ML20206A452

Provides Results of NRC Staff Review of Draft Pennsylvania Regulation That Will Be Needed to Support Request for Agreement as Explained in Ltr from SR Levin.Three Comments Identified in Encl

ML20206A452
Person / Time
Issue date:	04/14/1999
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Allard D PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML20206A456	List: ML20206A452 ML20206A480
References
NUDOCS 9904280171
Download: ML20206A452 (10)

Text

.

- D:vid J. Allard, Dir:ctor Bureau of Ridi tion Prot:ction AM i41999 a Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 -

l Harrisburg, PA 17105-8469

^

Dear Mr. Allard:

This letter provides the results of the U.S. Nuclear Regulatory Commission (NRC) staff review of the draft Pennsylvania regulations that will be needed to support your request for an Agreement as explained in Stuart R. Levin's letter dated February 24,1993. The review covered the draft regulations in Title 25, Environmental Protection, Chapters 215-232, dated December 3,1998 and November 12,1998; the final regulations in Chapters 215-219, j Volume 1, December 1998; Chapter 220 October 17,1998; Chapters 221-230, Volume 2, i December 1998; and the final regulations in Chapters 236 (November 23,1996) and 237 (December 21,1996). The review also covered the supplement regarding Section 217.200 dated March 9,1999. The draft and final regulations were reviewed by comparison to the equivalent NRC regulations in 10 CFR Parts 19,20,30,31,32,33,34,35,36,39,40,61,70, 71 and 150. We also reviewed the responses to our letter dated July 30,1998, that are attacned to Mr. Levin's letter.

As a result of our review, we have three comments that are identified in the enclosure. We would appreciate your response to the comments The comments are based on the compatibility and health and safety categories contained in OSP Procedure SA-200,

~ Compatibility Cateaories and Health and Safety Identification for NRC Reaulations and Other Prggram Elements.

I The review followed OSP Procedure SA-201, Review of State Reaulations (November 10, 1998). We request that when the proposed regulations are published for public comment, a copy of the "as published" regulations be provided to us for review._ As requested in OSP Procedure SA-201, please highlight any changes and send one copy in a computer readable format,if possible.

If you have any questions regarding the comments, the compatibility and health and safety I categories, or any of the NRC regulations needed for compatibility and health and safety, please contact me or Dr. Stephen N. Salomon of my staff at (301) 415-2368 or E-mail: SNSONRC. GOV. i Sincerely, OriginalSi0ned By:

9904290171 990414 y PAULH. LOHAUS '

PDR STPRO ESOPA Paul H. Lohaus, Director  ;

PDR R Office of State Programs  !

I

Enclosure:

As stated- \

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OSP FILE CODE: SP-NA-17 d

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. . . . . ,o April 14, 1999 David J. Allard, Director Bureau of Radiation Protection  :

Department of Environmental Protection I Rachel Carson State Office Building l P.O. Box 8469 Harrisburg, PA 17105-8469

Dear Mr. Allard:

This letter provides the results of the U.S. Nuclear Regulatory Cornmission (NRC) staff ,

review of the draft Pennsylvania regulations that will be needed to support your request for )

an Agreement as explained in Stuart R. Levin's letter dated February 24,1999. The review l' covered the draft regulations in Title 25, Environmental Protection, Chapters 215-232, dated December 3,1998 and November 12,1998; the final regulations in Chapters 215-219, Volume 1, December 1998; Chapter 220, October 17,1998; Chapters 221-230, Volume 2, December 1998; and the final regulations in Chapters 236 (November 23,1996) and 237 (December 21,1996). The review also covered the supplement regarding Section 217.200 dated March 9,1999. The draft and final regulations were reviewed by comparison to the equivalent NRC regulations in 10 CFR Parts 19,20,30,31,32,33,34,35,36,39,40,61,70, 71 and 150. We also reviewed the responses to our letter dated July 30,1998 that are attached to Mr. Levin's letter.

As a result of our review, we have three comments that are identified in the enclosure. We would appreciate your response to the comments The comments are based on the compatibility and health and safety categories contained in OSP Procedure SA-200, Comoatibility Cateaories and Health and Safety Identification for NRC Reculations and Other Proaram Elements.

The review followed OSP Procedure SA-201, Review of State Reaulations (November 10, 1998). We request that when the proposed regulations are published for public comment, a copy of the "as published" regulations be provided to us for review. As requested in OSP Procedure SA-201, please highlight any changes and send one copy in a computer readable format,if possible.

If you have any questions regarding the comments, the compatibility and health and safety categories, or any of the NRC regulations needed for compatibility and health and safety, please contact me or Dr. Stephen N. Salomon of my staff at (301) 415-2368 or E-mail: SNS @ NRC. GOV.

Sgtrely, U

y cu  ! b d Paul H. Lohaus, Director Office of State Programs

Enclosure:

As stated

3 Comments on Proposed and Final Pennsylvania Regulations Against Compatibility and Health and Safety Categories State NRC Gategory Reaulation Regulation Subiect and Comments Comment #1 1

Chapter 215 General Provisions 215.2 Definitions  ;

C 20.1003 Entrance or access point A 20.1003 lonizing radiation C 19.3 Worker We bring to your attention that these definitions appear to be duplicative to some extent of the definitions that are incorporated by reference in 10 CFR Parts 19 and

20. We suggest you consider their deletion.

1 C 150.3(g) Person '

The definition of person meets the essential objectives.

However, see Comment # 3.

Comment #2 Chapter 217 Licensing of Radioactive Material NRC Subchapter B 30 General Provisions for Radioactive Material NRC Subchapter D 32 Specific Licenses to Manufacture or Transfer Certain items Containing Radioactive Material NRC Subchapter G 40 Licensing of Source Material NRC Subchapter H 70 Licensing of Special Nuclear Material NRC SubchapterJ 150.20 Reciprocity NRC Chapter 230 71 Packaging and Transportation of Radioactive Materials There are provisions in 10 CFR Parts 30,32,40,70,71 and 150.20, which Pennsylvania has incorporated by reference, that are reserved to NRC. (These provisions, are identified by the 'NRC' category in OSP Procedure SA-200.) We conclude, however, that the standard language in 215.1(f) is sufficient to address the incorporation by reference of provisions reserved to NRC. Section 215.1(f) provides that, "If a provision of the Code of Federal Regulations incorpora:ed by

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-e Comments on Proposed and Final Pennsylvania Regulations Against Compatibility and Health and Safety Categories State NRC l Catenory Regulatlen Regulatien Subiect and Comments reference in this article is beyond the scope of authority l granted the department under statute, or is in excess of L the statutory authority, the provision shall be and l

remain effective only to the extent authorized by Pennsylvania law. We would appreciate confirmation to that effect.

! Comment # 3 Chapter 236 61 Low-Level Radioactive Waste l 236.2 61.2 Definitions

[C] Person l

As noted in our letter dated July 30,1998, the definition of " person" appears to be inconsistent in that paragraph l (i) refers to a definition in Section 215.2 that conflicts l with paragraph (ii). Paragraph (ii) includes all agencies l of the Federal government other than the NRC whereas paragraph (i) excludes Federal government agencies.

We notice that definition (ii) of person appears in the Low-Level Waste Disposal Act (Act 1988-12), Section

103. Definitions. However, we understand that i definition (ii) allows Federal agencies to dispose of low-level radioactive waste in the disposal facility. The first definition of person applies to regulatory actions and excludes Federal agencies. This interpretation is l consistent with Section 102. Legislative findings, (Act i

1988-12) that states, "It is the purpose of this act to:...

1 (2) Establish and maintain, to the extent allowab!e under Federal law, a comprehensive and pervasive low-l level waste disposal management, licensing and I

regulatory program in the Department of Environmental Resources..." and is in agreement with the proposed Pennsylvania Agreement in which the State does not have regulatory jurisdiction over Federal agencies. We would appreciate confirmation of this interpretation.

2

[

Comments on Proposed and Final Pennsylvania Regulations Against Compatibility and Health and Safety Categories State NRC Catenory Reaulation Regulation Sublect and Comments Comment #4 H&S 236.226 61.24(k)(1) Conditions of the license.

Paragraph 236.226 omits a paragraph on bankruptcy from the regulation, Bankruptcy Filing; Notification Requirements,52 FR 1292, January 12,1987 effective February 11,1987. Such a paragraph should be added to meet the compatibility category.

l However, Response #9 in Mr. Levin's February 24, 1999 letter says that the omission can be corrected by license condition because it is unique to the low-level radioactive waste site. We need assurance that this license condition can be instituted as a legally binding requirement (i.e., license conditions are permitted by ,

the State's administrative procedures and are legally i binding). Also, you must submit the license condition for review.

1 i

3

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Mr. David J. Allard, Director Bureau of Radiation Protection Department of Environmental Protection Rachel Carson State Office Building i P.O. Box 8469 Harrisburg, PA- 17105-8469

Dear Mr. Allard:

1 The purpose of this letter is to provide the results of the U.S. Nuclear Regul ory Commission

- (NRC) staff review of the draft Pennsylvania regulations that will be neede o support your request for an Agreement as explained in the letter dated February 24,1 , from Stuart R.

Levin, Chief, Division of Radiation Control. The review covered the draft gulations in Title 25, Environmental Protection, Chapters 215-232, dated December 3,1998 d November 12, 1998, the final regulations in Chapters 215-219, Volume 1, December 98; Chapter 220, October 17,1998; Chapters 221-230, Volume 2, December 1998; an e final regulations in Chapters 236 (November 23,1996) and 237 (December 21,1996). e review also covered the supplement regarding Section 217.200 dated March 9,1999. T draft and final regulations were reviewed by comparison to the equivalent NRC r ulations in 10 CFR Parts 19, 20, 30, 31, 32, 33, 34, 35, 36, 39, 40, 61, 70, 71 and 150. W lso reviewed the responses to our letter dated July 30,1998, that are attached to Mr. Levin's tter.

As a result of our review, we have four comments that are ide ied in the enclosure. The comments must be addressed to meet the compatibility and Ith and safety categories as indicated in the OSP Procedure SA-200, Comoatibility Cate es and Health and Safety identification for NRC Reaulations and Other Proaram ElemInts.

The review followed the standard procedure as outlined ir SP Procedure SA 201, Review of State Reaulations (November 10,1998). We request th when the proposed regulations are published for public comment, a copy of the "as publish regulations be provided to us for review. As requested in OSP Procedure SA-201, plea highlight any changes and send one copy in a computer readable format, if possible.

if you have any questions regarding the comments, e compatibility and health and safety categories, or any of the NRC regulations needed r compatibility and health and safety, please contact me or Dr. Stephen N. Salomon of y staff at (301) 415-2368 or E-mail: SNSONRC. GOV.

Sincerely, Paul H. Lohaus, Director Office of State Programs

Enclosure:

As stated Distnbution:

DlR RF (9-42) RBlanton DCD (SP05)

.SDroggitis . JKenn , LLDR < PDR (YES_/_ NO )

SMoore, IMNS ' GKim, GC Pennsylvania File - BUsilton DOCUMENT NAME: G:\SNS\ALLARD.WPD/ *See previous concurrence.

Tuesolve a oop r of this document. Indloots in the bios: "C" = Copy without attachment / enclosure "E' = Copy with attachment / enclosure v = No copy OFFICE , OSP Qn5 lC OSP:D , l RI:RA l NMSS:D l OGC l NAME- . SSalomon:nb:kk:nb PHLohaus4% HMiller CPaperiello Peme" M /qh _

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Mr. David J. Allard, Director Bureau of Radiation Protection Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105 8469

Dear Mr. Allard:

The purpose of this letter is to provide the results of the U.S. uclear Regulatory Commission (NRC) staff review of the draft Pennsylvania regulations that will be needed to support your request for an Agreement as explained in the letter dated February 24,1999, from Stuart R.

l evin, Chief. Division of Radiation Contro!. The review covefed the draft regulations in Title 25, Environmental Protection, Chapters 215-232, dated December 3,1998 and November 12, 1998, the final regulations in Chapters 215-219, Volume 1, ecember 1998; Chapter 220, October 17,1998; Chapters 221-230, Volume 2, Decembe 1998; and the final regulations in Chapters 236 (November 23,1996) and 237 (December 2 ,1996). The review also covered the supplement regarding Section 217.200 dated March 9 999. The draft and final regulations were reviewed by comparison to the equivalen NRC regulations in 10 CFR Parts 19,20,30,31,32,33,34,35,36,39,40,61,70,71 and 1 0. We also reviewed the responses to our letter dated July 30,1998, that are attached to Mr. evin's letter.

As a result of our review, we have four comments that ar identified in the enclosure. The comments must be addressed to meet the compatibility nd health and safety categories as indicated in the OSP Procedure SA 200, Compatibifity c teoories and Health and Safetv identification for NRC Reautations and Other Prooram Elements.

The review followed the standard procedure as outline in OSP Procedure SA 201, Beview of State Reculations (November 10,1998). We request at when the proposed regulations are published for public comment, a copy of the "as publis ed" regulations be provided to us for review. As requested in OSP Procedure SA-201, pie e highlight any changes and send one copy in a computer readable format, if possible.

If you have any questions regarding the comments, t e compatibility and health and safety categories, or any of the NRC regulations needed fo compatibility and health and safety, please contact me or Dr. Stephen N. Salomon of my staff at (301) 415 2368 or ,

E-mail: SNS @ NRC. GOV.

incerely, Paul H. Lohaus, Director Office of State Progra ns

Enclosure:

As stated Distribution:

DlR RF (9-42) RBlanton DCD (SP05)

SDroggitis JKennedy, LLDR PDR (YES_f._ NO i SMoore, IMNS GKim, OGC Pennsylvania File BUsilton DOCUMENT NAME: G:\SNS\ALLARD.WPD r , . . w ,m w. e w um.nt,ine ui.in u w c . c m . m .neevn.nv.ncinu. e . cc -m .wnm.nv.nci .u,. v . No coDY OFFICE OSP G D IB OSP:D, , l .cl RI:RA l NMSS:1) l OGC l NAME SSalomon:n'b:kk:nb PHLohaushN ict EMiller 9//6 CPaperielic , FCameron DATE 03/N/99 03/d /99W j 03/ /00 03/ 199 03/ /99 y//y/7<7 7SP FILE CODE: SP NA-17 40 40*d 695 4CC 019 Od DOM i "idlEn r t':60 6661-t T-dW

F.. +. i i

Mr. David J. Allard, Director

~

Bureau of Radiation Protection /

Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 -

Dear Mr. Allard:

The purpose of this letter is to provide the results of the U.S' Nuclear Regulatory Commission (NRC) staff review of the draft Pennsylvania regulations that will be needed to support your request for an Agreement as explained in the letter dated February 24,1999, from Stuart R.

Levin, Chief, Division of Radiation Control. The review coyered the draft regulations in Title 25, Environmental Protection, Chapters 215-232, dated Dec ber 3,1998 and November 12, 1998, the final regulations in Chapters 215-219, Volume , December 1998; Chapter 220, '

October 17,1998; Chapters 221-230, Volume 2, Decem r 1998; and the final regulations in Chapters 236 (November 23,1996) and 237 (December'21,1996). The review also covered the supplement regarding Section 217.200 dated Marck9,1999. The draft and final regulations were reviewed by comparison to the equivalent NRC regulations in 10 CFR Parts 19,20,30,31,32,33,34,35,36,39,40,61,70,71 aryd 150. We also reviewed the responses to our letter dated July 30,1998, that are attached to Mr. Levin's letter.

As a result of our review, we have four comments th are identified in the enclosure. The comments must be addressed to meet the compatibility and health and safety categories as indicated in the OSP Procedure SA-200, Comoatibitiv Cateoories and Health and Safety identification for NRC Reaulations and Other Proaram Elemen.lg.

The review followed the standard procedure as o ined in OSP Procedure SA-201, Review of State Regulations (November 10,1998). We requ'est that when the proposed regulations are

published for public comment, a copy of the "as published" regulations be provided to us for l

review. As requested in OSP Procedure SA-201/ please highlight any changes and send one I

copy in a computer readable format, if possible.I If you have any questions regarding the comments, the compatibility and health and safety categories, or any of the NRC regulations needed for compatibility and health and safety, please contact me or Dr. Stephen N. Salomonlof my staff at (301) 415-2368 or E-mail: SNSONRC. GOV.

f Sincerely, Paul H. Lohaus, Director Office of State Programs

Enclosure:

' As stated Distnbution:

DlR RF (9-42) RBlanton DCD (SP05) l SDroggitis JKennedy,,LLDR ' PDR (YES_f._ NO )

SMoore, IMNS GKim, OGC

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, DATE SSalomon:nb:kk:nb 03/W99 PHLohaus hiPiri 03/d /99W HMiller 03/ /99 CPaperiello 03/ /99 IECamesen- % i 03/ /e; 7' q'

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Mr. David J. Allard, Director i Bureau of Radiation Protection l Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469

Dear Mr. Allard:

The purpose of this letter is to provide the results of the U.S Nuclear Regulatory Commission (NRC) staff review of the draft Pennsylvania regulations th will be needed to support your l request for an Agreement as explained in the letter dated bruary 24,1999, from Stuart R.

Levin, Chief Division of Radiation Control. The review co red the draft regulations in Title 25, Environmental Protection, Chapters 215-232, dated Dece ber 3,1998 and November 12,  ;

1998, the final regulations in Chapters 215-219, Volume 1, December 1998; Chapter 220,  !

October 17,1998; Chapters 221 230, Volume 2, Decem r 1998; and the final regulations in l Chapters 236 (November 23,1996) and 237 (December 1,1996). The review also covered j the supplement regarding Section 217.200 dated March ,1999. The draft and final regulations were reviewed by comparison to the equival nt NRC regulations in 10 CFR Parts 19,20,30,31,32,33,34,35,36,39,40,61,70,71 an l 150. We also reviewed the responses to our letter dated July 30,1998, that are attached to N . Levin's letter.

As a result of our review, we have four comments tha are identified in the enclosure. The comments must be addressed to meet the compatibil' and health and safety categories as  ;

indicated in the OSP Procedure SA-200, Comoatibili Cateoories and Health and Safetv Identification for NRC Raoulations and Other Prooraib Elements.

The review followed the standard procedure as outi ed in OSP Procedure SA-201, Review of State Regulations (November 10,1998). We requ t that when the proposed regulations are published for public comment, a copy of the "as pu lished" regulations be provided to us for review. As requested in OSP Procedure SA 201, please highlight any changes and send one copy in a computer readable format, if possible.

If you have any questions regarding the commen s, the compatibility and health and safety l categories, or any of the NRC regulations noe for compatibility and health and safety, please contact me or Dr. Stephen N. Salomon o my staff at (301) 415-2368 or ,

E-mail: SNS ONRC. GOV.

Sincerely, l Paul H. Lohaus, Director Office of State Programs

Enclosure:

1 As stated Distnbution:  :

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