ML20216D132
| ML20216D132 | |
| Person / Time | |
|---|---|
| Issue date: | 11/29/1995 |
| From: | Bangart R NRC |
| To: | Trottier C NRC |
| Shared Package | |
| ML20216C659 | List: |
| References | |
| FRN-61FR24669, RULE-PR-20, RULE-PR-30, RULE-PR-40, RULE-PR-61, RULE-PR-70, RULE-PR-72 AF17-2-019, AF17-2-19, NUDOCS 9709090221 | |
| Download: ML20216D132 (2) | |
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'PDIL From Richard Bangart To CAT 1 Date: 11/29/95 3:12pm
Subject:
RECORDKEEPING RULE CONCURRENCE cheryl, OSP concurs with these additional comments. If you don't agree with the comments, please contact us to discuss.
- 1.Section II.1., Last Para.: Thc second sentence states that
"...these are the on.y records that need to be provided to the NRC at license termination," referring to decommissioning records and records of offsite releases and waste disposals. Literally, this sentence is incorrect, since the revised rule indicates only records of offsite releases and waste disposal need to be provided to NRC at f dcE license termination.
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- 2. From a national materials program consistency viewpoint, it's difficult to justify a Division 3 compatibility level for the requirement to have certain records tramnsferred to NRC at time of license termination. If NRC needs to retain these records indefinitely, why would not an Agreement Stato need to retain its equivalent records? Actually, the Division 3 designation is a concession to the reality that individual States may have administrative procedures or statutes that preclude indefinite retention of such records. So, to address this issue, I recommend the following text replace the current last sentence of the 2nd paragraph of Section III, Agreiment State Compatibility:
Under this level of compatibility the Agreement States will have'" N the option to adopt similar requirements regarding final )
disposition of the records, but will not be required to adopt such requirements. While NRC believes retention of these records will aid in the resolution of potential safety concerns that may be identified after license termination, it also recognizes that an Agreement State without an equivalent requirement for record retention has the ability to resolve potential future safety concerns. This can be achieved by conducting radiological surveys at the formerly licensed site. Without the records, these surveys may need to be greater in number and may be more costly, but the absence of retained records will not preclude an Agreement State from adequately assessing future f' safety concerns.
- 3. Section V., 2nd Para.: This paragraph states the public reporting s burden is estimated to average 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per response. The Response in gp ,
Section II. 2. identifies a reporting burden of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per licensee submittal. If these two statements are indeed referring to the same burden, the estimates need to be reconciled. f['>3
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9709090221 970904 PDR PR 20,q1FR24669 PDR
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