ML20247K202
| ML20247K202 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/1998 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Cooper V KANSAS, STATE OF |
| Shared Package | |
| ML20247K206 | List: |
| References | |
| NUDOCS 9805220039 | |
| Download: ML20247K202 (5) | |
Text
,
.. t Mr. Vick L. Cooper, Chief ' I~ D Radiation Control Program Kansas Department of Health and Environment l
i Bureau of Air and Radiation Forbec Field, Building 283 l Topeka, KS 66620
Dear Mr. Cooper:
)
Thank you for your letter of March 6,1998, responding to our review of the final Kansas !
10 CFR Part 20 equivalent regulation. We appreciate the actions you are taking to address our comments and ask that you provide us an opportunity to review any proposed and final changes that are made to your regulations. As requested in All Agreement States Letter SP-96-027,"Recuest to Hiahlight Changes to Agreement State Regulations Submitted to NRC for Compatibility Review"(March 1,1996), please highlight the changes in the regulations and send one copy in a computer readable format, if possible.
In your letter of March 6,1998, you agreed with our finding that the equivalent section to 10 CFR 20.2006 and Suggested State Regulations Section D.1006 " Transfer for Disposal and 4 Manifests" was omitted. We agree with you that the requirements of Appendix D are clearly spelleo out in KRPR 28-35-231b. Appendix D is the State equivalent of Appendix F of 10 CFR Part 20. (See p. 261, Volume ll, Oak Ridge National Laboratory (ORNL) report cited in our December 30,1997, letter.) However,10 CFR 20.2006 gives the rationale for the requirements, i.e., to control transfers of low-level radioactive waste (LLW) intended for disposal at a licensed LLW disposal facility, establish a manifest tracking system, and supplement existing requirements concerning transfers and recordkeeping for those wastes. In addition, both 10 CFR 20.2006 and Appendix F are compatibility category B program elements with significant direct transboundary implications and both should be included in order to ensure uniformity in these requirements from State to State and avoid confusion for licensees operating from jurisdiction to jurisdiction.
Our recommendation is that Kansas should include an equivalent to 10 CFR 20.2006 and substitute Appendix G to 10 CFR Part 20 for KRPR 28-35-231b when it adopts the new " Low-Level Waste Shipment Manifest Information and Reporting" requirement (60 FR 15649: 60 FR 25983) that has an effective dated of March 1,1998.
If you have any questions, please contact me or Dr. Stephen N. Salomon at (301) 415-2368 or E-mail SNS@NRC. GOV. ,
Signed By:
Sincerely, @PAULH.LOHAUS
)
9905220039 900501 Paul H. Lohaus, Deputy Director PDR STPRC ESOK Oke d StMe Pmm Distribution: \
DlR RF (DS-109) DCD (SP08) \
SDroggitis BUsilton PDR (YES_f._ NO )
CMaupin i LBolling, ASPO Kansas File P 23 O ad7 WMpy Part 20 File -
P $ __o DOCUMENT NAME: G:\SNS\ KANSAS 2.SNS Tv receive a cop i of this document. Indicate in the box: "C" s Copy without attachment /enetosure "E" = Cop r with attachment /enctoppre "N"
- No copy OFFICE OSPcC)$ l OSP:DD l OGC OSP b NAME SSalomon:nb PHLohaus FCameron , RLBangid1P DATE 04/20/98* 04/20/98* 04Qr)lf98" 030l/98 gggg , ! 11O u 8 '
OSP FILE CODE: SP-AG-10; SP-P-1 L J
Mr. Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment ,
Bureau of Air and Radiation !
Forbes Field, Building 283 Topeka, KS 66620
Dear Mr. Cooper:
Thank you for your letter of March 6,1998, responding to o r review of the final Kansas 10 CFR Part 20 equivalent regulation. We appreciate the tions you are taking to address I our comments and ask that you provide us an opportunity o review any proposed and final !
in All Agreement States Letter l changes that are SP-96-027, "Recuest made to to Hiahlight your toregulations.
Changes Agreemen As requestegt State Regulations Sl for Compatibility Review"(March 1,1996), please highli t the changes in the regulations and send one copy in a computer readable format, if possi in your letter of March 6,1998, you agreed with our fi ing that the equivalent section to 10 CFR 20.2006 and Suggested State Regulations S ction D.1006 " Transfer for Disposal and Manifests" was omitted. We agree with you that the requirements of Appendix D are clearly spelled out in KRPR 28-35-231b. Appendix D is th State equivalent of Appendix F of 10 CFR Part 20. (See p. 261, Volume 11, Oak Ridge Natio al Laboratory (ORNL) report cited in our December 30,1997, letter.) However,10 CFR 20 006 gives the rationale for the requirements, i.e., to control transfers of low-levelj adioactive waste (LLW) intended for disposal at a licensed LLW disposal facility, establish a manifest tracking system, and supplement existing requirements concerning transfers and recordkeeping for those wastes. In addition, both 10 CFR 20.D06 and Appendix F are compatibility category B program elements with significant direct trar.sboundary implications and should be included in order to ensure uniformity in these requirements from State toState and avoid confusion because of lack of uniformity.
Our recommendation is that Kansas should nelude an equivalent to 10 CFR 20.2006 and substitute Appendix G to 10 CFR Part 20 for KRPR 28-35-231b when it adopts the new " Low-Level Waste Shipment Manifest information and Reporting" requirement (60 FR 15649: 60 FR 25983) that has an effec */e dated of Mar h 1,1998, if you have any questions, please contact me or Dr. Stephen N. Salomon at (301) 415-2368 or E-mail SNS@NRC. GOV.
Sincerely, Paul H. Lohaus, Deputy Director Office of State Programs Distribution:
SDroggitis BUsflton PDR (YES f _, NO )
CMaupin LBolling, ASPO Ka/sas File Part 20 File DOCUMENT NAME: G:\SNS\ KANSAS 2.SNS [
Ta receive a cop f of this document, Indicate in the box: "C"/= Copy without attachmentleresp. are "Ef" Cop r with attachment / enclosure "N" = No copy OFFICE OSP l OSP:DD l 6 ODC OSP:D l l NAME SSalomon:nb PHLohaus FCameron RLBangart DATE 04/20/98* / 04/20/98* 04/)fj/98 04/ /98 OSP FILE CODE: SP-AG-10; SP-P-1
Mr. Vick L. Cooper, Chief ,
Radiation Control Program '
Kansas Department of Health and Environment l Bureau of Air and Radiation Forbes Field, Building 283 l Topeka,KS 66620
Dear Mr. Cooper:
1 Thank you for your letter of March 6,1998, responding to our review of the fin i Kansas 10 CFR Part 20 equivalent regulation. We appreciate the actions you are ta ing to address our comments and ask that you provide us an opportunity to review any prpposed and final changes that are made to your regulations. As requested in All Agreemefit States Letter SP-96-027, "Recuest to Hiahlight Changes to Acreement State Regulatbns Submitted to NRC for Compatibility Review" (March 1,1996), please highlight the chang in the regulations and send one copy in a computer readable format, if possible.
I in your letter of March 6,1998, you agreed with our finding that t equivalent section to 10 l CFR 20.2006 and Suggested State Regulations Section D.1009 Transfer for Disposal and ]
Manifests" was omitted. We agree with you that the requirements of Appendix D are clearly spelled out in KRPR 28-35-231b. Appendix D is the State egbivalent of Appendix F of 10 CFR ,
Part 20. (See p. 261, Volume ll, Oak Ridge Nations! Labo/atory (ORNL) report cited in our j December 30,1997, letter.) Nevertheless, both 10 CFR compatibility category B program elements with t directsignifican,20.2006 transboundary implications and Appendix F and should be included.
Our recommendation is that Kansas should include j n equivalent to 10 CFR 20.2006 and Appendix G when it adopts the new " Low-Level Vyaste Shipment Manifest Information and Reporting" requirement (60 FR 15649: 60 FR 2 983) that has an effective dated of March 1, 1998.
If you have any questions, please contact 'e or Dr. Stephen N. Salomon at (301) 415-2368 or E-mail SNS@NRC. GOV.
Sincerely, i 1
l lI Paul H. Lohaus, Deputy Director Office of State Programs Distribution:
SDroggitis BUsilton PDR (YES NO )
KSchneider CHackney, RIV LBolling Kansas File Part 20 File DOCUMENT NAME: G:\S'NS\ KANSAS 2.SNS Tu receive a copu of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N"
- No copy OFFICE OSP5%)[ OgMD , l OSP:D l l l NAME SSalomon:nb PHL6hWF RLBangart DATE 04rLC/98 04/oT/98 04/ /98 OSP FILE CODE: SP-AG-10; SP-P-1
W ar y t UNITED STATES g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. ma aaa1
\.,,,,l& May 1, 1998 Mr. Vick L Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation Forbes Field, Building 283 Topeka, KS 66620
Dear Mr. Cooper:
Thank you for your letter of March 6,1998, responding to our review of the final Kansas 10 CFR Part 20 equivalent regulation. We appreciate the actions you are taking to address our comments and ask that you provide us an opportunity to review any proposed and final changes that are made to your regulations. As requested in All Agreement States Letter SP-96-027, "Reauest to Hiahlicht Chances to Aareement State Regulations Submitted to NRC for Compatibility Review"(March 1,1996), please highlight the changes in the regulations and send one copy in a computer readable format, it possible.
In your letter of March 6,1998, you agreed with our finding that the equivalent section to 10 CFR 20.2006 and Suggested State Regulations Section D.1006 " Transfer for Disposal and
. Manifests" was omitted. ' We agree with you that the requirements of Appendix D are clearly spelled out in KRPR 28-35-231b. Appendix D is the State equivalent of Appendix F of 10 CFR Part 20. (See p. 261, Volume 11, Oak Ridge National Leboratory (ORNL) report cited in our December 30,1997, letter.) However,10 CFR 20.2006 gives the rationale for the requirements, i.e., to control transfers of low-level radioactive waste (LLW) intended for disposal at a licensed LLW disposal facility, establish a manifest tracking system, and supplement l existing requirements conceming transfers and recordkeeping for those wastes. In addition, both 10 CFR 20.2006 and Appendix F are compatibility category B program elements with significant direct transboundaly implications and both should be included in order to ensure uniformity in these requirements from State to State and avoid confusion for licensees operating from jurisdiction to jurisdiction.
Our recommendation is that Kansas should include an eaulvalent to 10 CFR 20.2006 and substitute Appendix G to 10 CFR Part 20 for KRPR 28-35-231b when it adopts the new " Low-Level Waste Shipment Manifest Information and Reporting" requirement (60 FR 15649: 60 FR 25983) that has an effective dated of March 1,1998.
If you have any questions, please contact me or Dr. Stephen N. Salomon at (301) 415-2368 or E-mail SNS@NRC. GOV.
erely, 3
l -
1 au H. Lohaus, Deputy Director Office of State Programs W \
N
! EXECUTIVE TASK MANAGEMENT SYSTEM
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TASK # - 8S109 ,, , DATE- 04/07/98
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1998 TASK STARTED - 04/07/98
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TASK DESCRIPTION - LTR. TO P. LOHAUS FROM V. COOPER REGARDING ANOTHER
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OFF. - KS REQUESTER - COOPER WITS - 0 FYP - N
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STATUS - OSP DUE DATE: 4/30/98 PLANNED ACC. -N LEVEL CODE - 1
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