ML20050A039
| ML20050A039 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1982 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Specter A SENATE |
| Shared Package | |
| ML20050A040 | List: |
| References | |
| FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70 45FR70874-3648, NUDOCS 8203290571 | |
| Download: ML20050A039 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION
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Q( fl onorable Arlen Specter Doc m NUMBER PR-30, 32, 70, 150 9-A4 I
hry 'p'2 nited States Senate PROPOSED RULE (45 FR 7o874) 6g k
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Dear Senator Specter:
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N The following infonnation is provided in response to your recent inquty W concerning your constituent Gilda DeFerrari, and her interest in the proposed, amendments to the Nuclear Regulatory Commission regulations to exempt from regulations smelted alloys containing residual contamination of certain radioactive materials.
The rulemaking in question was originally undertaken by the Commission at the request of the Department of Enenjy and pursuant to a 1974 amendment (P.L.93-377) to the Atomic Enenjy Act (AEA) of 1954.
The rulemaking would permit the recycling of scrap metal from discarded ecuipment 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 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 special nuclear material from its licensing requirements 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 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 and 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 maxinum contamination limits.
It also should be noted that the sco)e of the exemption is narrow permitting only the technetium-99 and low-enricied uranium as the contaminants.
Contami-nants such as plutonium, high-enriched uranium or other transuranics are not included in the exemotion. The Tc-99 and low-onriched uranium would be minor constituents (less t1an 5 parts per million (ppm) and 17.5 ppm, respectively) of representative samples of smelted alloys.
The resulting levels of contamination would be at or below those of many products commonly in use which contain traces of unenriched uranium, for mest building materials contain some traces of uranium (granite, 4.7
- example, ppm; cement. 3.4 ppmt by-product gypsum,13.7 ppm). Dontal porcelain, used in Q 3&O W 020300 fl0 llh: h(g,M *k $
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' MAR 8 1982 making false teeth, has been found to contain from 10 to 990 ppm uranium.
The NRC upper limit for unimportant quantities of unenr.iched uraniun is 500 ppm.
There is essentially no difference in the nature of the radioactivity emitted.
from this unenriched uranium and the low-enriched uranium being considered for exemption.
The NRC staff has prepared a Draft Environmental Impact State. snt (EIS)' in support of the proposed rule.
Without the exemption, thousancs 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 inillion.
Further, energy savings fran recycle have been estiested at the equivalent of about 170,000 barrels of crude' oil or 30,000 Mg of coal.
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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. Over 3,300 public comments were received.
Comments will be reviewed and addressed in' the,
Final Els before any decision is made by the Commission on proylgation of a final rule.
1 We hope this reply is responsive to your concerns. Should further information on the subject se required, please contact my office.
Sincer y,
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/gffice of Congressional Affairs on Kammerer. Dire: tor O
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