ML20045F684
| ML20045F684 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1993 |
| From: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Burnett J ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| REF-WM-3 NUDOCS 9307080237 | |
| Download: ML20045F684 (2) | |
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5 NUCLEAR REGULATORY COMMISSION 5
s WASMGTON, D C. M554m JIJN 2 41993 Ms. Jamie Burnett i
U.S. Environmental Protection Agency 401 M Street, SW (6603J)
Washington, DC 20460 l
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Dear Ms. Burnett:
The May 17, 1993, letter, from Ms. Barbara Hostage and Mr. Nicholas Lailas requested comments on the Environmental Protection Agency's (EPA's) draft 3
Issues Paper on Radiation Site Cleanup Standards dated May 5, 1993. We recognize the tight schedule under which this Issues Paper is being developed and, in this letter, are transmitting comments that we believe are most critical. We intend to make available our comments of a more editorial or specific nature at our meeting currently scheduled on July 1, 1993.
4 The major comments we offer for your consideration are as follows:
(1)
The fact that EPA is coordinating its efforts with the Nuclear Regulatory Commission is referred to in the introductory section, but the significant level of cooperation that the EPA has provided to NRC on our Enhanced Participatory Rulemaking is not mentioned. We believe that the introductory section of the EPA Issues Paper should discuss NRC's l
Enhanced Participatory Rulemaking process and EPA's cooperative role in some detail.
This section could also briefly mention the alternative i
regulatory approaches and other major issues that were addressed at the seven workshops.
Including this information will hopefully address any ambiguity caused by the parallel rulemakings of our two agencies.
(2)
In the context of comment (1), to the extent that EPA' believes that the regulatory alternatives addressed in NRC's Issues Paper are viable, these alternatives should also be addressed in EPA's Issues Paper.
If any alternative is not considered viable, or if others should be addressed, the reasons should be stated.
In this regard, the continuum of regulatory options discussed in section 5 of your issues Paper i
presents, in our view, only two options: (a) a dose limit [ goal]
approach with three implementation options - Dose / risk [ goal], Table of Concentrations, and Table of Concentration and Pathway Models, and (b) a Cleanup Technology approach.
Yet Section 4 discusses " Cleanup to Detection Limits or Lower" and " Cleanup to Background". NRC has also
.i considered " dose / risk limit" and " return to background" approaches that should be covered by the EPA Issues Paper if our efforts are to be logically consistent.
It is also unclear to us how it would be possible to implement and enforce requirements that would be lower than detection limits.
it would appear that that option and the return to background l
approach would require a statistical process to be defined for determining if a site is indeed at background levels.
t (3)
In general, the discussions of regulatory approaches should be expanded 1 (),
to address implementation and compliance issues; specifically, what 2
information will be provided in guidance documents.
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4 JUN 2 41933 Jamie.Burnett,
(4)
Both agencies' rulemaking activities will be benefited if the i
terminologies used are as consistent as possible. Currently, NRC's Issues Paper considers both a dose / risk limit and dose / risk goal approach.
EPA's Issues Paper considers a dose / risk limit approach that
...would define the overall health-based goal to be achieved...".
In order to further understanding by all parties interested in both agencies rulemakings, we believe EPA should redesignate its dose / risk limit option as a dose / risk goal option.
If you have any questions, please contact me at 301-504-1298 or Bill Lahs at 301-504-2569.
Sincerely, W1 tnal Signca By 5
Michael F. Weber, Section Leader Regulatory Section Decommissioning and Regulatory Issues Branch Division of Low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards f
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