ML20212J281
| ML20212J281 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1986 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Lash T ILLINOIS, STATE OF |
| Shared Package | |
| ML20210H056 | List:
|
| References | |
| FOIA-87-47 NUDOCS 8703060375 | |
| Download: ML20212J281 (5) | |
Text
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Il UNITED STATES
& NUCLEAR REGULATORY COMMtsstON
.y Ref: SA/J0L ]
- j. W ASHINGTON. D. C. 20555 ,
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, l SEP 2 91986
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Dr. Terry Lash, Director Department of Nuclear Safety 1035 Outer Park Drive .
Springfield, Illinois 62704
Dear Dr. Lash:
Thank you for the opportunity to review the redrafted supporting We documentation for the proposed request for a Section 274b Agreement.
noted that substantial revisions have been made to the program narrative and found it to be, overall, an excellent supporting document.
All of our coments.are intended to amplify certain portions of the document to provide support for NRC staff's assessment ofOur Illinois coments request which will be published in the Federal Register.I would like, however, to are sumarizedThis in the enclosure.
concerns the need to provide additional clarification one coment.
of the role of IDNS and, more specifically, of the Director, in the selections of the low-level waste disposal site, the site licensee authorized to construct and operate the site and in the assumption Certain byof the Department of custody of the site after it is closed.
the' LLW functions, e.g., site characterization will be perfomed by IDNS which begs the question, who will oversee the IDNS actions to assure We have that technical and procedural requirements were complied with?
previously indicated the importance of providing adequate assurance that these functions will not result in perceived or actual conflicts of interest with the Department's role as the licensing and regulatory agency for radiation safety for'the site.
If you have any questions, please do not hesitate to call Joel Lubenau
! or me. We look forward to receiving the formal request from Governor Thompson.
Sincerely, stAWh bon Donald A. Nussbaumer Assistant Director for State Agreements Program Office of State Programs
Enclosure:
As stated l
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JDavis, w/enci JTaylor,w/ecn1 SEP 2 91986 Dr. Terry Lash, Director Department of Nu-lear Safety 1035 Outer Park Drive 62704 Springfield, Illinois
Dear Dr. Lash:
Thank you for the opportunity to review the redrafted supporting We documentation for the proposed request for a S and found it to be, overall, an excellent supporting document.
All of our coments are intended to amplify certain portions of the document to provide support for NRC staff's assessment Our coments of Illinois request which will be published in the Federal Register.I would like, how are sumarized in the enclosure.This concerns the need to provide additional c one coment.
of the role of IDMS and, more specifically, of the Director, in the selections of the low-level waste disposal site, the site licensee authorized to construct and operate the site and in theof assumption Certain the Department of custody of the site after it is closed.
which begs the question, who will oversee We have the that technical and procedural requirements were complied hwith?
previously indicated the importance of providing adequate f as these functions will not result in perceived or actu agency for radiation safety for the site.
If you have any questions, please do not hesitate to call Joel Lub We look forward to receiving the iomal request from Governor or me.
! Thompson.
I Sincerely, Donald A. Nussbaumer Assistant Director for State Agreenents Program Office of State Programs
Enclosure:
! As stated l
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t 'NRC Staff Coments on September 8,1986 DraTt Application for Agreement State Status I
Note: NRC staff have no coments on vols.- III (Statut (Regulations).
adopted.
This fact and their effective date should The following are coments on Volume I.
(Application) and III. Commen_t_
Paragraph /Line M Close up space between lines.
Table of Contents II.B.I.5)(2)&
1st page II.B.1.c) 1st paragraph / Add the date that the regulations became effective.
3
- # "2. Modify, suspend or revoke 4
7th line p , licenses."
Please spell out "REAC/ RAFT."
7th -line 21 Re Column, " Number If so, please Mre state. these full time positions 27 of IDNS Staff &.
Office" ,. ;
Re s'ite selection /ihe issue of the potential for 31 conflict of interest for the
-- Director needs to be addressed.
' If the Director selects the site, who detemines the
, adequacy of the technical evaluations which support the selection?
Par, numbered "3)" < It would be helpful in t 31 the issuance of a LLW disposal site license If a selection and to whom it is process issued.
is involved then, again, the issut of conflict of interest should be addressed in the l
narrative.
When custody is assumed by IDNS, Re custody of 34 disposal will there be a license document? Who will hold it? If facilities IDNS is the license holder then, again, how is the conflict of l interest matter resolved?
I s-
- . - - - - -.,--n--.- - , - . , - - , - - , - . - , - - - - , , - - - - - . - . , - - - . . , , - . - - . - . . , . , - - ~ . _ , . -
t- ,
j .
Paragraph /Line Comment' Page
-35 8th line /" detectable limits" .is' a vague .
tenn. Can the liinits be defined or expressed in terms of fractions of MPC's?
Bottom para. ' Same questions as above for 36 p.34.
10th line ,Suggest deleting " licensing" and 36 ~ inserting "its regulatory responsibilities with respect to a."
44 2nd line /Shouldn't " third" be " fourth?"
Section C For clarity, the section should 54 - state that inspections of the Sheffield and regional disposal
<7 L fadilities will be conducted by
~ q this Division, if that is the-Otherwise, it needs to be 4 case.
covered in the sections on the
@' Sheffield and regional disposal facilities.
54 Section C, A nsert "as a minimum" before "be 3rd line modeled."
Last para, j Typo: "m_a,nagement."
56 2nd line 3rd line Insert " modified," before i 58 "suspende^d."
i 64 Top of page ,Suggest adding a statement that IDNS is closely following NRC regulatory reports following the Sequoyah Fuels accident, e.g.,
NUREG's 1179 & 1198, and will factor these into its regulatory program for Allied Chemical, as appropriate.
64 /Addtothissectionthe attendance of John Cooper at OSP's Special Licensing Topics:
Contingency Plans session held in San Francisco, October 6, 1986.
1st 3 lines See comment for p.54, Section C.
68 Inspection ,.Can change Hsu, Sanza and Kark 78 Procedures to "-1986."
i
-1
(=
b
- Coment Paragraph /l.ine_
M Licensing Course g"anchangeHwangandLaToucheto 79 1986." ,
Can change Hwang and Meiners._to Medical Course 79 "-1986."
Add: Special Topics in' 81 Licensing Contingency Plans -
/ NRC; John Cooper - 1986. (Or add s~s toSectionIV.B).
Re staffing ,/.Should the 1.4.figu're be 85 jadjusted for assistance to Cooper's program for LLW
' regulation */ (X-ref: p.98).
We believe.the point on response Lines 9-13 89 time can be made more effectively by deleting the last two sentences and substituting:
"The combination of the central location of the Springfield office and the Chicago area office will enable the Department to provide prompt on-site emergency responses within the State."
is may be an appropriate place 105 Division of to discuss conflict of interest Responsibilities concerns in the LLW program.
3rd line ,/Webelievethestaffingpoint 108 can be more effectively made by deleting the 3rd line and substituting: " compared to the NRC guideline for existing Agreement State program staffing of 1.0 to 1.5 staff-years per 100 licenses.
po: " responses _."
108 next to last line App. 5
- /ddtoc.v.'stherecent
/ attendances at NRC courses by Sanza, Hsu, Kark, Hwang, LaTouche and Meiners.
/
Add the c.v. of Gary Wright App. 5 since he is referred to on p.62 as available to the Agreement State program.
.