ML20006A214
| ML20006A214 | |
| Person / Time | |
|---|---|
| Issue date: | 01/17/1990 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 9001250462 | |
| Download: ML20006A214 (5) | |
Text
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. w-PL/C.KAMMERER JhN 1 'l WM MEMORANDUM FOR: Carlton Kammerer, Director State, Local and Indian Tribe Programs, GPA FROM:
Robert M. Bernero, Director Office of Nuclear Material Safety i
and Safeguards
SUBJECT:
TEXAS' DRAFT CHANGES TO URANIUM RULES you requested our comments on Draft 4 of.
By memorandum dated December 7,1989,f Uranium Recovery Facilities.
the Texas Regulations for Licensing o The March 28, 1988, document " Guidance on Technical Assistance Requests from States and Compacts" lays out a procedure for review of Agreement State regulations related to low-level waste. We suggest a process similar to that: discussed in
~
item II of the attachment to that document be followed for the review of-uranium recovery' regulations. We, therefore,.would appreciate your assistance in determining whether NRC's previous comments have been addressed by Texas and whether there are any new issues due to revisions in the text which require technical review by LLWM staff. Our staff reviewed an earlier version of these i
regulations and worked with your staff to prepare a set of comments which were transmitted to Region IV by memorandum from Vandy L. Miller to Robert J. Doda, January 11, 1989.
We are concerned about the definition of byproduct material in these regulations because it is more encompassing than the definition in 10 CFR Part 40. Texas' definition includes material that we (and probably DOE) would not consider to be byproduct material, thus leading to the possibility of problems if the DOE is requested to become perpetual custodian of a site containing such material. We suggest that this concern ~be highlighted to the State of Texas.
05gasd) Robert M., Bernero Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards Distribution:
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SUBJECT AB5 TRACT:
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e PL/C.KAMMERER 1-l l
MEMORANDUM FOR: Carlton Kammerer, Director State, Local and Indian Tribe Programs, GPA l
ROM:
Robert M. Bernero, Director
\\
Office of Nuclear Material Safety and Safeguards
SUBJECT:
TEXAS' DRAFT CHANGES TO URANIUM RULES By memoran m ated December 7,1989, you requested our consnents on Draft 4 of the Texas Regul'a'tions for Licensing of Uranium Recovery Facilities. The March 28, 1988 document " Guidance on Technical Assistance Requests from States-and Compacts" logs'oyt a procedure for review of Agreement State regulations related to low-level haste. Similar to the procedure discussed in item II of
\\
the attachment to that document, we request you to determine whether NRC's previous consnents have been addressed by Texas and whether there are any new issues due to revisions in the text which require technical review by LLWM l
s staff. Our staff reviewed an earlier version of these regulations and worked
- with your staff to prepare a ' set of comments which were transmitted to l
Region IV by memorandum from Vandy L. Miller to Robert J. Doda, J anuary' 11, 1989.
s We are concerned about the definition of byproduct material in these regulations because it-is more encompassing than.the definition in 10 CFR Part 40. Texas' definition includes material that we (and probably DOE) would not consider to be byproduct material, thus leading to the possibility of problems if the DOE is requested to become perpetual custodian of a site containing such material. We suggest that this concern be highlighted to.the State of Texas.
Robert M. Berner'o, Director Office of Nuclear Material Safety and Safeguards
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Distribution:
(# 8900637) Central File # 414.6 NM$S r/f JSurm;e{er l
RBernero RBangart JGreeves MBell PLohaus GArlotto CJenkins JJones t/f JJones t/fs JLepre t/f 1
PDR YES s
PDR NO
/ Category: Proprietary /./ or CF Only
/. /
ACHW YES /_X./
NO.
/
g SUBJECT AB5 TRACT:
TEXAS RAIT"UHANGES TO URANIUM' RULES NC
- See Previous Concurrence
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i l0FC :LLOB*
- LLOB*
- LLWM
- LLWM
- NM55
- NM55
,NAME:MFliegel/jj:PLohaus
- MBell
- RBangart :GArlotto :RBernero lDATE:12/20/89:12/20/89
- 12/21/89 :
/ /89 :
/ /89 : / /89 l
0FF1CIAL RECORD COPY
- (,.
t PL/C.KAMMERER 1
N MEMORANDU'\\:
M FOR Carlton Kammerer, Director State, Local and Indian Tribe Programs, GPA
\\ Office of Nuclear Material Safety FROM:
Robert M. Bernero, Director 3 and Safeguards D
s
SUBJECT:
TEXAS' DRAFT CHANGES TO URANIUM RULES
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By memorandum dated December 7, 1989, you requested our comments on Draft 4 of the Texas Regulations for Licensing of Uranium Recovery _ Facilities. Our staff-reviewed an earlier version of these regulations and worked with your staff to prepare a set of comments'which were transmitted to Region IV by memorandum i
from Vandy L. Miller to Rob'ert J. Doda, January 11, 1989. We have not reviewed Draft 4.
Sitailar t'o how we have been jointly handling reviews of i
proposed State LLW regulation.*l us comments have been addressed by Texas and we would appreciate your assistance in i
determining whether NRC's prev whether there are any new issues due to revisions in the text which require technical review by LLWM staff.
We are concerned about the definition of byproduct material in these s
regulations because it is more encompaqsing than the definition in 10 CFR Part 40. Texas' definition includes material that we (and probably DOE) would not consider to be byproduct materlel, thus leading to the possibility of i
problems if the DOE is requested to become' erpetaal custodian of a site containing such material. We suggest that is concern be highlighted to the State of Texas.
Robert M. Be nero, Director Office of Nuc ear Material Safety and Safeguar Distribution:
(# 8900637) Central File # 414.6 NMSS r/f RBernero RBangart JGreeves MBell JSurmeier PLohaus GArlotto CJenkins JJones t/f JJones r/f JLepre t/f i
/ Category:
Proprietary L/ or CF Only
//
ACNW YES
/
N0
/
SUBJECT AB ACT:
TEXAS RATTCHANGES TO URANIUM RULES
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- LLOB j
- LLWM
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- NMSS
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O R...............gart :GArlotto :RBernero DATE:12/20/89
- 12/20/89
- 12/21/89
- / /89 :
/ /89 :
/ /89 0FFICIAL RECORD COPY
PL/C.KAMMERER' 1-MEMORANDUM FOR: Carlton Kamerer, Director State, Local and Indian Tribes, GPA FROM:
Robert M. Bernero, Director
.i Office of Nuclear Material Safety and Safeguards
SUBJECT:
TEX
' DRAFT CHANGES TO URANIUM RULES By memorandum dated Dece, er 7,1989, you requested our comments on Draft 4 of the Texas Regulations for icensing of Uranium Recovery Facilities. Our staff reviewed an earlier version f these regulations and worked with your staff-to prepare a set of comments whi
.were transmitted to Region IV by memorandum from Vandy L. Miller to Robert. Doda, January 11,1989. We would appreciate your assistance in determining ether NRC's previous comments have been addressed by Texas and whether th re-are any new issues due to revisions in the text which require technical r iew by LLWM staff.
We are concerned about the definition of byproduct material in these regulations because it is more encompa sing than the definition in 10 CFR Part 40. Texas' definition includes ma erial that we (and probably DOE) wouldn't consider to be byproduct materi 1. thus. leading to the possibility of problems if the DOE is requested -to becom perpetual custodian of a site containing such material. We are presenti preparing a Commission paper to address the issue of disposal of non-byprod t materials in tailings which may.
We-suggest that this' concern-lead to NRC policy or regulations in this ar.:
be highlighted to the State of Texas.
Robert M. Ber ro, Director Office of Nucle r Material Safety and Safeguards L'
Distr'bution:
(f 8900637) Central File # 414.6 MSS r/f RBernero RBangart JGreeves MBell J
rmeier PLohaus GArlotto CJenkins JJones t/f-JJ es r/f-JLepre t/f PDR YES O
PDR NO
/ Category:
Proprietary C or CF Only
/
ACNW YES g/
NO
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SUBJECT AB5 TRACT:
TEXAS RAFTTHANGES 'TO URANIUM RULES aO k
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