ML20135D694
| ML20135D694 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/1997 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Rohers A TEXAS, STATE OF |
| Shared Package | |
| ML20133G767 | List: |
| References | |
| NUDOCS 9703050419 | |
| Download: ML20135D694 (4) | |
Text
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"%,1 UNITED STATES p
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NUCLEAR REGULATORY COMMISSION U
wASNINGToN, D.C. age 86 4001 February 11, 1997 Ms. Alice Hamilton Rogers, P.E., Manager UIC, Uranium, and Radioactive Weste Section industrial and Hazardous Waste Division Texas Natural Resource Conservation Commission P.O. Box 13087 Austin, TX 78711-3087
Dear Ms. Rogers:
We have reviewed the proposed revisions to Chapter 336 " Radioactive Substance Rules" of the Texas Natural Resource Conservation Commission. The proposed rules were reviewed by comparison to the equivalent NRC regulations in 10 CFR Parts 19,20,30, 40, and 61, We discussed these comments with members of your staff in Rockville on February 5 and 6,1997.
As the result of the review we have two comments. First, the definition of " byproduct material"in section 336.2 and the definition of " waste"in section 336.702 are not compatible with the equivalent definitions in NRC rules. We understand that your definitions are contained in statute, and note that this issue has been previously addressed in our letter of December 28,1994, and your letter of June 14,1995. We further understand that another effort to amend the statute will be made in the current' legislative session. We recommend that you continue your effort to amend the statutory definitions.
Secondly, while we note that NRC at this time has no rule equivalent to the soil concentration limits in section 336.356(a)(5), the concentration limit set forth in your proposed rule at 336.356(a)(5)(B) is inconsistent with existing Commission guidance. The i
inconsistencies were discussed in our report of an earlier preliminary review of the proposed rule. This report was sent to you in December 1996.
We request that when the proposed rules are adopted and published as final rules, a copy of the "as published" rules be provided to us for review. As requested in our All Agreement States Letter SP-96-027, "Remiast to Hiahliaht Chanaan to Aareement State Pamdations Submitted to NRC for Comnatibility Revi=w"(March 1,1996), please highlight the final changes and send one copy in a computer readable format,if possible.
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- I Alice Hamilton Rogers :
If you have any questions regarding the comments or any of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415-2322, or Mr.
Dennis Sollenberger at (301) 415-2819.
t
- erely,
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Paul H. Lohaus, Deputy Director Office of State Programs
Enclosures:
As stated
~_
-s Alice Hamilton Rogers FEB 111997 If you have any questions regarding the comments or any of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415 2322, or Mr.
Dennis Sollenberger at (301) 415-2819.
j Sincerely, Original Signed By:
PAUL H. LOHAUS 4
Paul H. Lohaus, Deputy Director Office of State Programs 4
Enclosures:
As stated k
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TASK # - 6S325 DATE-12/27/96 MAIL CTRL. - 1996 TASK STARTED - 12/27/96 TASK DUE - 01/29/97 TASK COMPLETED -
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