ML20134K678
| ML20134K678 | |
| Person / Time | |
|---|---|
| Issue date: | 08/20/1985 |
| From: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-39 NUDOCS 8508300349 | |
| Download: ML20134K678 (2) | |
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.g AUG 2 01985 URF0:SLW URL 6 MEMORANDUM T0:
Leo Higginbotham, Chief Low Level Waste and Uranium Recovery Projects Branch Division of Waste Management FROM:
Edward F. Hawkins, Chief Licensing Branch 1 Uranium Recovery Field Office, Region IV
SUBJECT:
URF0 COMMENTS ON DOE'S DRAFT CERTIFICATION PLAN FOR UMTRAP PROCESSING SITES The Uranium Recove:y Field Office's main comment on the draft Certification Plan is that the document reflects DOE's perception that the NRC's role in the UMTRAP project is passive. This perception sets the tone of the entire document.
The examples contained in the following paragraphs are used as illustrations. The NRC's only other comment on the draft dccument is a request for a copy of the specific radiological surveillance procedures referred to in Section 2.3.3.
First, in general, Public Law 95-604 requires NRC to concur in the Remedial Action Plan (RAP), which includes the final site design, changes made to the final site design after concurrence on the RAP, and in the certification that the remedial action has been completed in accordance with the RAP.
Yet, in three different places in the draft document; the DOE states that the contractor must obtain "D0E", "D0E or NRC", and "NRC" approval for changes to the final approved site design, while in fact the NRC must concur with DOE on any change proposed by the contractor. The draft document does not clearly reflect the NRC's role as stated in Public Law 95-604 On Page 6 of the draft document, the DOE states " In cases where the final design is significantly different than the SCD in the RAP, the DOE will submit the final design to the NRC for approval." Based on this statement, DOE will decide what is significant and therefore, what the 8508300349 850820 PDR WASTE WPt-39 PDR
. AUG 201985 NRC will approve. Again, this does not reflect the NRC's role as defined by Public Law 95-604, but illustrates DOE's perception of the NRC's role in the process.
As a final example, DOE makes the statement on page 6 that " Prior-to or during construction, the NRC will identify any construction activities that they wish to witness. DOE will coordinate the construction such that the NRC or the State are notified of the approximate time that they should visit the site."
In order to concur on the certification that the remedial action has been completed in accordance with the remedial action plan, the NRC will need a viable presence on site as well as conduct a detailed review of the documents as defined in the draft Certification Plan.
In any other licensing activity by URF0, this is standard and considered a pre-licensing activity. URF0 would expect no less on the UMTRAP sites and should not be restricted by DOE from participation except at DOE convenience. Again, this example illustrates DOE's perception of NRC's role as passive.
Based on the above comments, URF0 would recommend that the document be re-written to reflect the NRC's true role in the UMTRAP process.
Should you have any questions regarding the above comments, please call Sandra L. Wastler of my staff at FTS 776-2811.
Edward F. Hawkins, C11ef Licensing Branch 1 Uranium Recovery Field Office Region IV