ML20055E730

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Comments on Draft Application to Amend Agreement Between State of Il & NRC
ML20055E730
Person / Time
Issue date: 12/20/1988
From: Kammerer C
NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To: Lash T
ILLINOIS, STATE OF
Shared Package
ML20055C180 List:
References
FOIA-90-144 NUDOCS 9007120288
Download: ML20055E730 (5)


Text

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NUCLEAR RfeULATORY COMidl8880N maamwovos,o,e, sense -

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Dr. Terry R. Lash Director OT

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l Departsent of Nuc ear Safety-i 1035 Outer Park Drive l

Springfield. Illinois 62704,

.a Dear Dr. Laskt The staff of the NRC has rovfewed the draft a 11 cation to amend agreement between. illinois and the Nuclose Re latory Cospiission.

review covered all aspects of the submittal except those regulations Our which do not pertain to the request for amended agreement. <

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Parts 331, 341 and 400,- We recomend these parts be removed from the req and Parts:341 and 400 sent to our State Agreements Officer in Region !!!

for an independent review.

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3 With respect to ove consent's, we believe it would be more efficient and expeditious if we discuss them with IONS representatives and suggest we meet for this purpose in Washington DC.

clarify and resolve the coments. YheNR We suggest allowing two days to for three of your. staff for this purpose.C will pay travel and per diem 3'

. Please contact me or Mr. John F.

Kendig on the acceptability of such a meeting and dates.

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We have enclosed NRC staff coments on the total proposed draft request for your review prior to the meeting. Our review of the draft application to amend the agreement consists of five parts:

theAgreement(AttachmentB): Statutes (AttachmentC)

Sovernor's (Attachment 0) ands Program Statement (Attachment E)..

Please note that in attachments 0 and f our use of the asterisk (Catego I) in front of the numbered comment indicates the change is necessary NRC staff to sake a finding of e indicate a strong recommendation tibility. Two asterisks (Category 11) believe the changes will' provide regulatory clarity and eliminate-NRC staff an61 ty. Ado tion of t w remain will 1p to en ance the quali comments (Category !!!

The staff also'noted in its rev of he regulations'and Progr)a. we believe.

m Statement.

many areas where'the State reputations State Regulations Part U.-

We note thatare more stringent than those of the NRC or those containe reement State health and:

safety standards generally must be identi al to NRC's standards..Thfs case is an exception because under Section 204 of TNRCA. Agreement State standards for source material ailltag must be equivalent to or more-stringent than the standards adopted and enforced by the Commission.-

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IllinoisLis proposing more stringent standards in a neder of areas.- In the cases where it appears the State will experience major diffievities

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in-implementing the standards the NRC staff has included specific comments on these areas. For,the State's' standards that are more stringent:than the Cosmission's but can technicall NR0 staff plans to discuss;these areas with the l'y be tuplemented, tho' inois staff as e part of the meeting in Washington DC.

. Sincemly.

(

i Carlton Ka r r Director-State. Local and Indian Tribe Programs

Enclosures:

As stated e

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L Allied - Signal l

' No change in Status of the Allied Signal plant since.the Order of May-14, 1987.

  • July 15 1988 Allied-Signal requested a license amendment for onsite b

burial-of uranium contaminated wooden pallets (letter attached).

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1989 NRC requested: additional information and requested that

  • April 5,kept informed.

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  • June'16, 1989 Allied-Signal requeste'd again a license amendment for onsite burial for uranium contaminated pallets under 10 CFR 20.302(a).-

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  • December 4,1989 the IDNS, Division of Radioactive Materials, wrote to Allied Signal stating that IDNS and the CMC had licensing responsibili-ties for all low-levei waste disposal including onsite at the Allied-Signalplant(attached).

' January 11, 1990 OGC provided legal opinion regarding the licensing of disposal of low-level radioactive waste onsite at the Allied-Signal olant. The legal opinion was that the NRC ma the application from Allied Signal (attached)y entertain ~ and act upon

  • NRC' staff are discussing with Allied-Signal whether they wish to continue with the amendment.

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