letter TLL 283 provided a list of piping and instrument drawings and general arrangement drawings. An up-to-date listing of these drawings is requested along with the latest revision of the drawing if the drawing has a later revision date that the one provided in TLL 283. Most of the drawings provided were " Issued for Approval",

" Approved for Fabrica-tion" drawings should now be available and we request that these drawings be provided.

RESPONSE

The drawings listed below are provided in accordance with your request. The drawing revisions provided are the appropriate diagrams in that they represent the current revision presently being used. They are enclosed.

DRNJING NO.

REV.

TITLE 2-M74-SDS01 1

P&ID SDS Feed and Monitor Tank 527C-A-5011 2

P&ID Dewatering Station 527D-A-5001 5

P&ID Supply Manifold 527D-A-5002 4

P&ID Contaminated Feed Water System 527D-A-5004 6

P&ID Off-gas and Liquid Separation System 527D-A-5005 2

Ion Exchange Flow Sheet 527D-A-5006 4

Intermediate Sampling Station 527D-A-5007 1

General Layout Plan - Ion Exchange Equipment 527D-A-5009 3

P&ID Beta Monitoring Manifold 527D-A-5010 1

Ion Exchanger Support Assembly Drawing 527D-A-5013 2

P&ID RCS Cleanup Manifold 527D-D-5002 2

Pre-Filter (125 micron) 427D-D-5003 3

Final Filter (10 micron) 527D-D-5012 0

Ion Exchanger Final Filter and Pre-Filter 527D-D-5013 1

Ion Exchanger and Final Filter Those drawings having the same revision as our last suh=ittal have not been included in this submittal. Additional drawings, developed since our last submittal, have been included.

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The Honorable Richard W. Riley We would appreciate your letting us know whether the State of South Carolina would be interested in participating in such a reoriented pilot program, and what personnel resources and statutory authority the State possesses to meet the surveillance and enforcenent goals of the program.

Specifically, we wish to know which State agencies would be assigned the various responsibilities, what jurisdictional or legal authority they would have, and what type of enforcement action would be possible, e.g.,

rec _ation of licenses and/or pennits, levying of fines, etc.

If cur-rently South Ccrolina does not have the necessary technical capability w would like to know when and how the State might propose to obtain such capability. These points should be covered in a brief letter to the fiRC.

In conclusion, we look fonvard to an early resconse, whether you are interested in having the State of South Carolina considered for participation in the pilot program.

If so, please let us know with whom we should explore this matter farther Questions regarding this progran may be directed to Frank Young or Orie Janinek at the Office of State Programs, HRC (FTS-492-7794 or 301/492-7794).

4 Sincerely.

W2R:.n J.pheq William J. Dircks Executive Director for Operations

Enclosure:

July 1980 NRC/ DOT Review and Prospectus cc: Heyward G. Shealy, State 1.iaison Officer l

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,e: FC A *.* 2 !! (9-?E) N G CM 0240 D U.S. GCV E RNr.*ENT Ppl*4 TING OF FIC E: 1979 289 309