ML20023B129

Responds to Questions Re Interface W/Epa.Epa Must Meet Statutory Responsibility of Setting Radiological Stds in Areas Covered by 10CFR20.302(c),since Section Already Deleted

ML20023B129
Person / Time
Issue date:	12/03/1982
From:	Bunting J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
REF-WM-3 NUDOCS 8212230138
Download: ML20023B129 (1)

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Ld DISTRIBUTION 406.3/MJS/82/12/02/0 tRet rn to WM, 623-SS WM s/f-

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406.3 DMattson MKearney MEMORANDUM FOR:

R. Dale Smith, Director JBMartin Uranium Recovery Field Office REBrowning PDR FROM:

Joseph 0. Bunting, Jr., Chief Licensing Process and Integration Branch

SUBJECT:

INTERFACES WITH EPA We have the following responses to your questions in this area:

Question:

Should NRC delete S20.302(c) as no longer appropriate?

Response

That section already has been deleted in the draft rulemaking being prepared by Research in its revision to Part 20.

Mary Jo Seemann has worked with Walt Baker and Bob Cool on this activity.

Question:

Is a MOU needed and would it serve a worthwhile purpose?

Response: What is needed is not an MOU for standard setting but for EPA to meet their statutory responsibility of setting radiological standards in this area. The exception to this concerns the problem of overlapping jurisdiction for low-level radioactive waste that also contains hazardous properties as defined by the Resource Conservation and Recovery Act (RCRA).

The possibility exists that EPA's RCRA program and NRC's 10 CFR Part 61 regulations create a problem of overlapping jurisdiction for this type of waste. Mary Jo has worked with Paul Lohaus and has met with EPA staff to discuss the need for resolving this problem through an interagency MOU. A Task Form on future activities relating to an EPA /NRC MOU has concurrence from Paul Lohaus and has been submitted to Mr.

Browning.

I will be glad to discuss any of these points with you.

_s /

Joseph 0. Bunting, Jr., Chief Licensing Process and 8212230138 821203 Integration Branch PDR WASTE WM-3 PDR

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