ML20217Q407
| ML20217Q407 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1998 |
| From: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kathy Weaver COLORADO, STATE OF |
| References | |
| NUDOCS 9805080110 | |
| Download: ML20217Q407 (3) | |
Text
g April.30, 1998 Mr. Keii Weaver
- Chairperson, Committee SR-1 Colorado Department of Public
. Health and Environment.
4300 Cherry Creek Drive South Denver, Colorado 80246-1530
Dear Mr. Weaver:
In response to your memorandum dated April 1,-1998, enclosed are the Nuclear Regulatory Commission (NRC) comments on draft Part 0, " Licensing Requirements for -
Decommissioning," of the Conference of Radiation Control Program Directors' Suggested State Regulations. Our review of draft Part O has included considerations of its relationship to decommissioning regulations promulgated by the NRC between 1988 and 1996, as well as to NRC's July 21,1997 rule.
l Sincerely, j
Original Signed by.
j Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety
.)
Office of Nuclear Material Safety and Safeguards t
Enclosure:
' Comments on Draft Part O Distribution:(g:\\cardile\\ weaver.itr) Enterin PDR Yes d Noa PGordon/RF
[ g *gp itRNs/ Control File Nedss R/F.
NRC Centrol File ':
itANs Ticket No. 7008
- see previous concurrence M -b, To receive a cap? or this document, indicate in the box "C* = copy without attachment / enclosure, "B* = copy with attachment / enclosure. T = Im Copy 0FFICE:
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DC DATE:
4/22/98 4/22/98 4/22/98
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Mr. Ken Weaver L
Chairperson, Committee SR-1 Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80246-1530
Dear Mr. Weaver:
In response to your request of April 1,1998, enclosed are NRC comments on draft Part 0,
" Licensing Requirements for Decommissioning," of the Confereace of Radiation Control Program Directors' Suggested State Regulations. Our review of draft Part O has included considerations of its relationship to decommissioning regulations promulgated by the NRC between 1988 and 1996,- as well as to NRC's July 21,1997 rule.
Sincerely, Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
Enclosure:
Comments on Draft Part O Distribution:(g:\\cardile\\ weaver.ltr) Enterin PDR Yes o Noa RGordon/RF IMNs/ Central File NMss R/F NRC Central File IMNs Ticket No. 7008 To receive a enes of tMs document, indicate in the box "C* = copy without attactuwnt/ enclosure. *s' = copy with attactwnt/ enclosure.
"N* = No copy 0FFICE:
RGB/IMNS RG8/lHNS SGB/,IMPJS D/IMNS FCardile"h NNE:
han ne DCool DATE:
4/ W /98 f/ J A /98 h/ M
/98
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/98 0FFICIAL RECORD COPY I
NMSS FILE CODE NO.-
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l Enclosure t
.NRC Comments on Draft Part O
- "Licensina Reauirements for Decommissionina"-
i l
1.
Section O.3 - it is not clear why definitions'of " restricted ama" and " unrestricted arna" l
are included in Part O, which contains requirements that primarily deal with the decommissioning and license termination criteria.' Their inclusion in Part O can cause -
confusion with the terms testricted and unrestricted ".uaa" which are part of the definition "
.of decommissioning. It would seem more appropriate to continue to just include the -
- definitions of restrkted and unrestricted "afna" in Part A of the State regulations as is noted on page 2 of the rationale.
2.
Section O.3 - The section includes a definition of " unrestricted use" but not ora for
" restricted use." It would be useful to define both terms.l The definition of restricted use
- should note that there would be conditions placed on future'use of the site however, as noted in the definition of decommissioning, the license would be terminated and the -
facilities and areas would no longer be under control of the licensee.
3.
Rationale:
Introduction:
5th oara. 7th line - The citation for the ' July 21,1997, final rule
. on radiological criteria for license termination is 62 FR 39068 4.-
Rationale: Section O.2 - The definitions of " decommissioning plan" and " final radiation survey" are not in 10 CFR 20.1003, as is stated in the Rationale. Also the definition of
" principal activity" is from 10 CFR 30.4, not from 10 CFR 20.1003.
5.
Rationale: Sections. ' O.9-0.15 - These sections are somewhat confusing in that, for some sections, it is stated that a certain section " mirrors exactly" a certain NRC.
requirement whereas, for other sections, that statement is not made even though the particular section is also extremely close to the NRC requirement. For example,'it is noted that Sections 0.9(a), 0.10(a), and O.13 " mirror exactly" 10 CFR Parts 20.1402, 11403, and 1406, respectively, but it is not similarly noted that Sections G.9(b), O.10(b),
0.10(d), and 0.15 are the same as NRC's requirements in 10 CFR Parts 30.36(k),
' 20.1403 (b),20.1403(d), and 20.1401(c), respectively.L lt would seem that the references should be consistent.
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