ML20211G188

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Informs That Which Transmitted Comments on Rev to MD 5.6, Integrated Matl Performance Evaluation Program, Was Not Included in Final MD 5.6.Comments Were Requested by 970827 to Meet Commission Due Date.Comments Received 970829
ML20211G188
Person / Time
Issue date: 09/26/1997
From: Lohaus P
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Pearson D
TEXAS, STATE OF
References
SP-97-053, SP-97-53, NUDOCS 9710020142
Download: ML20211G188 (3)
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Text

. .-

l SEP 2 61997 t

Mr. Dan Pearson Executive Director Texas Natural Resource Conservation Commission.

P.O. Box 13087 Austin, TX 78711-3087

Dear Mr. Pearson:

This is in reference to your August 29,1997 letter with comments ori the revision to Management Directive 5.6 (MD 5.6), " Integrated Materials Performance Evaluation Program." We appreciate receiving your comments. We were not able to include your comments in our analysis and final MD 5.6. As we stated in our All Agreement States Letter, SP 97 053, we needed comments by August 27,1997 to meet a Commission assigned due date of August 29,1997 to prepare MD 5.6 in final. Your comments were received by fax on August 29,1997. Upon receipt of your comments, our finalization of

< MD 5.6 had been completed.

However, we will consider your comments during our next revision to MD 5.6. If you have any questions please contact me at 301415 2316 or Kathleen Schneider at 301-415 2320.

Sincerely,

[AI2 /4 9710020142 770926 - Paul H. Lohaus, Deputy Director PDR STPRG ESGT Office of State Programs ppg cc: Alice Hamilton Rogers Section Manager, UIC/RWS/TNRCC

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SDroggitis PDR (YES)

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- DOCUMENT NAME: G:\KXS\PEARSON.KNS Ta r.c*. . ..py ., thi. e.a u nt inec.t. m th. boa: c = copy without attachm.nt/.ncio.u,A "E" = Copy with attachm.nt/.nclosur. 'N' = No copy l OFFICE OSP l MSf:DDL OSP:D{[Q l l lNAME KNSchneider:kk:gd PfiLohaus ~ RLBangartiN lDATE 09/22/97 *  ; 09/p(j97 09phf97

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Ms. Alice Hamilton Rogers Section Manager ,,

UIC, Uranium and Radioactive /

Waste Section Texas Natural Resource Conservation Commission /

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P. O. BOX 13087 -

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Austin, TX 78711 3087 j

Dear Ms. Rogers:

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This is in referer.ce to your August 29,1997 letter with corn $ents on the revision to Manacement Directive 5.6 (MD 5.6), " Integrated Materials' Performance Evaluation Program." We appreciate receiving your comments, however, as we stated in our All Agreement States Letter, SP 97-053, we needed corpments by August 27,1997 to meet a Commission assigned due date of August 29,1997 ~to prepare MD 5.6 in final. We were not able to include your cornments in our analysis'and final MD 5.6.

However, we will consider your comments duffng cur next revision to MD 5.6. If you have -

any questions please contact me at 301-315-3340 or Kathleen Schneider at 301-415 2320.

Sincerely

/-

Richard L. Bangart, Diractor Office of State Programs

/

/

Distrib tion:

DIF RF DCD (SP08)

' S,D}roggitis PDR (YES)

Management Directives File ITexas File DOCUMENT NAME: G:\KXS\ ROGERS.KNS To receive e copy of this document, Indicate in the bos: "C' = Copy without attachment / enclosure 'E" = Copy with attachment / enclosure 'N' = No copy OFFICE OSP ,,q Ogg OSP:D NAME KNSchneider:kk PHL h7 RLBangart DATE 09/h/97 6 7- 09/ /97 OSP FILE CODE: SP-M-1, SP-AG-27

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,y t UNITED STATES s* g NUCLEAR REGULATORY COMMISSION

  1. WASHINGTON. D.C. 300SH001 4

\, , , , , , */ September 26, 1997 Mr. Dan Pearson Executive Director Texas Natural Resource Conservation Commission P.O. Box 13087 Austin, TX 78711 3087

Dear Mr. Pearson:

This is in reference to your August 29,1997 letter with comments on the revision tc Management Directive 5.6 (MD 5.6), " Integrated Materials Performance Evaluation

' Program." We appreciate receiving ycur comments. We were not able to include your comments in our analysis and final MD 5.6. As we stated in our All Agreement States Letter, SP-97-053, we needed comments by August 27,1997 to meet a Commission assigned due date of August 29,1997 to prepare MD 5.6 in final.- Your comments were received by fax on August 29,1997. Upon receipt of your comments, our finalization of MD 5.6 had been completed.

However, we will consider your comments during our next revision to MD 5.6. If you have any questions please contact me at 301-415 2316 or Kathleen Schneider a';

301-415-2320.

i Sincerely,

$Y& ba hh Paul H. Lohaus, Deputy Director Office of State Programs cc: Alice Hamilton Rogers Section Manager, UIC/RWS/TNRCC

  • . 62./29.97 16:26 0 612 239 6362 TNRCC tit 1RTS @uu2 Barry R, Mt Bee, Chairman R. R.
  • Ralph
  • Marques. Commissioner N q 4-buhn H. Bsksr,Comminioner  ?

Den tsatsm 8tneutiw Director _,,,,

TEXAS NATURAL RESOURCE CONSERVATION COMMISSION l'rvtecting Texa by haducinn endhewsting IWlution August 29,1997 Mr. Paul 11. Lohaus, Deputy Director Ofuce of State Programs US Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Revisions to Managem nt Directive 5.6 (SP.97-053)

Dear Mr. Lohaus:

This letter is wntten in response to your July 19,1997 request for conynents on the US Nuclear Regulatory Commission's (NRC's) draft revisior.3 to Management Directive 5.6, Integrated Materials Performance Evaluation Program (IMPEP)" The Texas Natural Resource Conservation Conunission (TNRCC), the state agency in Texas charged with reEulatmg disposal of low level radioactive waste, hereby submits the following comments:

Part I(A) Evaluntion Frecuency; With regard to the review of states with low-level radioactive waste disposal projects, we suggest the NRC consider tinung its IMPEP review so that a review is conducted during the techrucal review phase of an application. Since the application review period of a low-level radioactive waste disposal project is 15 months, the NRC could easily miss a low-level radioactive waste disposal Agreement State during this period ifit strictly adheres to its stated 1 IMPEP every 4 years schedule.

Part 11 Performance Indienters; Performance Indiator 1 - Low-1,evel Radioactivt.Wfstdimnul Proenan. Element 1 The NRC states that "There must be a capability for maintammg and retrieving statistietd data on the status of the inspection program for the low level radioactive waste disposal program". If the NRC is referring to an electronically retrievable database, the NRC should so state.

Performance 'ndientor 3 t ow f.evelRndinnetive Wuste Dis 20talPromm. Element 2: The NRC states that "The review teams will conduct indepth (sic), onsite reviews of completed inspection reports." It is unclear whether on-site refers to at the disposal facility or at the Agreement State's public records room. We recommend the in-depth review be conducted at $c Agirement State's public records room. The Agreement State most likely will not have the capaollity to store its ugency documents at a disposal facility owned by another entity.

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.P.O. Boa 13087

  • Austin. Tuas 75711 3087 * $12/2391000
  • Internet address; www.tnrec. state.tx.us n.u..o. ..u o.4 . .. .# ..

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Mr. Paul II. Lobaus

^ Page 2 August 29,1997 Pednrmance tnd: cent 3 1 ow-t rvel Radioactive Waste Dispnmal Pmmm. Element 3: The NRC could gr%tly help the Agreement St:tes by pmviding NRC paid training (and travel) specific to low-level radioactive waste disposal. Also, the NRC states "Esaluation of staffing and training should bc conducted in the same manner and as pan of the common performance indicator, Technical StatTmg and Training, pangraph (B)(3)(a), (b), (c) and (d) (unless the Low-1.evel Radioactive Waste Program is organizationally separate from the matedals progmm)." It is unclear from this sentence how a program that is organizationally separate would be evaluatet'.

Perfommnce Indicator 3 - Low-LevelRadinnetive Waste Dinnoul Procrant inement 4: The NRC states that " Technical quality includes not only the review of completed actions, but also an examination of any ongoing requests for licenses or renewa]s that may have health and safety implications." We recommend license amendments be included in this sentence, htigrmance Indicatnr 3 - Low. Level Rndinnetive Wage Disnnul Pmeram Flement 5: neNRC states " Reviews oflow-level radioactive waste program incidents and allegations of safety contems should be conducted in the same manner and as part of the common performance indicator, Response to incidents and Allegations (unless the Low Level Radioactive Waste Program is o;ganizationally separate fro.n the matenals program)." It is unclear from this sentence how a program that f. organizationally separate would be evaluated.

We thank you for the opportunity to conunent on these revisions, if you have any questions regarding this mntter, please contact Ms. Alice Hamilton Rogers, P.E., Manager of the Underground Injection Control and Radioactive Waste Section at (512) 239 6846.

S cerely, S _

Pears becutive irector DP/AHR/lg cc: Ms. Alice Hamilton Rogers C.\FitL%wrWJCEMPcP.CoM I

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