ML21006A409
| ML21006A409 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/2021 |
| From: | Brian Anderson NRC/NMSS/DMSST |
| To: | Semancik J State of CT, Dept of Energy and Environmental Protection |
| Beardsley M | |
| Shared Package | |
| ML20364A217 | List: |
| References | |
| Download: ML21006A409 (19) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 22, 2021 Mr. Jeffrey Semancik Director, Radiation Division Bureau of Air Management Connecticut Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127
Dear Mr. Semancik:
We have reviewed the proposed revisions to the Connecticut legislation in the Agency Legislative Proposal - 2021 Session, received by our office on December 17, 2020. This legislation was reviewed by comparison to the Council of State Governments Suggested State Legislation (SSL), 1983, Volume 42, and NMSS procedure SA-700, Processing an Agreement.
We discussed our review of the legislation with you and members of your staff on January 21, 2021.
As a result of our review, we have 71 comments that have been identified in the enclosure.
If you have any questions regarding the comments, or the State Suggested Legislation used in the review, please contact Michelle Beardsley, State Regulation Review Coordinator, at 301-415-0275 (michelle.beardsley@nrc.gov) or Stephen Poy at 301-415-7135 (stephen.poy@nrc.gov).
Sincerely, Brian C. Digitally signed by Brian C.
Anderson Anderson Date: 2021.01.22 13:11:55
-05'00' Brian C. Anderson, Chief State Agreement and Liaison Programs Branch Division of Materials Safety, Security, State and Tribal Programs Office of Nuclear Material Safety and Safeguards
Enclosures:
- 1. Comment table
- 2. Connecticut SRS Data Sheet
ML20364A217 pkg and Letter ML21006A409 OFFICE SALB SALB OGC SALB:BC NAME SPoy MBeardsley JOlmstead BAnderson DATE 12/31/2020 12/31/20 1/19/21 1/22/21 COMPATIBILITY COMMENTS ON CONNECTICUT PROPOSED LEGISLATION STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION 1 Section 22a- Section 2 Declaration of Policy 5.
Connecticut omits the term sources of ionizing and nonionizing Section 22a- radiation 148 et seq.
Connecticut needs to delete the delete the phrase as nearly as 16a-100 may be, from Section 16a-100.and to the extent deemed practicable by said department from 22a-148(b). Connecticut 22a-161 for also needs to change the sentence on the regulations of the LLRW United States Atomic Energy Commission to the United States Atlantic Nuclear Energy Commission, issued under authority granted to Compact said commission by the Atomic Energy Act of 1954, and subsequent amendments. Connecticut also needs to delete the later part of the sentence or, if such regulations should be deemed inappropriate by the Commissioner of Energy and Environmental Protection, on the latest recommendations of the National Committee on Radiation, as published by the United States Department of Commerce, National Bureau of Standards.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
2 Section 22a- Section 3 Purpose 5.
Connecticut omits the term sources of radiation Section 22a-148 et seq. Connecticut omits Section 3.2 of the SSL.
16a-100 Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
3 Definitions Section 4 Definitions Byproduct Material will be adopted The definition does not include The tailings or wastes produced through by the extraction or concentration of uranium or thorium from any regulation ore processed primarily for its source material content. The with reference to 42 U.S.C. 2014 also includes definitions not authority mentioned in the SSL. The reference to 42 U.S.C. 2014 deines provided (1)(i) again. The definition in Sec.22a-151 references US Atomic through Energy Commission.
legislative proposal Connecticut needs to provide an explanation or justification as to sec. 2 the reason for the omissions; or supply the missing information.
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION Section 16a-101 4 Definitions Section 4 Definitions Civil Penalty will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 5 Definitions Section 4 Definitions Closure or Site Closure will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 6 Definitions Section 4 Definitions Decommissioning will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION 101 7 Definitions Section 4 Definitions Disposal of low-level radioactive waste will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 8 Definitions Section 4 Definitions High-level radioactive waste will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 9 Definitions Section 4 Definitions General license will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 10 Definitions Section 4 Definitions Specific license
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 11 Definitions Section 4 Definitions Low-level radioactive waste will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 12 Definitions Section 4 Definitions Person will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 13 Definitions Section 4 Definitions Radiation will be adopted Connecticut states that the definitions are not included in the
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 14 Definitions Section 4 Definitions Ionizing radiation will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 15 Definitions Section 4 Definitions Nonionizing radiation will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 16 Definitions Section 4 Definitions Radiation generating equipment will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 17 Definitions Section 4 Definitions Radioactive material will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 18 Definitions Section 4 Definitions Registration will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 19 Definitions Section 4 Definitions Source material will be adopted Source Material is defined in accordance with 42 US Code 2014.
through The wording is not exact but is open ended with the statement regulation in such concentration as the Commission may by regulation with determine from time to time. This code defines Commission as authority Atomic Energy Commission rather than U.S. Nuclear Regulatory
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION provided Commission.
through legislative Connecticut needs to delete the statement indicated above, and proposal correct the definition of Commission to read, U.S. Nuclear sec. 2 Regulatory Commission.
Section 16a-101 20 Definitions Section 4 Definitions Source material mill tailings will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 21 Definitions Section 4 Definitions Source material milling will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 22 Definitions Section 4 Definitions Sources of radiation will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION legislative proposal sec. 2 Section 16a-101 23 Definitions Section 4 Definitions Special nuclear material will be adopted Connecticuts definition of special nuclear fuel includes a through reference to the Atomic Energy Commission and does not include regulation the phrase, does not include source material; or any material with artificially enriched by any of the foregoing, but does not include authority source material.
provided through Connecticut needs to provide an explanation or justification as to legislative the reason for the omissions; or supply the missing information.
proposal sec. 2 Section 16a-101 24 Definitions Section 4 Definitions Spent nuclear fuel will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal sec. 2 Section 16a-101 25 Definitions Section 4 Definitions Transuranic waste will be adopted Connecticut states that the definitions are not included in the through proposed legislation but will be adopted in regulation. However, regulation this definition was omitted from the list.
with authority Connecticut needs to provide an explanation or justification as to provided the reason for the omissions; or supply the missing information.
through legislative proposal
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION sec. 2 Section 16a-101 26 22a-5 Section 5 State Radiation Control Agency Connecticut omits Section 5 (a) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
27 22a-5 Section 5 State Radiation Control Agency Connecticut omits Section 5(b) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
28 22a-153(c) Section 5 State Radiation Control Agency Connecticut omits Section 5 (d) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
29 16a-102(a) Section 5 State Radiation Control Agency Connecticut omits Section 5 (e) of the SSL.
Connecticut indicates in their crosswalk that Section 5(e) and (f) are not applicable.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
30 16a-102(a) Section 5 State Radiation Control Agency Connecticut omits section 5(f) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
31 Sec. 2 of Section 6 Advisory Committee on Radiation proposed legislation. Connecticut omits section 6 (a) of the SSL.
(Section
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION 22a-153(b) Connecticut needs to provide an explanation or justification as to and (c)) the reason for the omissions; or supply the missing information.
32 Sec. 2 of Section 6 Advisory Committee on Radiation proposed legislation. Connecticut omits Section 6 (b) of the SSL.
(Section 22a-153(b) Connecticut needs to provide an explanation or justification as to and (c)) the reason for the omissions; or supply the missing information.
33 Sec. 3 of Section 7 Licensing and Registration of Sources of Radiation proposed legislation. Connecticut omits the phrase radioactive material not under the (Section authority of the U.S. Nuclear Regulatory Commission 22a-154)
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
34 Sec. 3 of Section 7 Licensing and Registration of Sources of Radiation proposed legislation. Connecticut omits Alternative I Section 7 (b) of the SSL.
(Section 22a-154) Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
35 Sec. 2 of Section 7 Licensing and Registration of Sources of Radiation proposed legislation. Connecticut omits Alternative I Section 7 (d) of the SSL.
(Section 22a-153(b) Connecticut needs to provide an explanation or justification as to and (c)) the reason for the omissions; or supply the missing information.
36 Sec. 3 of Section 7 Licensing and Registration of Sources of Radiation proposed legislation. Alternative II(a)
(Section 22a-153) Connecticut omits the phrase radioactive material not under the authority of the U.S. Nuclear Regulatory Commission Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
37 Sec. 3 of Section 7 Licensing and Registration of Sources of Radiation proposed legislation. Connecticut omits Alternative II Section 7 (b) of the SSL.
(Section
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION 22a-153) Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
38 Sec. 2 (b)(5) Section 7 Licensing and Registration of Sources of Radiation and 3 of proposed Connecticut omits Alternative II Section 7 (d) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
39 Sec. 3 of Section 8 Source Material Processing and Related [Byproduct Material]
proposed [Mill Tailings legislation.
(Section Connecticut omits Section 8 (a) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
40 Sec. 3 of Section 8 Source Material Processing and Related [Byproduct Material]
proposed [Mill Tailings legislation.
(Section Connecticut omits Section 8 (b) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
41 22a-159 Section 9 Low-level Radioactive Waste Disposal Connecticut omits Section 9 (b) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
42 22a-159 Section 9 Low-level Radioactive Waste Disposal Connecticut omits Section 9 (c) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
43 Sec. 2 (a) of Section 9 Low-level Radioactive Waste Disposal proposed legislation. Connecticut omits Section 9 (d) of the SSL.
Connecticut does not specifically have requirements for the disposal of low-level waste.
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
44 Sec. 3 (a) of Section 9 Low-level Radioactive Waste Disposal proposed legislation. Connecticut omits Section 9 (e) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
45 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (a) of the SSL.
legislation.
Connecticut does not have language that specifically states the following:
establish by rule or regulation standards and procedures to ensure that the licensee will provide an adequate surety or other financial arrangement to permit the completion of all requirements established by the agency for the decontamination, closure, decommissioning and reclamation of sites, structures and equipment used in conjunction with such licensed activity, in case the licensee should default for any reason in performing such requirements.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
46 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (b) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority for remediatory action.
47 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (c) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION for remediatory action.
48 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (d) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority for remediatory action.
49 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (e) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority for remediatory action.
50 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (f) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority for remediatory action.
51 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (g) of the SSL.
legislation.
Section 6. Connecticut needs to provide an explanation or justification as to for authority the reason for the omissions; or supply the missing information.
for remediatory action.
52 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (h) of the SSL.
legislation.
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority for remediatory action.
53 Sec. 2 and 3 Section 11 Surety Requirements of the proposed Connecticut omits Section 11 (i) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to Section 6. the reason for the omissions; or supply the missing information.
for authority for remediatory action.
54 Section 2 Section 12 Inspection (a)(2) of the proposed Connecticut omits Section 12 of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
55 Section 2 Section 13 Records (a)(6) of the proposed Connecticut omits Section 13 of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
56 Section 2 Section 14 Federal-State Agreements (a)(1) of the proposed Connecticut needs to revise Section 22a-152 to clarify the legislation. difference between discontinuance of NRCs authority and relinquishing of NRCs authority with regard to programs and the 22a-152 Agreement.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
57 Section 2 Section 14 Federal-State Agreements (a)(7) of the proposed Connecticut omits Section 14 (b) of the SSL.
legislation regarding Connecticut needs to provide an explanation or justification as to reciprocal the reason for the omissions; or supply the missing information.
agreements.
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION 58 Section 2 Section 15 Inspection Agreements and Training Programs (a)(1) of the proposed Connecticut omits the phrase, under Section 274i of the Atomic legislation Energy Act of 1954.
Connecticut needs to clarify the specific statutory authority in this proposed legislation.
Connecticut needs to provide all language involving cooperation with other government entities.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
59 Section 2 Section 15 Inspection Agreements and Training Programs (a)(5) of the Connecticut omits Section 15 (b) of the SSL.
proposed legislation Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
60 Section 2 Section 16 Conflicting Laws (a)(5) of the proposed Connecticut omits Section 16 of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
61 Section 2 Section 17 Administrative Procedure and Judicial Review (a)(5) of the proposed Connecticut omits Section 17 (a) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
62 Section 2 Section 17 Administrative Procedure and Judicial Review (a)(5) of the proposed Connecticut omits Section 17 (b) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
63 Section 2 Section 17 Administrative Procedure and Judicial Review (a)(5) of the proposed Connecticut omits Section 17 (c) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION the reason for the omissions; or supply the missing information.
64 Section 2 Section 17 Administrative Procedure and Judicial Review (a)(5) of the proposed Connecticut omits Section 17 (d) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
65 Section 2 Section 17 Administrative Procedure and Judicial Review (a)(5) of the proposed Connecticut omits Section 17 (e) of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
66 Sec. 6 (a) of Section 17 Administrative Procedure and Judicial Review the proposed legislation. Connecticut omits Section 17 (f) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
67 Sec. 4 of the Section 17 Administrative Procedure and Judicial Review proposed legislation. Connecticut omits Section 17 (g) of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
68 Sec. 4 of the Section 18 Injunction Proceedings proposed legislation. Connecticut omits the following language:
a permanent or temporary injunction, restraining order, or other order may be granted.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
69 Section 5 of Section 19 Prohibited Uses the proposed legislation. Connecticut omits the following language:
distribute, sell, install, repair, receive, and from Section 5.
Section 22a-157) of the proposed legislation.
STATE SECTION STATE SUBJECT and COMMENTS SUGGESTED LEGISLATION SECTION Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
70 Sec. 2(c)(3) Section 20 Impounding of the proposed Connecticut omits Section 20 of the SSL.
legislation.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information.
71 Sec. 6. of Section 21 Penalties the proposed legislation Connecticut uses the term civil penalty in Section 4(a) of the proposed legislation.
Connecticut needs to clarify civil penalties in their legislation.
Connecticut omits Section 12(b) provisions of the SSL.
Connecticut needs to provide an explanation or justification as to the reason for the omissions; or supply the missing information including whether these provisions cover NRC or other agreement state licensees working in Connecticut.
.