ML20151R958
| ML20151R958 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1988 |
| From: | Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nussbaumer D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 8808120360 | |
| Download: ML20151R958 (3) | |
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b 88121 GP 7/13 MEMORANDUM FOR: Ocnald A. Hussbaumer Assistant Director for State Agreements Program State, local and Indian Tribe Programs FROM:
Malcolm R. Knapp, Director Division of Low-level Waste Management and Decommissioning, HMSS
SUBJECT:
REVIEW 0F cal.lFORNIA'S LICENSE APPLICATION REVIEW Pl.AN In accordance with your request of June 29, 1988, we have completed our review of the License Application Review Plan prepared by Roy F. Weston, Inc. for the California Department of Health Services (DHS).
The following are our comments on this document:
1.
DHS has committed to the uce of NUREG-1200 (the Standard Review Plan or SRP) and kUREG-1300 (the Environmental Standard Review Plan or ESRP) as the basis for their review of the U.S. Ecology license application.
However, the plan submitted by DHS is silent on how license conditions will be developed out of the safety and environmental reviews they will conduct. The need for this process to be explicitly stated was expressed to DHS representatives during our visit in April, and it should be made a part of any revision to the review plan.
2.
In Section 4.4 (page 13), the review plan states: "It is assumed that the applicant will prepare the license application package consistent with the available guidance." Rather than assume, DHS should assure that the application package is prepared by the applicant consistent with the available guidance and in a format that will provide for maximum efficiency in review of the application.
3, In Section 5.2 (page 16), DHS proposes to develop quality assurance principles and procedures to be incorporated into an overall quality assurance plan for the license review.
DHS may find relevant portions of Section 9 of the SRP and NUREG-1293, "Quality Assurance for Low-Level Radioactive Waste Disposal Facility" useful in development of this plan.
4 In Section 5.3 (page 18), we recognize that the project director will also act as the license review project manager.
However, in paragraph 3 of this section it appears as if these functions are being performed by two individuals, rather than one. Please clarify this aspect of the management plan.
5.
In Section 7.1 (page 19), DHS indicates that the review process will take approximately 14 months.
However, the estimated times for the major activities listed on this page total to 15.5 months, in addition, on page 20 the bar chart is missing the activity "Comment Analysis". When this 8808120360 880720 f'I (j 0 f PDR WASTE
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activity is factored into the chart, the review time becomes 15.5 months, assuming that the activities in the chart are largely interdependent. The text and bar chart should be corrected as noted.
We appreciate the opportunity to coment on this document and look forward to particpating with your staff in the upcoming review of the California program.
If you have any questions on these coments, please call George Pangburn of my staff at x20580.
ORIGINAL SIGNED BY Malcolm R. Knapp, Director Division of Low. Level Waste Management and Decomissioning, NMSS DISTRIBUTION:
Yellow Ticket #88121 poentral file HMSS rf LLOB rf GPangburn, LLOB SBahadur, LLOB PLohaus, LLOB JSurmeier, LLTB HBell, LLRB JGreeves, LLWM MKnapp, LLWM CCantor, LLhM PDR n
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DATE:~1/6/88
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OFFICIAL RECORD COPY 1
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