ML19316A706
| ML19316A706 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Goller K NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19316A707 | List: |
| References | |
| NUDOCS 8005230755 | |
| Download: ML19316A706 (2) | |
Text
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800seso } H ISTRIBUTION
/ CENTRAL FILE RMattson NRR R/F DEisenhut HDenton DMuH er MAR *' 51980 EGCase WEKreger HBerkow/WRussell MGroff (NRR-3846)
Dross PlaGrange/CPaul MEMORANDUM FOR:
Karl R. Goller, Director, Division of Siting, Health and Safeguards Standards SD
.FROM:
Harold R. Denton, Director, NRR
SUBJECT:
EPA-NRC INTERAGENCY AGREEMENT ON Cl.EAN AIR ACT (NRR-3846)
In response to your memorandum of March 6,1980, we have reviewed the draft subject agreement and have the following coments:
1.
The agreement, while stating the principle of avoiding " unnecessary duplication of effort," is not specific enough to have a significant effect in achieving that goal; 2.
The notice, in (b) of page 4, should indicate that the technical spect-fications that are part of a facility license are conditions that pro-vide for very specific radionuclide release control;.
3.
The items of " EPA will": on page 5 should be more specific so that thdy For example, it should say what meaningfully (describe what EPA will do.b) review and approve as appropriate is meant by or modified sources. We believe that where NRC can assure EPA that new or modified sources meet existing NRC requirements, that have satisfied the Clean Air Act standards promulgated by EPA, EPA should not have to review the application.
4.
Similarly, it is not clear what is meant by " EPA will:
(c) issue waivers of compliance," and why, or under what conditions.
S.
On page 5, it should also be more specific about "NRC will:
(b)make recommendations to EPA on applications for new and sodified sources What kind of recommendations and to what effect. Why shouldn't NRC just specify that the NRC regulatory program will assure that regula-ted facilities and sources will meet EPA standards?
6.
On page 6, it is not repeated from the earlier part that EPA will promul-gate air emission standards that take maximum consideration of how NRC is regulating its licensed facilities. We believe it should.
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It is desirable that when NRC regulates to its rules, that will be in T#c. Y
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compliance with EPA promulgated clean air act standards, the EPA will 9
not have to review an application but will accept NRC's review and P
l analysis. This should be clearly stated. This is an expansion of S.
1 f b.;
f above.
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r'arl R. Goller These conments have been discussed between John Hickey, 50 and 11. Kreger,
- lPP. on March 17, 1980.
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