ML20125C453
| ML20125C453 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1992 |
| From: | De Planque E NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9212110197 | |
| Download: ML20125C453 (3) | |
Text
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...........w....a,,....aa i N0TATION V0TE RELEASED TO THE PDR i
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gESPONSE SilEEI m " " " " * " "trem .,
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- TO: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION 3
FROM: C0lHISSIONER nE PLANQUE
SUBJECT:
SECY-92-238 - FINAL TECHNICAL POSITION 0N ALTERNATE CONCENTRATION LIMITS FOR TITLE II
- URANIUM MILLS i
i APPROVED x<in part) DISAPPROVED x (in part) ABSTAIN i
Nor PARTICIPATING REQUEST DIsCL*3SION j
. COMMENTS:
See attached comments.
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i commissioner de Planque's Comments on SECY-92-238 t approve in part and disapprove in part, che guidance document,
' Final Technical Positjon on Alternate Concentration Limits for Title II Uranium Mills, but with some changes. The Final Technical Position on Alternate Concentration Limits for Title II l
Uranium Mills represents excellent work on the part of staff. It nhould be very useful to both staff and licensors.
My comments and changes are as follows.
- 1. The first comment pertains to page 28, under section 3.3.2.3.3, Evaluation of Environmental Hazards. The first paragraph directs the applicant to include in the evaluation
, of environmental hazards, potential adverse effects of the i
proposal, including potential for harm to endangered species i
or critical habitats. Consultation with the Fish and i
Wildlife Service (FWS) hppears to be optional. The Endangered Species Act requires consultation with FUS if an endangered or threatened species. 3 found on the site or is thought to inhabit the site. This la done not only to -
verify presence of an endangered or threatened species or critical habitat, but to verify effacts and to develop corrective actions to mitigate inpacts. The paragraph should be clarified accordingly, i
- 2. On page 27, under section 3.3.2.3.2, Evaluation of Health j Hazards and use of the risk level range of 1 x 10 4 to 1 x l 10" implies adcption of EPA's risk levels. This would be j precedent setting and is a major deviation from what we have endorsed under 10 CFR Part 20. The applicant is being asked to document that the proposed ACL is ALARA and also that it does not represent a significant hazard to human health or the environment. But the applicant la being told that the j
ACL must f all within the 1 x 10" to 1 x 10 range and that '
- it's even preferable that it be at the 1 x 10 4 end of the scale. This appears to be an unreasonable burden on the applicant. I would proposa that those references be deleted fron the text of the guidance itself, and Part 20 be l referenced for calculating doses to the public. As additional guidance, it would be preferable to place the EPA risk levels in an appendix to the guidance document, along with other risk ranges that may be appropriate for the l applicant to use, and to cleerly identify the agency that
- generated and adopted the levels and the purpose for which
! they are intended to be used.
I 3, Since NRC signed an EOU with EPA that states that both agencies "'will actively explore ways to harmenire risk j goals and will cooperate in developing a mutually' agreeable approach to risk' assessment methodologies for radionuclides'", I think it is incumbent upon NRC to begin
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' that dialogue in earnest with EPA through whatever mechanisms are'available.
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