ML19309C827
| ML19309C827 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19309C819 | List: |
| References | |
| SECY-79-646, SECY-79-646-01, SECY-79-646-1, SECY-80-054, SECY-80-54, NUDOCS 8004090306 | |
| Download: ML19309C827 (3) | |
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UNITED STATES December 7, 1979 NUCLEAR REGULATORY COMMISSION SECY-79-646 WASHINGTON, D. C. 20G55 INFORMATION REPORT For:
The Commissioners From:
Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:
Executive Director for Operations di La
Subject:
NRC IMPLEMENTATION OF 40 CFR PART 190, ENVIRONMENTAL REDIATION PROTECTION STANDARDS FOR NUCLEAR POWER OPERATIONS Purcose:
To inform the Commissioners of the staff plans and practices for implementation of the EPA regulation 40 CFR Part 190.
Discussion:
Staff groups in SD, NMSS, ELD, IE and NRR have been developing implementation mechanisms for EPA's regulation 40 CFR Part 190 since 1977, with coordination by a task force headed by the Assistant Director for Site Analysis, NRR. The regulation was promulgated by Federal Register notice 42 FR 2858 of January 13, 1977, although the advance notice of intent to propose the standards was published on May 10, 1974 (39 FR 16906). Authorit) to regulate fuel cycle facilities under these standards resides in the NRC, or, in some cases, the States, under agree-ments with NRC. The effective date for the standards that limit doses to individuals is December 1,1979, for all operations except the milling of uranium ore, for which the effective date is December 1,1980.
The effective date for the standards that limit luantities of radioactive materials entering the general environment from the uranium fuel cycle is also December 1,1979, except that the standards for krypton-85 and f odine-129 shall be effective January 1,1983. The standards apply to any twelve months of nomal operation, except that the standards for quantities of radioactive materials are based on a per gigawatt-year of electrical energy production.
The primary thrust of the staff's effort has been to make in-place NRC license mechanisms work for the EPA Standards implementation. The spec-ific implementing items that have been worked on as a result of the coordinating task force efforts are as follows:
1 Standard Radiological Effluent Technical Specifications (RETS) for BWRs, NUREG-0473, and PWRs, NUREG-0472, (Rev. 2 issued July 1979).
These specifications, which are written primarily to implement Appendix I to 10 CFR Part 50, contain descriptions of requirement;.
i related to 40 CFR Part 190. These new RETS have been transmitted to all LWR licensees, and will be implemented during calendar 1980.
All licensees have also been informed by letter of September 17, 1979 of their requirement to meet Part 190, whether the new RETS are in place or not.
Contact:
. William E. Kreger, DSE 49-28026 Enclosure "E" 8 004090 3Ob
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The Commissioners -
A working group has revised the original RETS wording related to the variance requirement of Part 190 (f 190.11) and is now factor-ing in comments on the revision from NRC staff and EPA staff.
The wording will allow " emergency" use of a variance where the emission level, although resulting in doses that are over the 40 CFR Part 190 limit, is not extreme and the licensee has a plan for re-achiev-ing compliance.
2.
NUREG-0543 " Methods for Demonstrating. LWR Comoliance with the EPA Uranium Fuel Cycle Stancard." inis cocument provices licensees witn guicance as to now to interpret the RETS regarding 40 CFR Part 190 It describes an acceptable methodology for calculating whether compliance with 40 CFR Part 190 is achieved for sites where several reactor units that comply with Appendix I to 10 CFR Part 50 may all contribute to the dose to a real individual. This document is scheduled for issuance in December 1979.
3.
NUREG-0133 "Precaration of Radiological Effluent Technical Soeciff-cations for Nuclear Power Piants (Octooer 1978)."
inis cescription of now to prepare tne RETS incluces a section on environmental radi-ation protection standards for nuclear power operations that addres-ses 40 CFR Part 190. This document is being revised for issuance of Rev.1 in the winter of 1979.
4 Co'mmission Paper (50). A SD Commission paper identifying proposed NRC regulation changes to recognize 40 CFR Part 190 is in final-stages of preparation and should be reaching the Commission shortly. As a result of the task force's consensus, minimal changes are proposed to be made in existing NRC regulations to, accommodate to 40 CFR Part 190.
5.
Fuel Facility License Conditions.
There are nine operating uranium fuel cycle (UF6 conversion and fuel fabrication) plants licensed by the NRC that a're subject to the provisions of 40 CFR 190 beginning December 1,1979 (The regulation does not become effective for. uran-ium mills until December 1,1980.).
A recent overview of these nine facilities, based upon evaluation of effluent data reported for the past several years, has shown that the plants, with the possible exception of two facilities, are operating within 40 CFR Part 190 limits. Also, the staff has previously concluded that it would not be cost-effective to require additional treatment to j
further reduce emissions from the uranium fuel cycle facilities.
This information has been reported to Dr. David M. Rosenbaum, Deputy Assistant Administrator for Radiation Programs at EPA in a July 27, 1979 letter from R. B. Minogue, Director of OSD.
e
The Commissioners
- Detailed assessments using current data are underway to document the present status of each plant with respect to the requirements of 40 CFR 190. A description of the dose calculations methods used will be included in the assessments. The assessments for the two facilities which are questionable in terms of 40 CFR 190 limits will include evaluation of environmental air sampling data that are being collected near the plants and consideration of what actions, if any, may be necessary to achieve compliance.
It should be noted that the exposure pathway of concern for these ope.ating uranium fuel cycle plants is inhalation of airborne effluents; other pathways of exposure are insignificant contributors to the radiation exposure of public individuals.
Based upon these assessments, site-specific license conditions will be imposed upon each licensee to assure continued compliance with 40 CFR 190.
These conditions will include quartprly action levels on effluent releases or environmental measurements and a requirement to report to the NRC if these levels are exceeded with a description
,f the actions that are being taken.
o Variance requirement policy, which may be different for non-reactor fuel cycle facilities are in an early develop-ment stage.
It is planned that the license conditions including a variance requirement, will also be used for uranium mills.
These will be developed during the coming calendar year.
The task force effort has included members of EPA staff, including upon occasion, members of the EPA legal staff.
EPA staff review has been requested for many of the items described above and comments that have been made by EPA staff have been accommodated.
l EPA has effectively concurred in the thrust of our 40 CFR Part 190 implementation effort.
M/
Harold R. Denton, Director Office of Nuclear Reactor Regulation t
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