ML20138C976
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UNITED STATES
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7 ni MUCLEAR REGULATORY COMMISSION i
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wAssmorow, o. c.aoses
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June 18, 1990-t.
n MEMORANDUMFORi Guy i Arlotto, MSS '
Janiece E. Moore, OGC C
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Frank J. Miraglia, NRR Luis A. Reyes, RII Brian' Sheron, RES
'FROM:
Edward L. Jordan, Chairman j
i Committee to Review Generic Requirements j
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SUBJECT:
CRGR DISPOSITION OF REVIEW ITEM #23 (DISTRIBUTED TO l
Co mITTEE MEMBERS ON APRIL 23,1990)-
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!The subject review package involves proposed amendments to 10 CFR Parts 20 and J61 on low-level waste shipment manifest infomation and reporting.
- Briefly, F
the staff is proposing (a) to change existing requirements on the data that.
l licensees must include in LLW shipment manifests to improve LLW data completeness and consistency; (b) to establish minimum requirements for design and use of l
computer recordkeeping systems at LLW disposal facilities; and (c) to require 1
that disposal facility operators routinely submit, in an electronic format, l
reports of LLW shipment manifest information.
Stated objectives of the proposed-i action are to improve NRC and State programs for regulation of LLW disposal j
facilities, and to amend our regulations to be consistent with the requirements j
of the Low-Level Radioactive Waste Policy Amendments Act of 1985.
J The proposed amendments appear to impose backfits that impact both directly and
. indirectly the cost of power reactor operation; therefore, CRGR review would i
normally be required.
Another aspect of the package that would appear to warrant CRGR discussion is the position taken by OGC in this case, i.e., that i
. the changes to be imposed (specifically, in the areas of LLW data reporting and j
LLW storage facility recordkeeping) are not subject to the backfit rule.-
i Notwithstanding such considerations, due to the low safety priority associated with the issue (compared to others considered by CRGR during the April-May period), and more recently the unavailability of key staff persons needed to support its presentation to CRGR,'it has not been possible to schedule this p
ites for review for more than two months.
Because of these circumstances, I am requesting your views regarding the need for formal CRGR review of this t
- item at this stage.
July 11 appears to be the earliest practicable date for review at a CRGR meeting; and it is possible that such review could be delayed longer (e.g., if the ATWS appeal _ review takes more than one meeting).
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In view of the fact that the proposed action involves issuing a draft rule for
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comment, I believe that CRGR could defer their-review to the final rule stage.
This would avoid further delay of this ites, and ivrove the Committee's review of' this matter from.having benefit of _ a range of views on the question of need for the proposed action,'and comments from affected parties regarding estimated costs of implementation.
Accordingly, if I hear no objection from any member, I'will: notify the sponsoring office (RES) one week from the date of this letter 1
2 that the proposed rule can be issued for public comment without the need for formal review by CRGR.
The Committee is to be informed of public comment received and will review this matter formally at the final rule stage.
If any member has questins or objections to this disposition or wishes to request formal review of this item at a CRGR meeting, please call me or J. Conran (x29855) by COB, June 19.
=
ard V. Jordan, Chairman Commit $ to Review Generic Requ ements cc:
J. Taylor, E00 E. Beckjord, RES i
L. Shao, RES M. Silberberg, RES
~M. Haisfield, RES i
G. Roles, NMSS
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