ML20128E446
| ML20128E446 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1992 |
| From: | De Planque E NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9302100445 | |
| Download: ML20128E446 (6) | |
Text
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RELEMED TO THE PDR NOTATIO_N V0TE]
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RESPONSE SHEEI
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SAMUEL J. CHILK, SECRETARY OF THE Col 41ISSION FROM:
C0!44ISSIONER DE PLANQUE
SUBJECT:
SECY-92-356 - FINAL RULE, AMENDMENTS TO 10 CFR PARTS 30, 40, 70, AND 72, "DEC0l44TSSIONING RECORDKEEPING AND LICENSE TERMINATION:
DOCUMENTATION ADDITIONS" APPROVED x(in part)
DISAPPROVED x (in part) ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION C0l44ENTS:
see attached comments.
38R 288AA !!!
CORRESPONDENCE PDR L O br <r u SIGNATURE /
RELEASE VOTE
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oecember 3,1992 DATE WITHHOLD VOTE
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1 ENTERED ON "AS" YES N0 x
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Commissioner de Planque's Comments on SECY-92-356, Final Rule, Amendments-to-10 CFR Parts 30, 40, 70, and 72, Decommissioning Recordkooping and License Termination Documentation Additions"-
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I approvo in part and disapprova in part with the following comments and edits.
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t The background and summary sections of the FR notico state that-this rule would not apply to areas whero only sealed sourcos:woro use' provided they have not leaked or if they had leaked, no contamination romained after cleanup. The clarifications were not-added to the text of the rule.
The wording-in parts 30 and 70 (30. 3 5 (g) (3) and 70.35(g) (3)) should be revised to clearly stato:-
"Except for areas containing only sealed sources (provided the sources have not leaked or no contamination remains after cleanup of'any leak), or byproduct materials having only half-lives of less than 65 days...",
The rule is unclear as to what levol-of detail'those lists aroLto:
contain.
4sc example, is NRC asking for building name and y
number, room number, geographic coordinates,; address, dates used,.
If decontaminated - when, what nuclide(s) was (were) used-in which rooms, otc.?
Since the rule is ambiguous on the lovel of detail, a1 statement thatiguidance--on the lovel-of-specificity-of--
information being required will be developed should be placed in a
the supplementary information-section to the rule, perhaps'in the background section.-
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.- n I do not agree with dropping the requirement _.to list currentLand' old burial sites within a site simply because this,is-information-t that is required by the new Part 20.
Since the whole purpose of this exercise to censolidate the information "in one document", and be;atse the rulo requires a listing of other information which is already required by other regulations, I see.
no reason to exclude old and current burial sites within the site boundaries.
Old burial sites may present NRC with major 4
challenges in some c our cleanup actions,- and thus including their locations in this listing saems appropriate.
.It'should not-require a major expenditure of time to includu a copy of the-listing compiled for the Part 20 provision..
o Enclosura 7, items 4'and 9 (the OMB FR notice) should be revised
- (see attached) to more fully describe the information collection requirements.
Further, it appears as if we have been requested cVer the past several r. saths to review a number of act. ions' pertaining. to decommissioning.
And there are several yet to come..I' believer this would be an opportune time for NRC to pauseLand take a.look at the decommissioning program as a whole, the-direction the agency is; headed and how the NRC intends to achieve ics;goalsfin.
the program.-
This includes examining resources, what pieces of' the program are missing, what kind of guidal.ce-needs to 133 :
developed, impacts'in other Areas (such as low level waste),e NRC's role in coer11 nation with_other agencies, etc.
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-understanding'that aTdecommissioning management-plan is-being:-
developed,=and I1believe that-it'Nould be appropriate.that thei i
Commission be';~ given : tie ' opportunity to.revies and. discuss;the-plan.-
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4.
How often is the collection required:
Initial update of the-decomissioning listing and then no later than once every 2 years until termination of license, for those licensees requiring approval of a decommissioning plan,. one-time submittal of a list of certain equipment p
to be left onsite at license termination. ttqiS li9t of a y&M, o vd 5.
Who will be required or asked to report:
10 CFR 30, 40, 70, and 72 NRC licensees and Agreement State licensees except those who possess only non-leaking sealed sources, or byproduct material with half-life of less than 65 days, or depleted uranium used only for shielding or as penetrators in unused munitions.
6.
An estimate of the number of respondents: Approximately 3,309 of the approximately 23,500 NRC and Agreement State licensees will maintain the decommissioning listing documentation.
An average of 19 licensees annually will submit the list as part of their decommissioning plan.
An average of 22 licensees annually will submit the equipment list at license termination.
7.
An~ estimate of the number of hours annually needed to complete the requirement or request:
5 initial list, 1 every 2-year duration.
Note:
Ouration of license is for 5 years resulting in a 5-hour average total response effort (5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> initial list plus 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for 10 years, averaged over 10 years and multiplied by 5).
2 l
y V.
An indication of whether Section 3504(h), Pub. L,96-511 applies:
8.
Not Applicable.
The final rule would require materials licensees (exemoting Abstract:
f less than 9.
the ones who possess scaled sources or byproduct material o d areas 65-day half-life) to maintain a itst identifying all restricte d all areas while licensed materials and equipment were used or store,
i i g rule for where documentation is required in the current decommiss on n f restricted areas unusual occurrences or spills, and all areas outside o the conttining material such that if the license were terminated, licensee would be required to decontaminate the area or seek The final rule also regt. ires some licenseest approval for disposal.
after decommissioning to submitv pecific information on certain s
the time of license ant that will remain onsite at decontaminated equil termination.
Copies of the submittti may be inspected or obtained for a f NRC Public Document Room, 2120 L Street, NW. (Lower Level),
Washington, DC.
Comments and questions can be directed by mail to the OMB rev Ronald Minsk Office of Information and Regulatory Affairs l
(3150-0017,3150-0320,3150-0009,3150-6132-l NE0B-3109 3
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