ML20040G142
| ML20040G142 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1982 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Deconcini D SENATE |
| Shared Package | |
| ML20040G143 | List: |
| References | |
| FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70 45FR70874-3639, NUDOCS 8202110325 | |
| Download: ML20040G142 (2) | |
Text
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The Honorable Dennis DeConcini O
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Dear Senator DeConcini:
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. 0 v2 The following infomation is provided in response to your inquiryconcerning you
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Janua ry 26, 1982,
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s her interest in the proposed amendments to exempt from the Nuclear la tory (
Comission regulations smelted alloys containing residual contaminatio o
certain radioactive materials.
The rulemaking in question was originally undertaken by the Commission at the request of the Department of Energy and pursuant to a 1974 amendment (P.L.93-377) to the Atomic Energy Act (AEA) of 1954.
The rulemaking would pemit the recycling of scrap metal from discarded equipment at DOE's uranium enrichment plants.
This scrap metal is sometimes contaminated with small amounts of byproduct or special nuclear material resulting from the enrichment process.
This contamination cannot practically be removed but is considered too insignificant to constitute a radiation health or safety problem.
Until Congress amended the AEA in 1974, it was necessary for the Comission to issue a specific license for the possession of this type of radioactive material, no matter how small the quantity.
In amending the Act, Congress gave the Comission the authority to axempt minute quantities of special nuclear material from its licensing equirements if it finds that a licensing exemption "will not constitute an unreasonable risk to the comon defense and security and to the health and safety of the public."
.We would like to emphasize that under the proposed amendments persons who smelt scrap contaminated with technetium-99 or low-enriched uranium or who are the first transferors of such smelted alloy would not be exempt from licensing requirements.
Such persons would'be under license a'nd would be required to submit a description of the decontamination and smelting procedures and sampling and analytical procedures to be used.
This would assure that the smelted alloys subsequently to be used under the exemption meet the proposed
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maximum contamination limits.
It also should be noted that the scope of the exemption is narrow permitting only the technetium-99 and low-enriched uranium as the contaminants.
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nants such as plutonium, high-enriched uranium or other transuranics are not included in the exemption.
The Tc-99 and low-enriched uranium would be minor
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g of representative samples of smelted alloys.
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The resulting levels of contamination would be at or below those of many R
products coronly in use which contain traces of unenriched uraniun. Fcr O
yg example, most building materials centain some traces of uranium (granite, 4.7 2n rs '
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FEB 5 1982 raking false teeth, has been found to contain frca 10 to 990 ppm uranium.
The SRC upper limit for unimportant quantities of unenriched uraniun is 500 ppm.
There is essentially no difference in the nature of the radioactivity emitted froa this unenriched uranium and the low-enriched uranium being considered for exenption.
The NRC staff has prepared a Draft Environmental Impact Statement (EIS) in support of the proposed nale.
Without the exemption, thousands of tons of government-owned nickel, copper, iron and steel scrap would have to be disposed of as radioactive waste at substantial cost to the taxpayers.
If exempted, this metal could be smelted down and resold for in excess of $40 million.
Further, energy savings from recycle have been estimated at the equivalent of ab'out 170,000 barrels of crude u;l or 30,000 Mg of coal.
By comparison with these benefits, the risk of cancer from release and unrestricted use of the entire inventory of smelted alloy is estimated to be considerably less than one.
This means that it is highly unlikely that the recycled alloy would cause even one cancer in one person in the total U.S.
population.
Notice of the proposed rule was made in the Federal Register and the press on October 27, 1980.
The coment period expired December 11,1980. 0ver 3,300 public comments were received.
Comments will be reviewed and addressed in the Final EIS before any decision is made by the Comission on promulgation of a final nale.
We hope this reply is responsive to your concerns-Should further information on the subject be required, please contact my office.
Sincerely, cariten D erer Carlton Vammerer, Director Office of Congressional Affairs w,a,,Q. jfrc n;id
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