ML19294B898
| ML19294B898 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/1980 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Danielson L NATIONAL WILDLIFE FEDERATION |
| References | |
| REF-PROJ-M-25 NUDOCS 8003060301 | |
| Download: ML19294B898 (2) | |
Text
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FEB 0 81980 Mr. Luke J. Danielson National Wildlife Federation Natural Resource Clinic University of Colorado School of Law Boulder, Colorado 80309 Daar Mr. Danielson:
Your letter of January 11, 1980, identified four issues of technical concern which you state were not treated in any detail in the GEIS.
You also expressed your view that much new information has come to light regarding these issues and that, due to its significance, it should be treated in the final GEIS and constitutes supporting evidence of the need for the issuance of a second draft.
Furthermore, you state your opinion that reopening the comment period on the present draft to receive additional comments on these issues would not necessarily result in significant delay.
As we discussed in our phone conversation with you on February 6,1980, the issues which you have identified are ones we are aware of and concerned about, and we will certainly be giving them appropriate consideration in our decision-making and in preparation of the final GEIS.
It is our view, however, that any delay in the preparation of the final GEIS or promulgation of final regulation changes would be significant, due to the immediacy of the need for issuance of formal regulations.
We fully anticipate that the technological data base on uranium milling and uranium tailings will continue to expand at a rapid pace for at least the next several years and probably longer. This will be virtually guaranteed by the continuation and expansion of the comprehensive research programs already initiated by both NRC and D0E. Additionally, vast amounts of field data and experience will be generated through actual irhplementation of DOE's congressionally mandated remedial action program for abandoned processing sites. To simply abstain from rule making due to this coming technical evolution would constitute tacit acceptance of status quo conditions for an indefinite period, which is unacceptable.
Therefore, if we are to improve upon the current regulatory framework in a timely manner, we must proceed with rule making in the face of developing technology.
Rapid finalization of the draft GEIS and proposed rules at this time will certainly r :c preclude any opportunities for further regulation changes should they become needed on the basis of additional infomation.
8003060 p 1
s Mr. Luke J. Danielson.
In summary, we continue to consider it appropriate to move forward without delay toward formal regulation changes based on current knowledge.
We appreciate your comments and interest in these matters, and invite you to cont'act either me or Mr. Miller at 301-427-4103 should you require any further response.
Sincerely, j?W k aLW '
Dan E. Martin, GEIS Project Manager Uranium Recovery Licensing Branch Division of Waste Management cc:
E. Grammer, ELD D. Harmon, OSD e
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