ML20049K070
| ML20049K070 | |
| Person / Time | |
|---|---|
| Issue date: | 02/22/1982 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Long C HOUSE OF REP. |
| References | |
| FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70 45FR70874-3644, NUDOCS 8203290370 | |
| Download: ML20049K070 (2) | |
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FEB 2 : 82 T2 F8 24 Ao *2 1-3 The Honorable Clarence Long
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United States House of Pepresentatives
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20515
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Cear Congressman Long:
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The following information is provided in response to your inquiry of February 8,1982, concerning your constituent Mrs. Rene A. Lambert, and her interest in the proposed amendments to the fluclear Regulatory Commission regulations to exempt from regulations smelted alloys containing residual contamination of certain radioactive materials.
Mrs. Lambert's remarks are in response to a rulemaking originally undertaken by the Comission at the request of request of the Departnent 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 equipnent at DOE's uranium enrichment plants.
This scrap metal is sometimes contaminated with small anounts 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 Commission 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 exempt minute quantities of spacial nuclear material from its licensing requirenents if it finds that a licensing exemption "will not constitute an unreasonable risk to the common defense and security and to the health and safety of the public."
We would like to emphasize that under the proposed amendments persens who smelt scrap contaminated with technetium-99 or low-enriched uranium or who are l
the first transferors of such smelted alloy would not be exempt from licensing l
requirements.
Such persons would be under license and would'be required to submit a description of the decontamination and snelting procedures and OS/O sampling and analytical procedures to be used. This would assure that the sj snelted alloys subsequently to be used under the exemption meet the proposed
/p naxirum contamination limits.
It also should be noted that the scope of the exemption is narrow pemitting w SMh only the technetiur>99 and low-enriched uranium as the contaminants. Contami-nants such as plutonium, high-enriched uranium ce other transuranics are not included in the exemption. The Tc-99 and low-enriched uranium would be minor constituents (less than 5 parts per million (ppm) and 17.5 ppa, respectively) l of represbntative samples of smelted alloys.
The resulting levels of contamination would be at or below those of nany products co nonly in use which contain traces of unenriched uranium. For
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B203290370 820222 PDR PR 30 45FR70874 PDR A
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raking false teeth, has been found to contain fron 10 to 990 pen uranium.
The HRC upper limit for uninportant quantities of unenriched uraniun. is 500 ppa.'
There is essentially no difference in the nature of the radioactivity emitted from this unenriched urantua and the low-enriched uranium being considered.for exemption.
The HRC staff has prepared a Draft Environmental Impact Statement (EIS) in support of the proposed rule.
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 snelted down and resold for in excess of $40 million.
Further, energy savings from recycle have been estinated at the g
equivalent of about E
170,000 barrels of crude oil or 30,000 Mg of coal.
By E
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.
c This neans that it is highly unlikely that the
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recycled alloy would cause even one cancer in one person in the total U.S.
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population.
Hotice of the proposed rule was cade in the Federal Register and the press on i
Octcher 27, 1980.
The comment period expired December 11, 1980. Over 3,300 i
public caaments were received.
Comments will be reviewed and addressed in the 5
Final EIS before any decision is made by the Commission on promulgation of a y;
final rule.
Please be assured that the NRC is actively considering Mrs. Lanbert's remarks alo'ng with all other comments received prior to the comment period expiration I
ij da te.
When the Comnission has completed its review a report will be issued.
[E We-hope this reply is responsive to your concerns. Should further information on the subject be required, please contact my office.
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Sincerely, II
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lis:;p Carlton Kannerer, Director 7::6 Office of Congressional Affairs F
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MEMBER:
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DISTRICT OTTICE
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'A Mr. Joseph Hendrie f{:=..:1 Chairman.
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Nuclear Regulatory Commission 1717 H Street, N.W.
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Washington, D.C. 20555
Dear Mr. Hendrie:
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I am writing on behalf of Mrs. Rene A. Lambert, 1710 Delp Road, Whiteford, f.hhh Maryland 21160.
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Mrs. Lambert has been in touch with me concerning her strong objection
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to the proposed deregulation of contaminated scrap metal.
I am enclosing 5E5's l
a letter from her in which she states her belief that the intent of the I
Nuclear Regulatory Commission was to protect individuals, and deregulation e._..__
k is inconceivable.
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I should appreciate your giving Mrs. Lambert's views every possible b[
consideratien prior to any final decision in this matter.
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.2 I look forward to hearing from you.
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' arm regards,
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17 7b I 1710 Delp Road sihiteford, L'd. 21160 Janusry 23, 1981 Ur. Nunzio J. Falledino, Chairman U.-S. Nucleer Regulatory Co= mission fe-
- schington, D. C. 20555 d it;,
Dear l'r. Fallsdino:
is to come ~before the N. R. C. ne:xt month.I understand the deregulatio'.
To consider such deregulation is incccceiveble.
I am voicing (loudly) my objections os the prenice the N. R. C's, first i
consideration is regulatory... for the protection of others.
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I beg you, do not consider this propercl.
It is not $m the best
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