ML20055D281
| ML20055D281 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1987 |
| From: | Nussbaumer D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Borchert H NEBRASKA, STATE OF |
| Shared Package | |
| ML20055D259 | List: |
| References | |
| FOIA-90-169 NUDOCS 9007060091 | |
| Download: ML20055D281 (6) | |
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Mr. Harold Borchert. Director D
Division of Radiological Health M M& U' Departrient of Health
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- 301 Centennial Mall. South PIA,
- p. O. Box 95007 Lincoln. Nebraska 68509 U/848.
I Deer Mr. Borchert:
We have reviewed Nebraska's draft regulations governing Near-Surface Disposal of Low-Level Radioactive Waste. Our coments are enclosed.
We have also enclosed a copy of the final draft of Part M. and Sections D.307 through D.401 of the Suggested State Regulations (SSR) covering -
low-level waste disposal which we hope will assist you in acecenndating some of the coenents we have made.
We have categorized our conments as follows:
a)
Division 1 Rules - those provisions in NRC-regulations that States must adopt, essentially verbatim into their regulations, Att include regulations that form basic language dea 15%.,;.h radiation protection.
b)
Division 2 Rules - those provisions that address basic principles of radiation safety and regulatory function which a State must address, but the language need not be identical.
c) pfvision 3 Rules - those provisions in NRC regulations which would be appropriate for Agreement States to adopt but do not require any degree of uniformity between NRC and State rules, d)
Division 4 Rules.- those provisions which are reserved to NPC' and should not be addressed by the States.
If there are any questions on matters you feel need discussion, please let ne know.
4,, g '"I Sincerely.
C oracth 1 of :ned byr
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State Agreenents program (j
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Donald A. Mussbaue r k060091900SW Assistant Director for
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Coments on Nebraska Draft Regulations for Disposal of LLW Division ! Coments Coment No.
_ Reference I-Coupent i
v/ 1 p.1, Chapter 1 i
Section 001.
We suggest that the statement, "Such i
Active maintenance includes ongoing i
activities such as pumping and treatment of water from a disposal unit or one time measures such as replacement of a disposal unit cover.'
be inserted be%en
' met.* and ' active.'
Additionally, delete
' institutional control activities" and insert
' custodial activitiet such as repair of fencing, repair or replacement of monitoring equipment, reveqetat'on, minor repa' r of disposal unit covers, and general disposal site upkeep such as mowing
/
grass.
2 p.1, Chapter 1 Section 003.
The definition of
' buffer tone' should be changed to read:
'means a portion of the disposal site that is controlled by the licensee and that lies under the disposal units and between the disposal units and the boundary of the site."
v' 3 p.1, Chapter 1 Section 006.
Delete the words "the institutional control grogram"andinsert custodial care and that assure that the disposal site will remain stable and will
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-t' not need ongoing f
4 ective maintenance.'
4 p.1, Chapter 1 The term ' custodial
.ed og agency" was deleted from the list of definitions.
5 p.2, Chapter 1 The definition of Section 016
'harardous waste' h*9, W should be changed to N6 read. *means those wastes designated as hazardous by U.S.
Environmental Protection Agency in 40 CFR Part 261."
..s 6) p.5, Chapter 1 We suggest that Section 032.01 between '235' and
'but' that "any other material which the l
Nuclear Regulatory I
Comission determines to be special nuclear material' be inserted.
/ 7 p.24, Chapter 5 After " flood plain "
l Section 0.001.01E delete 'or wetland" and insert ', coastal hich harard area or i
wetland, as defined in Executive Order 11988,
' Floodplain Management Guidelines.'
/ - 8 p 28, Chapter 5 Insert 'and beneath section 003.01H, disposed waste' after t
line 2.
' boundary' and the ( )
I period.
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Division !! Coments l
Coment _No, Reference Coment
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P.7. Chapter 3' W suggest that the l
Section 001.02 statement " Failure to cort 1y with this requirement may be grounds for dental of a license.' be inserted after
" facility."
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Elvision !!! Coments
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Coment No.
Reference Coment
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- p. 39. Chapter 6 We suggest that the Section 002.01.
wording " prior to comencement of i
operatior.s* be i
inserted betwe
" assurance" an,rin
.i "that.'
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i Ofvision IV Coments Coment No.
. Reference Coment 1
- p. 37. Chapter 5 The section entitled Section 009.
" Alternative Require-ments for waste classification and characteristics,"
should be deleted.
The authorit described ir,ythis section is reserved to the NRC.
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