ML20043F245
| ML20043F245 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1985 |
| From: | Heyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20043F230 | List: |
| References | |
| FOIA-TUYL90-36 NUDOCS 9006140286 | |
| Download: ML20043F245 (3) | |
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MAY 0 31985 i
MEMORANDUM FOR:
Robert D. Martin, Regional Administrator FROM:
Ralph S. Heyer. Health Physicist State and Governmental Affairs Staff
SUBJECT:
IMPLEMENTATION OF EPA'S GROUND WATER MONITORING STANDARDS (40CFR192)
.On April 30, 1985, I attended a meeting in Austin, Texas, between members of the Uranium Recovery Field Office (URF0) and Texas Department of Health, Bureau of Radiation Control (TDH/BRC) uranium mill staff (list of attendees attached).
The intent of this meeting (was to discuss what is required by the standards EPA issued on October 7, 1983 48 FR 45926-45947).
There appeared to be some uncertainty.as to what specific sections of EPA's referenced Resource Conserva-tion and Recovery (RCRA) provisions are required.
During the meeting Mr. Dale Smith discussed those EPA standards which are effective for NRC licensees.
These sections are:
40 CFR 264.92 Ground Water Protection Standards 40 CFR 264.94 Hazardous Constituents
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40 CFR 264.94 Concentration Limits 40 CFR 264.100 Corrective Action Program 40 CFR 264.111 Closure Performance Standards 40 CFR 264.221 Design and Operating Requirements for Surface Impoundments These regulations clearly apply to conventional mills (surface impoundments) and not to in situ uranium operations. The TDH/BRC has.one conventional uranium mill currently. operating (Chevron Panna Maria, Hcbson, Texas) which is expected to shut down after completing its mining of ore late in July 1985.
It appears that TDH/BRC may implement some of those requirements administrative 1y prior to the adoption of NRC's final regulations.
Later during the day a separate meeting was held between Mr. Edward Hawkins, URF0, I.
and the TDH/BRC staff to discuss applicability of regulations to in situ operations, as well as the current status of those operations in Texas.
Original signed by Ralph Heyer Ralph S. Heyer, Health Physicist State and Governmental Affairs Staff bec w/ enclosure:
P. S. Check R. L. Bangart
/R. J. Doda G. F. Sanborn
.D. A. Nussbaumer, OSP J. O. Lubenau, OSP R. S. Heyer M
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REGULATORY GUIDE 8.1 y
GUIDELINES FOR ISSUING NEW RADI0 ACTIVE MATERIAL LICENSES OR
'CERTTF7 CATES OF REGISTRATION DUE TO A CHANGE IN NAME OR OWNERSHIP 0
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Introduction Tnis guide. describes general conditions that necessitate the issuance of a new license or certificate of registration due to the naue or ownership change of a licensee or registrant.
It also describes conditions involving
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a name vr ownership change that may not require the issuance of a new licens,e or certi fic ate of registration.
This guide does not cover all circumstances, and each license or certificate of registration will be evaluated by the Agency on a case-by-case basis.
-In, all instances, the Agency should be contacted 30 days prior to a change f in name or ownership. When a new licensa or certificate of registration is
% not required, an amendment to the existing license or certificate of registration will be required.
If an application for a new license or certificate of registration.is required, regulatory guides for specific types of licenses and registrations are available from the Agency.
II.
Changes Requiring the Issuance of a New License or Certificate of Registration When there is. to be a change in the name and ownership of a licensee or.
registrant and the facilities, radiation safety offict r, users, or loca-tion (s) will also change, an application for a new lic3nse or certificate 4
of registration'should be submitted..The name change coans a new legal entity will be n am ed on the -license or certificate of registration.
Additional changes in facilities, radiation safety offiner, users, or location (s) are considered significant enough to require thht a new appli-cation be submitted to the Agency for review.' Docume itation of the purchase agrwement and copies of all previously accumu'.ated personnel monitoring records should also be submitted to the Agency.
In these cases, the old license or certificate of registration will be terminated.
\\ TEXAS DEPARTMENT OF HEALTH. BUdEAU OF RADIATION CONTROL, REGULATORY GUIDES
' RIgulatory Guides are issued to describe and make avadable to the Comments and suggesuons for improvements in these Regulatory putWic acceptable methods of irnplemenung spedhe parts of Tesee Reg-Guides are encouraged at all umes and they will be revised. as apg o-elastees fee Coetrel of Radiation to dehneate techniques used by prtate, to accorimodate comments and to reflect new informauon or i
the staff in evaluating spedhc problems or postulated accidents. or to experience. Comments should be sent to the Administrator, Standards
. prov6de guidance to apphcants. licensees. or registrants. Regulatory Branch. Bureau of Radiation Control. Texas Department of Health. I100 Guides are not substitutes for regulations. and comphance with them is W. 49th Street. Ausun. Texas 78756 not requ! red. Metnods and solutions different from those set out in the gu6 des will be acceptable if they provide a basis for the Bureau of Radi-Requests for single copies of issued guides Iwhich may be reproducedi suon Control, Texas Department of Health, to make i.ecessary deter-should be made in writing to the Bureau of Radlauon Control. Te as minations to issue or conunue a license or certificate of regist ation.
Department of Health.1100 W. 49th Street. Ausun. Texas 78756
(7/85)
.III. Cnanges That' May Not ' Require the Issuance of ~a New License or Certificate of Registration A.
A new license or certificate of registration may not be required when-the name of the licensee or registrant will remain the same regardless of other chan<es. This is because the legs 1 entity will remain the same.
However, if a significant change in operating procedures or lines of authority will also occur, a new application mcy be required to be submitted.to the Agency to reflect the changes.
B.
A new license or certifidate of registration may not'be required if only a nt:ne change will occur due to a changa in ownership or for.
other business reasons.
If this change is not accompanied by changes in facilities. users, locations, or procedures, the license or certi-ficate of registration need only be amended to reflect the different legal entity. However, the licensee or registrant must submit written certi fication to the Agency that the only change is in the company name and that 'the new licensee or registrant shall continue to abidt J
by the previously submitted application, established license conditions, procedures, and other requirements.
Documentation of the purchase agreement and copies of all previously accumulated personnel i
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monitoring records should also be submitted to the Agency.-
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