ML20246P329
| ML20246P329 | |
| Person / Time | |
|---|---|
| Issue date: | 07/13/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8907200170 | |
| Download: ML20246P329 (4) | |
Text
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M i 3 tDJ Mark L. Matthews, Acting Project Manag:r Uranium Mill Tailings Project Office Albuquerque Operations Office Department of Energy Albuquerque, New Mexico 87115 l~
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Dear Mr. Matthews:
I received your June 27, 1989 letter on draft VPMIM Directives numbers E5, E6 and E7. Our response is delayed, because you sent the transmittal to Dennis Sollenberger, who is no longer associated with the UMTRA review process.
I informed you of this change in our April 14, 1989 letter on the initiation of the VPMIM Directives.
l I must take issue with your statement in the June 27, 1989 transmittal letter, that barring a response within 15 days of your transmittal, DOE can presume to have NRC concurrence with changes to the VPMIM. DOE should not interpret silence, or a possible delayed response, as tacit NRC approval.
NRC has, however, extended a generic concurrence with normal VP cleanup actions in which NRC does not review a specific category of such cleanups.
With respect to your requested 15-day response time, some of our concurrence reviews involve multiple NRC organizations, which would make that review schedule unfeasible. You should also note that this particular transmittal, which was sent by regular mail, took 9 days to reach NRC.
In the future DOE should consider sending all such VPMIM Directives by express mail if rapid response is desired. Furthermore, the TAC " Transmittal of Documents" form was missing from the copy we received, so we are unable to provide an NRC-signed form confirming our receipt.
Please make note in your office procedures that any document, course of action or decision requiring NRC concurrence should be directe to Paul H. Lohaus, unless it relates to a specific site or vicinity prope;, delegated to URF0.
In those cases, you should direct the transmittal to Ramon Hall, who is the Director of URF0.
I have enclosed the subject Directives' response forms, as you requested.
ORIGINAL SIGNE) B Paul H. Lohaus, Ch Ief,YOperations Branch Division of Low Level Waste Management and Decommissioning, NMSS
Enclosures:
As stated cc w/enclos:
R. Hall, URF0; C. Mantelli, JEG; J. Garcia, D0E/AL i
Distribution: Central? File i NMSS SUBJ WM439? NMSS r/f JJones r/f 4
JGreeves, LLWM MBell, LLWM JAustin, LLRB JSurmeier, LLTB PLohaus, LLOB MFliegel, LLOB GGnugnoli, LLOB DGillen, LLOB z
SWastler, LLOB MDunkelman, LLOB TLJohnson, LLOB EHawkins, URF0 8
DJacoby, URF0 VScovill, URF0 RHeyer, URF0 oXk PDR YES /X /
?
co PDR NO
/ / Category: Proprietary / /
or CF Only / /
ota NH ACNW YES /X /
N0 / /
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SUBJECT AB5 TRACT:
ERC Resp _onse..orr@0E VPMIM Directives E5, E6 & E7.
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e RESPONSE TO VPMIM DIRECTIVE #E 5 Date:
July 12, 1989 Comment Orininator: Giorgio Gnugnoli, Project Manager Organization / Telephone Number:
USNRC/NMSS/LLWM/LLOB FTS 492-0578 COMMENTS
- 1. All VPMIM directives should be provided to Paul Lohaus NRC/NMSS/LLWM/LLOB as well as to Ramon Hall NRC/URF0 (Denver Field Office).
- 2. 00E cannot assume tacit NRC agreement or concurrence.
Bypassing NRC-concurrence with significant changes to the VPMIM would seriously jeopardize the NRC generic concurrence on VP cleanup actions following VPMIM procedures.
- 3. In order to expedite the implementation of these directives, 00E should carefully scrutinize'the need fo= NRC concurrence with any'given directive.
- 4. NRC expects responses to significant comments on VPMIM directives regardless of 15-day turnaround period, unless 00E fully addresses the comments in the final version of the directive.
- 5. DOE should also consider using expr ss delivery mail, in light of this e
abbreviated proposed schedule.
- 6. As with directives, these responses to NRC comments should be provided to both Paul Lohaus and Ramon Hall, as well as to the NRC comment or' T ator.
Signature: Giorgio Gnugno11 14 Approvals: Myron Fliegel s
Paul Lohau 4
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PLEASE RETURN WITH " TRANSMITTAL OF DOCUMENT" FORM FOR UMTRA PO USE ONLY
[ ] COMMENTS REVIEWED AND INCORPORATED
[ ] COPNENTS REVIEWED AND NOT INCORPORATED lw ____- _ _ - -
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- RESPONSE TO VPMIM DIRECTIVE #E 6
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Date:
Ju1y 11, 1989 Comment Originator:
Giorgio Gnugnoli, USNRC/NMSS/LLWM/LLOB I
Organization / Telephone Number:
USNRC/NMSS/LLWM/LLOB FTS 492-n57A COMMENTS NRC staff has no objection to the anomally characterization critorinn of 20 % over background.
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RESPONSE TO VPMIM DIRECTIVE #E 7 Date*
July 11, 1989 Comment Originator:
Giorgio Gnugnoli, Project Manager j
Organization / Telephone Number: USNRC/NMSS/LLWM/LLOB FTS 492-0578 COMMENTS 1
NRC staff has no obiection to the clarification on the prohibition of re-averacino once remedial action has becun.
Future references should be explicitiv indicated with respect to the VPMIMr e.g.,
page #, section #,
paracraph #.
etc....
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Approval: Myron Fliege
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PLEASE RETURN WITH " TRANSMITTAL OF DOCUMENT" FORM ]
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FOR UMTRA PO USE ONLY
[ ] COMMENTS REVIEWED AND INCORPORATED g%f
[ ] COMMENTS REVIEWED AND NOT INCORPORATED JAww&/
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