ML19323B586
| ML19323B586 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/1980 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Miller H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-PROJ-M-25 NUDOCS 8005130713 | |
| Download: ML19323B586 (5) | |
Text
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Distribution:
WMUR r/f Apg 10 $80 Nf1SS r/f Wilr/f WMUR c/f Mill File Subject File
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HEMOR/diDUM FOR: Project M-25 Record M
JBMartin TilRU:
Hubert J. Miller REBrowning Uranium Recovery Licensing Branch RAScarano Division of Maste fianagement HJMiller
.U DEMartin i
FR0il:
Dan E. !!artin i
Uranium Recovery Licensing Branch Division of Haste fianagement
SUBJECT:
!!I:'UTES OF !!EETI!!G UITil AMERICA!!
filf!Ii!G C0:'GRESS (N C) l Purpose t
The meeting uas held, in response to an /JIC request, for the purpose of providing AMC representatives with current inforrution on the status, course, and schedule of the GEIS and associated proposed regulation changes.
Place and Date UStiRC, Uillste Bldg, Room 474, Monday, March 31,1980, at 3:00p.
Attendees A!!C - Jeff Zimmerran
!!RC - Ross A. Scarano
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Edward McGrath llubert J. Miller Charles Slider Dan E. !!artin j
Summry 1
At 3:00p the meeting was convened with all listed attendees present.
i Zimmeman passed out copies of an agenda (copy attached) to identify the i
topics Af!C uished to discuss and asked for comments. Scarano identified l
l item "2" on the agenda (potentially involving discussion of what specific substantive changes might be rude in the proposed regulations) as one l
where discussion would have to be limited for reasons of fairness.
From this point on the meeting essentially consisted of I;RC responses to M1C requests for information. The following information was provided to A!'C :
1 THIS DOCUMENT CONTAINS POOR QUAUW PAGES 1
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! APR 101990 liiller described the volume of public coments received and identified their sheer bulk as a problem.
f At Scarano's request, Martin described the mechanical procedures beira employed to identify, categorize, synthesize, and respond to I
public comments.
Zimmerman remarked that the procedure seened
" extremely rational" and should assure that comments are not missed.
Scarano stated that there would be a complete " paper trail" identifying the treatment of each comment, and described the j
iterative review process.
11artin stated that the ma.iority of comments were being handled in-house and that !!RC would bear the final responsibility for all responses generated.
I'cGrath said that the purpose of the meeting was assessment of current status; Zimmerman inquired as to the current status of preparation of responses. Martin said some had been prepared and some had not.
!! iller said oth6r !!RC offices such as the Office of the General l
Counsel and the Office of Policy Evaluation would reviou the product and that the Commission would have the benefit of their vicus in making its final determination.
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itartin said target date for initiation of internal review process among other offices was early June, that the target date for submittal to the Comission was early July, that the tentative publication date for the GEIS was late August, and that the publication of the regulations was scheduled 60 days later to allow for a i
mandatory GAO review.
Scarano comented that the Comrission was not committed to a definite review period, that our final publication dates were thus tentative, and that we intended to send the entire package to the Comission at one time.
Scarano clarified the fact that our present intentions are to publish the GEIS and regulation changes in final form, without l
further public input or review by Agreement States.
l Scarano identified the need to allow Agreement States sufficient icad time to allow incorporation of our regulations in State statutes prior to !!ovember 8,1931 (so as to maintain continuity of I
their Agreement State status under the VIITRCA) as being a determining j
factor in the GEIS schedule. flartin stated that although we would not he seekinn comant or advicn frnn tha Sornmnnt 9tatne "o mkht take action al appropriate to provide thc a with advance notice as GPPtCE %
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i 3-APR 101980 Zimmerman commented that CEQ regulations would require a minimum 30-day delay between any final EIS publication and an agency C.
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action.
Zirnaerran asked whether flRC interpreted this to require 30 days following the final GEIS before regulations could even be promulgated (i.e., does promulgation of regulations before they become effective constitute an action.) Miller stated that !!RC i
would likely not consider promulgation as the " action".
i Zimmerman asked as to any plan to incorporate land cleanup criteria similar to those in draft EPA remedial action criteria. Scarano l
sai.d no and explained that we were leaving that up to EPA.
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Ziamerman inquired as to the possibility of EPA regulation of nills under the Clean Air Act requireacnts. Scarano said he did not forsee that at the moment but that EPA my eventually add a radon limit to 40 CFR 190.
. tiller stated that we had written concurrence from EPA as to j
compatability of our proposed regulation changes with RCRA standards, as required by the UIITRCA, and that we did not consider further concurrence would be necessary. Scarano stated that EPA had not been critical of our proposed regulations; liiller added that EPA's recedial action criteria were largely based on the draft GEIS.
Scarano said he did not anticipate any significant inconsistencies because EPA and ;!RC are working with the same data base.
Scarano said that we did not anticipate any major changes in j
regulations. ililler commented that new information becoming
""l' available has not markedly changed past perspectives, but that new information would be included and that the Final GEIS would have i
changes. Scarano said that nothing had really " fallen apart" and needed to go "back to the drawing boards".
1 The above items constitute the points of discussion related to the GEIS i
directly. Further discussion on other issues is summarized below:
i I'cCrath inquired as to Ililler's recent hearing experience in Harrisburg on the proper S-3 entry for radon.
iiiller summarized by saying that he saw no problebs as long as our radon limit became effective promptly, without significant alteration, but that l
elinination of the radon limit for any reason would essentially re-open all proceedings.
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~4-Apa 101980 l'cGrath claborated at some length as to the need to make the !!ILDOS code publicly available and inquired as to the status of that i
effort. 14111er responded that our current plan is to achieve ilILDOS availability, with adequate user guidance, in about one nonth.
- ~M The meeting was ended at about 4:30p.
1 Criginal Signed By:
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l Dan E. Ihrtin j
Uranium Recovery Licensing Branch I
Division of Haste flanagement Attach::1ent:
N:C :ceting Agenda f
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. Agenda for Meeting March 31, 1980 American Mining Congress and Division of Waste Management, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission e
f This meeting will be limited to the following topics concerning Project M-25, the Generic Environmental Impact Statement on Uranium Milling (GEIS) and the proposed amend-ments to the uranium mill licensing regulations, 10 CFR Parts 30, 40, 70, 150 and 170:
1.
Schedule and mechanism for Staff and NRC review of the comments on the draft GEIS proposed regulations; 2.
Issues identified by Staff that (1) do not require further study, (2) require further study and (3) require supplementary public input before publication of revised GEIS and regulations; 3.
Coordination of Staff review of draft GEIS, proposed regulations and comments with EPA, particularly in relation to EPA regulation of radionuclides under the Clean Air Act and inactive mill site standards; 4.
Procedural coordination with " Agreement" states in review of draft GEIS proposed regulations and comments; 5.
Manner and tir.ing of review with other federal, state, and local governmental agencies; 6.
Schedule for publication of revised GEIS and revised regulations; and 7.
Potential effective data final regulations.
Minutes of the meeting and a list of those attending will be prepared.
When agreement is reached by NRC and~AMC that the
' minutes and list accurately reflect.the participants and dis-cussions-at this meeting, copies of the minutes will be placed in the Public Dockets for Project M-25 and the proposed uranium mili licensing regulations, 10 CFR Parts 30, 40, 70,150, and 170.
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