ML20211N151
| ML20211N151 | |
| Person / Time | |
|---|---|
| Issue date: | 08/17/1999 |
| From: | Salomon S NRC |
| To: | Woodruff R NRC |
| Shared Package | |
| ML20211N144 | List: |
| References | |
| NUDOCS 9909100084 | |
| Download: ML20211N151 (2) | |
Text
[ Stephen Salomon 'Rf R; vised SC letter re r; view of fin:1 regs Paga 1]
., =* ,
From: Richard 5/!oodruff To: Stephen Salomon
. Date: Tue, Aug 17,199910:15 AM J
Subject:
Re: Revised SC letter re review of final regs i
Good moming Steve! The " manifest" reg file is attached, hope it omes through this time. )
The Transportation regs (RHA 2.22) are written in a generic fashion and do not have specific dates in the !
body of the rule. I don't know when they were promulgated or revised last, but I do know that they were promulgated prior the the last September 1998 revision. . The Attorney Generats opinion was dated February 12,1999.
n> Stephen Salomon 08/16 3:13 PM >n Dick, I did not receive an attachment. Somehow, it dropped off. Please send. WWt is the effective date of the incorporation by reference for Part 717 Steve l n> Richard Woodruff 08/16 2:42 PM >n l Sorry about that Steve, I thought the LLRW and manifest was sent along with the others. I have attached the file with this reply.
With regard to Part 71, South Carolina has adopted NRC Part 71 and DOT and U.S. Postal regulations by reference, and I did verify that SC had an attomey generats opinion regarding their legality and enforceability on file. These provisions are covered in RHA 2.22, " Transportation of Radioactive i Material." Because of this, I did not believe it necessary to provide a detailed line by line analysis of the I SC transportation regulations.
n> Stephen Salomon 08/12 3:19 PM >n Dick, -
I worked real hard to include everything. Hope you can find the SC regs in paragraph #2 for RATS 1995-3 corresponding to the LLW manifests; and RATS 1996-1 corresponding to the IAEA Part 71. They are not in your tables.
Let me know what you think now.
1 I bet you brought back a load from TN. I Steve i
i 9909100084 990825 PDR STPRC ESCSC PDR
f~
TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS
! STATE: SOUTH CAROLINA '
- l. RADIOACTIVE MATERIAL REGULATIONS 61-63, TITLE A
!. NRC REG: LOW-LEVEL WASTE SHIPMENT MANIFEST INFORMATION AND
! REPORTING, PARTS 20 AND 61 (60 FR 15649 AND 60 FR 25983)
EFFECTIVE MARCH 1,1998 STATE REG: TRANSFER FOR DISPOSAL AND MANIFEST, RHA 3.32 APPENDIX D, RHA 3.55, REQUIREMENTS FOR TRANSFERS OF LOW-LEVEL RADIOACTIVE WASTE INTENDED FOR DISPOSAL AT LICENSED LAND DISPOSAL FACILITIES AND MANIFEST l PART Vil, LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE REVIEW DATE: JULY 28,1999 NRC CAT REGULATION STATE COMMENTS REG REG l 20.2006 B Transfer for Disposal and RHA 3.32 Essentially identical Manifest 20.2101 C Subpart L -Records RHA Essential Objectives -
(b) & @ General Provisions 3.34.2 '
(Need SI Units)
Appendix B Requirements for transfers APP.D, Essentially identical !
G of Low-Level Rad Waste RHA 3.55 Intended for Disposal at and Licensed Land Disposal RHA 3.2 !
Facilities and manifests Definitions Part 61, C Records, Reports, Tests, Part Vil, Essential Objectives Subpart and inspections RHA 7.32 G, 61.80, (f), (i), &
(1) 1