ML20055E707
| ML20055E707 | |
| Person / Time | |
|---|---|
| Issue date: | 12/14/1989 |
| From: | Harold Denton NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20055C180 | List: |
| References | |
| FOIA-90-144 NUDOCS 9007120271 | |
| Download: ML20055E707 (3) | |
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1 MEMORANDUM FOR:
A.' Bert Davis Regional Administrator-Region 111 A
HaroldR.Denton, Director [
bW FROM:
Office of Governmental and Aublic Affairs
SUBJECT:
ORAFT PROPOSED ILLIN0IS DEPARTMENT OF NUCLEAR SAFETY (IONS) REGULATION ENTITLED, " STANDARDS l
FOR THE TREATMENT OF LOW-LEVEL RADI0 ACTIVE 1
WASTE " PART 607 This responds to your memorandum of November 6,1989 requesting program office review of the above subject draft regulation.
We have-
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reviewed the document and our coments are enclosed.- We have provided -
a copy of our comments to the Office of General Counsel -(OGC) and the Division of. Waste Management and Decommissioning (NMSS). 0GC has reviewed our comments and has no objections.
OGC and NMSS will be responding back to you directly under separate cover.
Since you will be receiving comments L
i from these offices, please place the Office of Governmental and Public Affairs (GPA) on concurrence for your reply back to IDNS.
Enclosuce:
As Stated i
i p@j71fg)) 900612 0 'ME;AL I 90-144 PDa DEC 211989 l
4 COMMENTS ON THE ILLIN0l$ DRAFT OF A NOTICE OF PROPOSED STANDARDS:- STANDARDS FOR TREATMENT OF LOW. LEVEL-RADIOACTIVE WASTE COMMENT NUMBER COMMENT 1.
In Section 607.20, there are four definitions of terms which-are not consistent with their.-
definitions in Title 32, Chapter II, Subchapter d of the Illinois l'
Administrative Code.
These terms are " chelating agent,"
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" low-level wa ste," "pyrophoric,"
and " stability." Moreover, some of the definitions are i
inconsistent-with 10 CFR Part i
- 61. -A copy of the definitions l
of these' terms from the Illinois Administrative Code is enclosed.
2.
In Section 607.40, " Process Control Programs," it states that these types of programs must be reviewed and certified i
by the Illinois Department of l
Nuclear Safety.
This requirement will place a specific requirement on nuclear-power stations. Thus, this-
' quirement when implemented, l
' ti extend the authority which s..
,;,.aois now has to regulate certain
- 31c Energy Act materials beyond ik scope of the 274b Agreement ao areas in which the exercise of the ' regulatory authority is preempted by the Federal Government.
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2 COMMENT NUMBER C0ff4ENT 3.
In Section 607.50, " Waste Form Testing Requirements for
'5011dified Wastes," paragraph e, line 7, samples are to be test chamber ar.f a-series of 10 thermal.cyc)6% are to be carried out.- We have suggested in the.
NRC " Technical Position on Waste-Form"(TP)that30thernal-cycles be carried out. What is your rationale for using only ten thermal cycles?
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