ML20210R087
| ML20210R087 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/1997 |
| From: | Bangart R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Sinclair W UTAH, STATE OF |
| References | |
| NUDOCS 9709020303 | |
| Download: ML20210R087 (11) | |
Text
_____ - -
,, sutg t UNITED STATES
/
3 ,e j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 30 2 6-0001
(,,,../ August 19, 1997 Mr. William J. Sinclair, Director Division of Radiation Control Department of Environmental Quality 168 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4850
Dear M,
. 3inclair:
The Nuclear Regulatory Commission (NRC) has recently evaluated the previous Utah Agreement State program review conducted in 1994, and concluded the review findings were not biased by decisions or infermation documented by the previous Director, Utah Division of Radiation Control. The review was held during the week of June 13 17,1994 in Salt Lake City, Utah, and audited the State's actions during the period of April 12,1992 to June 13,1994. In a letter dated December 6,1994, the Utah program was found to be
) adequate to protect public health and safety and compatible with the regulatory programs of the NRC.
Results of the June 1317,1994 program review identified two areas which we cannot determine, based on our recent evaluation, have been closed out. We request information as identified in the following two areas.
- 1. Air Pathways Analysis in support of Envirocare amendment for additional radionuclides was an issue identified from the 1992 review and not closed during tlie 1904 review.
NRC noted that pathway analysis did not address potentially significant nuclides such as C 14 or tritium. NRC recommended a pathway analysis to include C-14 "and tritium." In response to NRC comments, the State required Envirocare to perform the analysis. The State in its March 17,1995 response to NRC's 1994 review summarized Utah's evaluation of the review of the licensee's methodology and the licensee's results for C 14. The results for tritium or the rationale for its exclusion were not submitted. NRC requests that you supply the information specifically for tritium,
- 2. A recommendation was offered under Contractual Assistance that the State should have procedures in place to avoid the selection of contractors associated with the i development or operation of the site. Only one contractor was involved in the specific instance and Utah responded that no conflict was involved. Utah committed to modify their procedures as appropriate. For completion, NRC requests {l the name of the contractor involved, a copy of the modified procedure, and Utah's evaluation of Utah cmractors supporting the review of the Envirocare license renewal applicatk.. to assure no conflict of interest is present.
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9 William J. Sinclair 2-This additional information will allow us to complete our analysis of all open issues. Your reply is requested by September 30,1997. We appreciate your assistance and if you have any questions, please contact me at 301 415 3340.
Sincerel Richard L. Bangart, Director Office of State Programs i
DISTRIBUTION: DCD (SP08)
DIR RF (7S121) PDR (YES/)
SDroggitis Utah File DOCUMENT NAME: G:\KXS\7S121 KNS ft 'See Previous Concarrence.
n ,...sv. . ..n ., w. 4.eum.at. inee.i. in the b .: c c _ vVpout n. chm.ntiencio.ur. - copy with ett.chmirvi.ncio.ur. u - N copy OFFICE OSP O T:by/ [ NMSS OSP:C[/M NAME KSchneider:gd:nb PHLotiaus JGreeves RLBangart 7" DATE 07/23/97
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5 A9~g William J. Sinclair 2-This additional information will allow us to complete our analysis of all open issues. Your j reply is requested by September 30,1997. We appreciate your assistance and if you have any questions, please contact me at 301 415 3340.
Sincerel Richard L. Bangart, Director Office of State Programs l
l l
QlSTRIBUTION: DCD (SP08)
DIR RF (7S121) PDR (YES/)
SDroggitis
' Utah File DOCUMENT NAME: G:\KXS\7S121,KNS ft 'See Previous Concurrence.
Tm receive a copy of thh document,ind6cate in the boa: "C" = C y 5vitt,out ettschnient! enclosure *E' = Copy with attachmqfit/ enclosure 'N' = No copy OFFICE OSP l Oy:DQJ l NMSS OSP:[]/s NAME KSchneider:gd:nb PHLoliaus JGreeves RLBangart V
DATE -07/23/97
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William J. Sinclair 2-This additional information will allow us to complete our analysis of all open issues. Your reply is requested by September 30,1997. We appreciate your assistance and if you have any questions, please contact me at 301 415 3340.
Sincerely, Richard L. Bangart, Director Office of State Programs l
DISTRIBUTION: DCD (SP08)
DIR RF (7S121) PDR (YES/)
SDroggitis Utah File DOCUMENT NAME: G:\KXti\7S121.KNS h 'See Previous Concurrence, n % . , . w. e . ai. we & n p ui.it.enen.nti.,cioiv,.
m in. ws: c . c r copy wiin eti. chm.ni!.ncio ur. w - wo eop, OFFICE OSP Oy:DQ/ [
NAME KSchneider:gd:nb
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PHLoriaus 4 Keves- RLBangart DATE 07/23/97
William J. Sinclair 2-NRC noted that pathway analysis did not address potentially significant nuclides such as C 14 or tritium. NRC recommended a pathway analysis to include C 14. In response to NRC comments, the State required Envirocare to perform the analysis.
The State in its March 17,1995 response to NRC's 1994 review surnmarized Utah's evaluation of the review of the licensee's methodology and the licensee's results for C 14. The results for tritium or the rationale for its exclusluc were not submitted. NRC requests that you supply the Information specifically for tritium.
- 3. A recommendation was offered under Contractual Assistance that the State should have procedures in place to avoid the selection of contractors associated with the development or operation of the site. Only one contractor was involved in the specific instance and Utah responded that no conflict was involved. Utah committed to modify their procedures as appropriate. For completion, NRC requests the nanie of the contractor involved, a copy of the modified procedure, and Utah's evaluation of Utah contractors supporting the review of the Envirocore license renewal application to assure no conflict of interest is present.
This additional information will allow us to complete our analysis of all open issues.
We appreciate your assistance and if you have any questions, please contact me at 301 415 3340.
2 l
- Sincerely, Richard L. Bangart, Director Office of State Programs DISTRIBUTION: DCD (SP08)
Dln RF (7S121) PDR (YES/)
SDr:ggitis Utah File DOCUMENT NAME: G:\KXS\7S121.KNS 'See Previous Concurrence ,
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- E' = Copy with .ttachm.nt!.nclosur. *N' = No copy OFFICE OSP 0% pp: OSP:D NAME KSchneider:gd:nb PHLo %d RLBangart DATE 07/23/97
William J. Sinclair 2-
/
NRC noted that pathway analysis did not address potentially significpnt nuclides such as C 14 or tritium. NRC recemmended a pathway analysis toinclude C 14, but not specifically tritium, in response to NRC comments, the State required Envirocare to perform the analysis. The State in its March 17[1995 response to NRC's 1994 teview summarized Utah's evaluation of the rpsiew of the thensee's methodology and the licensee's results for C 14. The res6lts for tritium or the rationale for its exclusion were not subrnitted. NRC r94'uests that you supply the information specifically for tritium.
- 3. A recommendation was offered under Contractual Assistance that the State should have procedures in place to avoid the selection of contractors associated with the development or operation of the site. Onlyine contractor was involved in the specific Instance and Utah responded that no confilet was involved. Utah committed to modify their procedures,as appropriate. For completion, NRC requests the name of the contractor involvedyb copy of the modified procedure, and Utah's evaluation of Utah contractors supporting the review of the Envirocare license renewal application to assure no i:onflict of interest is present.
/
This additional information will allow us to complete our analysis of all open issues.
We appreciate your assistance an'd if you have any questions, please contact me at 301 415 3340.
/
Sincerely, Richard L. Bangart, Director Office of State Programs
/
DISTRIBUJiON: DCD (SP08)
DIR RF (7S121) PDR (YES/)
SDroggitis Utah File DOCUMENT NAME:. G:\KXS\7S121.KNS T3 recobre e copy of this document. Indicate in the boa: 'C' = Copy without attachment / enclosure 'E' = Copy with ettachment/ enclosure 'N' = No copy OFFICE OSP gj) l OSP:DD l OSP:D l NAME- KSchneider:gd PHLohaus RLBangart DATE- 07/g97 07/ /97. 07/ /97 OSP FILE CODE: SP AG 2 3
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. . - 05/13/97 TA.SK.DUE
.. . - 06/12/97 TASK COMPLETED ..
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T.ASK DE.SCRIPTION.
..... .. ..... - LETTER TO UTAH ON OUTSTANDING ISSUE FROM 1994 REVIEW R.EQUEST..ING
..... .. OFF. - OSP REQUESTER
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, OSP DUE DATE: 6/13/97 PLANNED ACC. -N LEVEL CODE - 1 00LfyNN,-Q -
o ,. O William J. Sinclair, Director l Division of Radiation Control Department of Environmental Quality 168 North 1950 West l P.O. Box 144850 i Salt Lake city, UT 84114 4850
Dear Mr. Sinclair:
1 NRC has recently evaluated the previous Utah Agreement Stato program review conducted in 1994 and concluded the review findings were not biased by decisions or information documented by the previous Director, Utah Division of Radiation Control. The review was held during the week of June 1317,1994 in Salt Lake City, Utah and audited the State's actions during the period of April 12,1992 to June 13,1994. In a letter dated December 6,1994, the Utah program was found to be adequate to protect public health and safety and compatible with the regulatory programs of the NRC.
Result of the June 1317,1994 program review identified three areas which we cannot determine based on our recent evaluation, have been closed out. We would appreciate Infortnation as identified in the following three areas.
- 1. Completion of the Safety Evaluation Report (SER), was an issue identified from the 1992 review and not closed during the 1994 review.
The completion of the SER, to include the grou~l water discharge permit statement of basis, was c ,sidered partially addressed, bu: nP losed at the time of the 1994 review. The State was in the process of ongoing licensing actions and preparation of a draft revised ground water discharge permit. The report for the 1994 review stated that NRC would continue to monitor Utah's continual actions with regard to the inclusion of the ground water discharge permit statement of basis in the SER and that NRC requested a copy of Utah's draft permit for comment when issued.
Mr. Fred Ross has received information from the Utah staff during the past year, however, there has been no formal submittal from the State of the draft permit.
NRC requests a copy of the ground water discharge permit if final or the draft permit if it has not been issued.
- 2. Air Pathways Analysis in support of Envirocare amendment for additional radionuclides was an issue identified from the 1992 review and not closed during the 1994 review. J
, x Ut,cy.c a Ak SQ'1')(v~iu eMnmf kwahuo WA+hh,)ehe f,,&- Lf md ddU
/_ 2 NRC recommended a pathway analysis to include C 14jand tritium. In response tof d3
,/ M ilh M NRC comments, the State required Envirocare to perform the analysis. The Statej kly* D supplied the results whosponse-to the review $f.the methodology used by-tha,
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licensee and the results for C 14. The results for tritium or the rationale for its exclusion were not submitted. NRC requests that you supply the information specifically for tritium.
- 3. A recommendation was offered under Contractual Assistance that the State should '
have procedures in place to avoid the selection of contractors associated with the development or operation of the site. Only one contractor was .nvolved in the '
specific instance and Utah responded that no conflict was involved. Utah committed to modify their procedures as appropriate. For completion, NRC requests the name of the contractor involved, a copy of the modified procedure, and Utah's evaluation of Utah contractors supporting the review of the Envirocare license l
renewal application to assure no conflict of interest is present. ;
This additional information will allow us to complete our analysis of all open issues. ,
We appreciate your assistance and if you have any questions, please contact me at '
301 415 3320.
l j)(0 Sincerely, Richard L. Bangart, Director j Office of State Programs DISTRIBUTION: DCD (SP08)
DlR RF (7S121) PDR (YES/)
SDroggitis Utah File DOCUMENT NAME: G:\KXS\7S121.KNS i: e.c.h,. . ..py ., thi. 4 um.at. indic.i. in ih. b..: c - copy without ti.ci.m.nti.ncio.u,. . copy with eii. chm.nt/.nclosur. N = No copy OFFICE OSP OSP:DD OSP:D l l NAME KSchneider:gd PHLohaus RLBangart DATE 07/ /97 07/ /91 07/ /97 OSP FILE CODEi SP AG 23
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Mr. William Sinclair. Utah g
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Dear Mr. Sinclair:
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NRC has recently eval ated the previous tah Agreement State arogram review conducted ;n 1994 an concluded the re 1ew findings were not Jiased by
, decisions or inform ion documented b the previous Director. Utah Division of Radiation Control. The review was held during the week of June 13 17. 1994 in Salt Lake City. Ut.h and audited tb6 State's actions during the period of April 12. 1992 to June nal 13.1994./oproetterdatedDecember6.1994,theUt6h program was foun to be adequa t ect )ublic health and safety and compatible with he regulator rograms of t ie NRC.
'~~\
j w ,e ms Asra bsult_of _thot revieQ we request the following information on three' s y
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areas identified during our recent review to complete NRC's assessment: &9
- l. Completion of the Safety Evaluation Report (SfR), was an issue identified from the 1992 review and not clQsed during the 1994 review.
- \ M b \% '.(h W The completion of L @he SER, to i clude the ground water discharge permit
, statement of basis'. was consid ed partially addressed, but not cbsed at the time of the\ review. Th State was in the process of ongoing licensing actions and prepara on of a draft revised ground water discharge permit. The report stated that NRC would continue to monitor Utah's continual actions with regard to the inclusion of the ground water discharge permit statement of basis in the SER and that NRC requested a co)y of Utah's draft permit for comment when issued.
Mr. Fred Ross las received information from the Utah staff during the
. past year, however, tnere has been no formal submittal from the State of the draft permit. NRC requests a ccpy of the ground water discharge permit if final or the draft permit if it has not been issued.
- 2. Air Pathways Analysis in s wort of Envirocare amendment for additional radionuclides was an issue identified from the 1992 review and not closed during the 1994 review. 9 S' s X NRC recommended a pathway analysis to inc ude C 14 and tritium. In response to NRC comments, the State requi'ed Envirocare to perform thet pch analysis.
)y..the used of the methodology licensee _and__he results t for C-14.'TheThe State sup) s lied the res re5111tifrtritium^or the rationcie for its exclusion were not submitted.
%y w tritium. NRC requestsgah suppl %i the information specifically for
% Ti bp g
- 3. A recommendation was offered under Contractual Assistance that the State should have procedures in place to avoid the selection of contractors associated with the development or operation of the site. Op one contractor was involved in the specific instance and'the Utaffprespordeh
o
- d that no conflict was involved, Utah committed to modify their procedures as appropriate. For completion. NRC requests the name of the contractor involved, a copy of the modified procedure and W1Jtah's evaluation of the 4 Utah contractors supporting the review of the Envirocare license renewal application to assure no conflict of interest is present.
This additional information will allow us to complete our analysis of all open issues. We appr contactmeat3)eciateyourassistanceandifyouhaveanyquestions,please 0
Vj415 2320')
/ $}A Y qfg , Sincerely, t *' aj,G 2 3 pp W Richard L. Bangart l
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OFFICE OSP OSP:DD OSP:D r
NAME KSchneider: PHLohaus RLBangart DATE 06/ /97 06/ /97 OSP FILE reg -
CODE: SP AG 28 '
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