ML20249B543
| ML20249B543 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1998 |
| From: | Combs F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kathy Weaver COLORADO, STATE OF |
| References | |
| NUDOCS 9806230287 | |
| Download: ML20249B543 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION C
WASH'NGTON, D.C. 20555 4001
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June 17, 1998 Mr. Ken 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 March 3,1998, " draft Part M - Licensing Requirements for Radioactive Waste Management for Disposal," we have reviewed draft Part M and provide the following comments.
Sec. M2 - Definitions.
Confusion still exists with the definition of " land disposal facility" in Part M. The Rationale for Revision states that a clarification was made by NRC effective July 22,1993, which is required for purposes of compatibility of Agreement State programs with the NRC. The Rationale also indicates that regulatory change was made to Part M; however, the definition of " land disposal facility" in Part M does not incorporate the changes made to the 10 CFR 61. 2 definition for
" land disposal facility," which allows for disposal above ground.
The definition should indicate that low-level radioactive waste facilities apply to disposal in above-ground facilities and should read:
Land disposal facility means the land, buildings and structures, and equipment which are intended to be used for the disposal of radioactive wastes. For purposes of this chapter, a " geologic repository" is not considered a " land disposal facility."
This definition would then include engineered structures such as vaults and bunkers, above the surface. The present definition in Part M indicates that the disposal of waste is into the subsurface of the land.
Sec. M.10 - Protection of the General Pooulation from Releases of Radioactivity.
The standards for issuing a license for land disposal of radioactive material must be adequate to provide assurance that the standards of radiation protection set out in 10 CFR Part 20 are met. The Suggested State Regulations (SSR) use terms as " dose equivalent to the whole body"; 10 CFR Part 20 uses the " Total Effective Dose Equivalent" (TEDE). The SSR should consider keeping definitions and limits closer to the definitions that are in the Federal l
regulations to avoid confusion in regulation compatibility.
50
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Ken W2 aver 0 Sec. M25 - Land Disposal Facility Ooeration and Disoosal Site Closure.
4 This section does not reference the minimum requirements for waste characteristics as in 10 CFR 61.56 (a). Furthermore, this section does not reference the labeling requirements as in 10 CFR 61.57.
Sec. M33 - Maintenance of records. Reoorts. and ' Transfers.
Title 10 CFR 61.80 (c) states "... The record may also be stored in electronic media with the capability for producing legible, accurate, and complete records during the required retention period..." Further, Title 10 CFR 61.80 (c) states "... Records such as letters, drawings, specifications, must include all pertinent information such as stamps, initials, and signatures.
The licensee shall maintair, adequate safeguards against tampering with and loss of records."
The committee should consider the inclusion of these statements in Section M33.
In an April 3' 0,1998, letter to you, Dr. Donald Cool provided comments on Draft O " Licensing Requirment for Decommissioning." in addition to those previous comments, we offer the following:
Sec. O.14 - Vacatina Premises.
The section states "Each licensee, or person possessing non-exempt sources of radiation shall,
' no less than 30 days before vacating or relinquishing possession or control of premises which may have been contaminated with radioactive material as a result of his activity, notify the agency, in writing, of the intent to vacate. When deemed necessary by the Agency, the licensee, registrant, or person possessing non-exempt sources of radiation shall decontaminate i
the premises in such a manner that the annual total effective dose equivalent (TEDE) to any individual after the site is released for unrestricted use should not exceed ten millirem above background and that the annual TEDE from any specific environmental source during decommissioning activities not exceed ten millirem above background." This section appears to contradict Sec. O.9 - License Termination of Licenses Without Restriction and Sec. O.10 -
License Termination Under Restricted Conditions.
Sincerely,
)
Frederick C. Combs, Acting Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards cc. Paul Lohaus, OSP DISTRIBUTION: IMNS-7027 NRC Central File IMNS r/f NMSS r/f PDR:YES X NO DOCUMENT NAME:
c:simns7027.gwp
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To receive a copy of this document, indicate in the bor i
"C"a Copy w/o att/ encl. "E" = Co py w/att/enets"N" = No copy *See previous concurrence OFC OB OB IMNS NAME GPurdy/II SMoore FCombs DATE
' 6/10/1998 6/
/1998 6/
/1998 OFFICIAL RECORD COPY l
Ken Wrver
-23une17,1998 a..
Sec. M25 - Land Disoosal Facility Ooeration and Discosal Site Closure.
This section does not reference the minimum requirements for waste characteristics as in 10 CFR 61.56 (a). Furthermore, this section does not reference the labeling requirements as in 10 CFR 61.57. A reference to the equivalent SSRs should be included in this section for clarification.
Sec. M33 - Maintenance of records. Reoorts. and Transfers.
Title 10 CFR 61.80 (c) states "... The record may also be stored in electronic media with the capability for producing legible, accurate, and complete records during the required retention period..." Further,10 CFR 61.80 (c) states "... Records such as letters, drawings, specifications, must include all pertinent information such as stamps, initials, and signatures.
The licensee shall maintain adequate safeguards against tampering with and loss of records."
The committee should consider the inclusion of these statements in Section M33.
In an April 30,1998, letter to you, Dr. Donald Cool provided comments on Draft O " Licensing Requirement for Decommissioning." In addition to those previous comments, we offer the following:
Sec. O.14 - Vacatina Premises.
The section states "Each licensee, or person possessing non-exempt sources of radiation shall, no less than 30 days before vacating or relinquishing possession or control of premises which may have been contaminated with radioactive material as a result of his activity, notify the agency, in writing, of the intent to vacate. When deemed necessary by the Agency, the licensee, registrant, or person possessing non-exempt sources of radiation shall decontaminate the premises in such a manner that the annual total effective dose equivalent (TEDE) to any individual after the site is released for unrestricted use should not exceed ten millirem above background and that the anr ual TEDE from any specific environmental source during decommissioning activities not exceed ten millirem above background." This section appears to contradict Sec. O.9 - License Termination of Licenses Without Restriction and Sec. O.10 -
License Termination Under Restricted Conditions.
Sincerely, Original signed by Fred Combs Freoerick C. Combs, Acting Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards cc. Paul Lohaus, OSP i
DISTRIBtITION: IMNS-7027 I
NRC Central File IMNS r/f NMSS r/f PDR: YES X NO DOCUMENT NAME:
ommns7027.gwp To receive a copy of this document, indicate in the box; "C"= Copy w/o att/enci *E" = Co py w/att/ encl.*N" = No copy *See previous concurrence 4/W/f f dG OFC OB Cbj CthlN l
Jaw n
>g NAME GPurdy/II*
S Woore i F, rnbs
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DATE 6/12/1998 6/1 9-/1998 hh/1998 OFFICIAL RECORD COPY
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