ML19345D613

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Responds to 801115 Comments on Proposed Rules 30,32,70 & 150 Re Exemption of Smelted Alloys from Licensing Requirements. Prospect That Recycled Enrichment Plant Scrap Would Cause Cancer Unlikely
ML19345D613
Person / Time
Issue date: 12/02/1980
From: Henry J
NRC OFFICE OF STANDARDS DEVELOPMENT
To: Atamian L
AFFILIATION NOT ASSIGNED
References
FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70, TASK-OS, TASK-TP-710-1 NUDOCS 8012160238
Download: ML19345D613 (2)


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DEC 2 1930 Ms. Linda Atamian 20 Pond Street Wakefield, Rhode Island 02879 Cear Ms. Atamian:

Subject:

Questions en Proposed Exemption of Smelted Alloys This responds to your letter of November 15, 1980, expressing your deep concern about our proposal to exempt a loys frcm licensing requirements.

In your first question, you asked what is meant by "...it is hoped to reduce the contamination..." that appears in News Release No.80-193 of October 27, 1980. The quoted vords relate to an early NRC staff decision that any pro-posed action must cover scrap metal melted or fused into smelted metal.

Smelting provides a decontamination procedure for uranium in addition to the procedures for prior decontamination of the scra9 and disperses the residual contamination throughout the smelted metal. This eliminates the possibility that exempt perscns could receive scrap with loosely adhering, easily separable radioactive material in cracks, crevices, and other recesses.

In more technical language, the specifically licensed person who smelts scrap or initially transfers smelted alloys must be able to certify to any interested person that the smelted alloy initially transferred has been smelted, sampled, and analyzed using procedures sufficient to provide reasonable assurance that the technetium-99 or low-enriched uranium are minor constituents less than 5 parts per million or 17.5 parts per million, respectively, of representative samples of billets, ingots, or other smelted alloy products.

Your second question asked what is meant by "... has estimated that less than one health effect would result from the radiaticn doses received from recycled uranium enrichment plant scrap." The quoted statement summarizes the end result of a ccmprehensive, detailed estimation of the relative risks of cancer to the population exposed to radiation from technetium-99 and Icw-enriched uranium during one year of unrestricted use of smelted alloys. These risks are -

believed to be representative of those for a multitude of products made of smelted alloy. The estimate is that the risk of causing any cancers at all in the total exposed population is 0.003, i.e., less than one. This means that it is highly unlikely that recycled encichment plant scrap would cause even one cancer in one person in the total U. S. population.

I trust that this discuss-ion has resolved your concern about our attitude towards the health of peop.le.

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s e DEC 2 1950 In response to your requsst to be kept informed about this regulation, I am enclosing a copy of the proposed rule published in the Federal Register on October 27, 1930, and a copy of the draft envircnmental impact statement preparad in connection with the prepcsed rule. These documents contain detailed discussions of my responses set out above.

Radioactive raterials appear in many products other than smelted alloys.

To help place our proposal in perspective, I am also enclosing a copy of a book on radioactivity in consumer products.

You should find the book both useful and interesting.

Sincerely, C sac f akv ames J. Henry Transportation & Product Standards Branch Office of Standards Development

Enclosures:

1.

45 FR 70874 2.

NUREG-0518 3.

NUREG/CR-0001