Text

Concurs W/Commission Paper Entitled, Draft Rulemaking Plan: Amends to 10CFR30 & 35 - Financial Assurance for Teletherapy & Kr-85 Licensees, If Encl Comments Are Incorporated Into Rulemaking Plan
	ML20148D511
Person / Time
Issue date:	05/21/1997
From:	Paperiello C; NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Morrison D; NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20147J307	List: ML20147J304; ML20148C539; ML20148D511; ML20148D524; ML20148D530;
References
	REF-WM-3 NUDOCS 9705300265
	Download: ML20148D511 (7)
	v • d • e

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, May 21, 1997 l

MEMORANDUM 70: David L. Morrison. Director l Office of Nuclear Regulatory Research FROM: Carl J. Paperiello. Director (0RIGINAL SIGNED BY Office of Nuclear Material Safety M. KNAPP FOR) and Safeguards j

SUBJECT:

OFFICE REVIEW AND CONCURRENCE ON A RULEMAKING PLAN FOR

. AMENDMENTS TO 10 CFR PARTS 30 AND 35 - FINANCIAL i ASSURANCE FOR TELETHERAPY AND KRYPTON-85 LICENSEES l

! The Division of Waste Management staff has reviewed the Commission Paper

$ entitled " Draft Rulemaking Plan: Amendments to 10 CFR Parts 30 and 35 -

3 Financial Assurance for Teletherapy and Krypton-85 Licensees." The Regions and IMNS were also surveyed for comments. We have attached our comments and concur if these comments are incorporated into the Rulemaking Plan. Our comments have been discussed with Clark Prichard, of your staff, and we understand that he finds them acceptable.

Attachment:

As stated CONTACT: Louis M. Bykoski. NMSS/DWM 415-6754 DISTRIBUTION: NMSS 9700191 Central File LLDP r/f DWM r/f NMSS r/f PUBLIC NMSS Dir. Off. r/f CPoland ACNW MFederline Greeves PSobel DWM t/f 4 To receive a copy of this document in small box on "OFC:" line enter: "C" = Copy without attachment / enclosure; "E" = Copy with cttichment/ enclosure; "N" = No copy I

Path & File Name: S:\DWM\LLDP\ LMB \CPREVIEW.MEM 'SEE PREVIOUS COMMENTS ce<enooreo/uAv 20.1897 OFC LLDP' LLDP' LLDP' DWM* IMNS* NMpg.,.

NAME LBykoski/bg TCJohnson JHickey MFederline LCamper Cheb DATE 5/1/97 5/15/97 5/15/97 5/20/97 5/15/97 5[g/97 OFFICIAL RECORD COPY

</</va o ACNW: YES _X NO _ Category: Proprietary _ or CF Only _ ,'

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4 E E NUCLEAR REGULATORY CGMMISSION "f WASHINGTON, D.C. 20555-(401

,/ May 21, 1997 i

! MEMORANDUM TO: David L. Morrison.-Director i Office of Nuclear Regulatory Research 1

)' FROM: Carl J. Pa)eriello, ector ~

Office of iuclear and Safeguard h

SUBJECT:

OFFICE REVIEW AND CONCURRENCE ON A RULEMAKING PLAN FOR t

AMENDMENTS TO 10 CFR PARTS 30 AND 35 - FINANCIAL ASSURANCE FOR TELETHERAPY AND KRYPTON-85 LICENSEES i

l j The Division of Waste Management staff has reviewed the Commission Pap'er l entitled " Draft Rulenaking Plan: Amendments to 10 CFR Parts 30 and 35 -

i Financial Assurance for Teletherapy and Krypton-85 Licensees." The Regions and IMNS were also surveyed for comments. We have attached our comments and l

[ concur if these comments are incorporated into the Rulemaking Plan. Our comments have been discussed with Clark Prichard, of your staff and we !

l i

j understand that he finds them acceptable.

i j

Attachment:

As stated i CONTACT: Louis M. Bykoski, NMSS/DWM

! 415-6754 t

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l NMSS Comments on Rulemakina Plan: Amendments to 10 CFR Parts 30 and 35 -- Financial Assurance for Teletheraov and Krvoton -85 Licensees DWM COMMENT l

The rulemaking plan should evaluate the costs of decontaminating Kr-85 gas handling systems. Note that NMSS issued Information Notice 96-51, " Residual Contamination Remaining in Krypton-85 Handling System after Venting," indicating that Kr-85 contamination can remain in gas handling systems following decommissioning. If the costs to remediate the gas handling systems are a few thousand dollars, these nominal decommissioning costs would justify eliminating Kr-85 as a nuclide for which decommi sioning financial assurance is recaired.

IMNS COMMENTS Cost Factor Estimates:

1. Teletherapy l a. One hour of staff time to proceso an exemption appears to be low. It is better compared with the cost of processing an amendment - based on Fees in Part 170, about $440 or 3.5 staff hours.

b. NRC staff annual labor costs seem low. We suggest OC be asked the annual labor cost per material person, 1

c. We believe that most teletherapy licenses already have a condition which -

allows this exemption and therefore no cost savings would be realized. To the contrary the cost of removing these conditions would result in 3.5 staff hours additional costs per license, l 2. Krypton-85

a. The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> stated it would take to do a Kr-85 exemption appears to be high.

We recommend that it be compared with the cost of processing an amendment as mentioned in la, above.

b. The suggested NRC hourly labor rate ($375) in the paper seems to be twice what we charge licensees.

l Preferred Ootion l Because all medical rulemaking issues are controversial, we recommend not using the

! direct rulemaking approach.

1 I

Attachment

a - . .

M ORANDUM T0: David L. Morrison Director Office of Nuclear Regulatory Research FROM. Carl J. Pa)eriello. Director Office of luclear Material Safety and Safeguards

SUBJECT:

OFFICE REVIEW AND CGNCURRENCE ON A RULEMAKING PLAN FOR AMENDMENTS TO 10 CFR PARTS 30 AND 35 - FINANCIAL ASSURANCE FOR TELETHERAPY AND KRYPTON-85 LICENSEES The Divisi-n of Waste Management staff has reviewed the Commission Paper entitled " Draft R making Plan: Amendments to 10 CFR Parts 30 and 35 -

Financial Assurance f Teletherapy and Krypton-85 Licensees." The Regions and IMNS were also surve d for comments. We have attached our comments and concur if these comments ar . incorporated into the Rulemaking Plan.

Attachment:

As stated CONTACT: Louis M. Bykoski, NMSS/D 415-6754

\

DISTRIBUTION: NMSS 9700191 Central File LLDP r/f WM r/f NMSS r/f PUBLIC NMSS Dir. Offi r/f ~.CPoland NW MFederline Greeves DWM t/f PSobel To receive a copy of this document in small box on "OFC:" line enter: "C" = Copy without attachment / enclosure; "E" = Copy with attachment / enclosure: "N" = No copy '

P;th & File Name: S:\DWM\LLDP\ LMB \CPREVIEW.MEM *SEE PREVIOUS COMMENTS creenooreo/uay ro,iss7

~

OFC LLDP" LLDP* LLDP' DWM '\ IMNS* NMSS NAME LBykoski/bg TCJohnson 'JHickey MFederifne LCamper CPaperiello DATE 5/1/97 5/15/97 5/15/97 5/20/97 k 5/15/97 5/ /97 OFFICIAL RECORD COljY ACNW: YES X_NO _ Category: Proprietary _ or CF Only _ \

1G : YES NO \

LSS : YES NO Delete file after distribution: Yes No \

\

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l

MEMORANDUM T0: David L. Morrison, Director i Office of Nuclear Regulatory Research i FROM: Carl J. Pa)eriello, Director l Office of luclear Material Safety and Safeguards

SUBJECT:

OFFICE REVIEW AND CONCURRENCE ON A RULEMAKING PLAN FOR AMENDMENTS TO 10 CFR PARTS 30 AND 35 - FINANCIAL ASSURANCE FOR TELETHERAPY AND KRYPTON-85 LICENSEES The Division of Waste Management staff has reviewed the Commission Paper entitled " Draft Rulemaking Plan: Amendments to 10 CFR Parts 30 and 35 -

Financial Assurance for Teletherapy and Krypton-85 Licensees." The Regions ,

and IMNS were also surveyed for comments. We have attached our comments and concur if these comments are incorporated into the Rulemaking Plan. I l

Attachment:

As stated CONTACT: Louis M. Bykoski NMSS/DWM 415-6754 DISTRIBUTION: TICKET: 9700191 Central File LLDP r/f DWM r/f NMSS r/f PUBLIC Dir. r/f CPoland MKnapp JLinehan ACNW MFederline Greeves PSobel DWM t/f To r::ceive a copy of this document in small box on "OFC:" line enter: "C" = Copy without attachment / enclosure: "E" = Copy with ttichment/ enclosure; "N" = No copy f(N Path & File Name: S:\DWM\LLDP\ LMB \CPREVIEW.MEM *SEE PREVIOUS COMMENTS OFC LLDP" [ LLDP' f, LL@ // DWM A/ IMNS* NMSS NAME LBykoski/bg TCJohnson Jbkey NEr LCamper CPaperiello DATE 5/1,07 5/15/97 5//N97 5/k/97 5/15/97 5/ /97 OFFICIAL RECORD COPY 9/ f//4/f7 jfje ACNW: YES _X__ NO Category: Preprietary _ or CF Only _ "//yi IG : YES _ NOX_ _

LSS : YES _ NO g Delete file af ter distribution: Yes _ No _

. . ~ _- . - - _ -_. - .. - - . .

e MEMORANDUM T0: David L. Morrison, Director Office of Nuclear Regulatory Research FROM: Carl J. Pa ; eriello. Director Office of luclear Material Safety and Safeguards

SUBJECT:

OFFICE REVIEW AND CONCURRENCE ON A RULEMAKING PLAN FOR AMENDMENTS TO 10 CFR PARTS 30 AND 35 - FINANCIAL ASSURANCE FOR TELETHERAPY AND KRYPTON-85 LICENSEES The Division of Waste Management staff has reviewed the Commission Paper entitled " Draft Rulemaking Plan: Amendments to 10 CFR Parts 30 and 35 -

Financial Assurance for Teletherapy and Krypton-85 Licensees." The Regions and IMNS were also surveyed for comments. We have attached our comments and concur if these comments are incorporated into the Rulemaking Plan.

Q[,tockaoA Encles6re: As stated CONTACT: Louis M. Bykoski, NMSS/DWM 415-6754 DISTRIBUTION: TICKET: 9700191 Central File LLDP r/f DWM r/f NMSS r/f PUBLIC Dir. r/f CPoland MKnapp JLinehan ACNW MFederline Greeves PSobel Own 4 {F To receive a copy of this document in small box on "OFC:" line enter: "C" = Copy without attachment / enclosure: "E" = Copy with cttachment/ enclosure; "N" = No copy Path & File Name: S:\DWM\LLDP\ LMB \CPREVIEW.MEM 'See Previous Comments OFC LLDP* LLDP l LLDP DWM IMNS NMSS NAME LBykoski/bg TCkth son JHickey bmper CPaperiello DATE 5/1/97 5/'97 h 5/ /97 5/ /97 5697 5/ /97 OFFICIAL RECORD COPY !

ACNW: YES _X. NO _ Category: Proprietary _ or CF Only _

IG : YES _ NO _

LSS : YES __ NO _ Delete file after distribution: Yes No

/

/ :

MEMORANDUM T0: David L. Morrison, Director / I Office of Nuclear Regulatory Research 7

/ '

FROM: Carl J. Paperiello, Director /

Office of Nuclear Material Safety and Safeguards i l

SUBJECT:

0FFICE REVIEW AND CONCURRENCE ON A RULEMAKIyG PLAN FOR i

AMENDMENTS TO 10 CFR PARTS 30 AND 35 - FINANCIAL !

ASSURANCE FOR TELETHERAPY AND KRYPTON-85' LICENSEES j

/

The Division of Waste Management staff has . viewed the Commission Paper i

1

! entitled " Draft Rulemaking Plan: Amendments t 10 CFR Parts 30 and 35 -

i

! Financial Assurance for Teletherapy and Kry on-85 Licensees." We have no comments and concur in the Rulemaking P1 . .

1 l

i CONTACT: Timothy C. Johnson, NMSS WM i 415-7299 i

DISTRIBUTION: TICKET: 970041

, Central File LLDP r/f DWM r/f NMSS r/f PUBLIC 2

h'[ Dir. r/f MFederline oland Greeves MKnapp PSobel JLinehan ACNW To rroelve e copy of thle document in smalf box on "oFC:" line enter: "C" = Copy without ettechment/ enclosure: "E" = Cnoy with attachmentlenolosure: "N" = No copy Path & File Name: S:\DWM\LL P\ LMB \CPREVIEW.MEM

} OFC Ll,DP / LLDP LLDP DWM IMNS NMSS NAME hh/bg/ TCJohnson JHickey JPiccone CPaperiello l DATE 5///97/ 5/ /97 5/ /97 5/ /97 5/ /97 5/ /97

' OFFICIAL RECORD COPY ACNW: YES _K. O_ Category: Proprietary _ or CF Only _

IG : YES _ N _

j LSS : YES _ O_ Delete file after distribution: Yes No 4

a d

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ML20148D511

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