ML20126A276

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Provides Comments on Linkage to EPA & Other Federal Agency Programs, Final Draft Comprehensive State Groundwater Protection Program Guidance
ML20126A276
Person / Time
Issue date: 12/10/1992
From: Weber M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Barles R
ENVIRONMENTAL PROTECTION AGENCY
References
REF-WM-3 NUDOCS 9212180110
Download: ML20126A276 (2)


Text

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. Robert Barles, Chief State Programs and Policy DEC 101992 Integration Branch Ground Water Protection Division Office of Ground Water and Drinking Water U.S. Environmental Protection Agency Washington, D.C.

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Dear Mr. Barles:

In response to your November 16, 1992 request, we have conducted a cursory review of the Environmental Protection Agency's description of how the Nuclear Regulatory Commission's groundwater protection activities can potentially be coordinated with State programs under Comprehensive State Groundwater Protection Programs (CSGWPPs). The enclosure provides our comments. We also recognize that much of this description comes from NRC's NUREG-1243 entitled

" Ground-Water Protection Activities of the U.S. Nuclear Regulatory Commission."

Because the short timeframe did not allow us to complete a fully coordinated review, we anticipate looking at this section in more detail as we review the final draft CSGWPP Guidance for States.

We anticipate providing comments on this final draft for your consideration by December 24, 1992.

Please contact me at (301) 504-1298 or Meg Harvey at (301) 504-2522 if you need further information.

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6 Michael F. Weber, Section Leader Decommissioning and Regulatory Issues Branch Division of low-Level Waste Management and Decommissioning Office of Nuclear Materials Safety and Safeguards

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COMMENTS ON EPA'S DESCRIPTION OF HOW NRC PROGRAMS CAN C0 ORDINATE WITH CSGWPPS OK

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NUCLEAR REGULATORY COMMISSION STAFF PRELIMINARY COMMENTS ON

" LINKAGE TO ENVIRONMENTAL PROTECTION AGENCY AND OTHER FEDERAL AGENCY PROGRAMS"

  • FINAL DRAFT COMPREHENSIVE STATE GROUNDWATER PROTECTION PROGRAM GUIDANCE DECEMBER 1992 Rewrite of first paragraph:

The Nuclear Regulatory Commission (NRC) ensures adequate protection of public health and safety, the national security, and the environment in the civilian use of nuclear materials. NRC's scope of responsibility includes regulation of nuclear power plants, fuel cycle plants, and the medical industrial, and research uses of radioactive materials.

Groundwater protection activities in the NRC occur within four primary program areas:

the Office of Nuclear Material Safety and Safeguards (NMSS), which is responsible for the licensing, inspection, and regulation of facilities and materials associated with the use, processing, transport, and handling of nuclear materials, the disposal of nuclear waste, and uranium recovery facilities; the Office of Nuclear Reactor Regulation (NRR), which carries out the licensing and inspection of nuclear power reactors, test reactors, and research reactors; the Office of Nuclear Regulatory Research (RES), which plans and conducts the Commission's research and technical and regulations development program; and the Office of State Programs, which administers the State Agreements Program and maintains liaison with States, local governments, other Federal agencies, and Indian Tribal organizations.

Regional Offices implement regulatory programs originating in the Headquarters Office.

In paragraph two, there are 29 NRC Agreement States.

Rewrite of last sentence in paragraph 2:

NRC designates particular regulatory requirements as matters of strict compatibility.

The Commission is currently evaluating generic implications of-compatibility issues.

Rewrite of last sentence in paragraph 3:

... the effects of NRC's protective measures address nonradiological impacts on ground water to the extent that the radiological impacts are controlled.

Rewrite of last sentence in paragraph 4:

In some cases, EPA standards have been applied on a site-specific basis to the remediation of contaminated sites to ensure adequate protection of ground and surface water resources.

Rewrite of third and fourth sentences in paragraph 5.

In decommissioning facilities that have been licensed to possess nuclear materials, State priority-setting under a CSGWPP could be considered in the assessment of whether a-site has been decommissioned to levels of radioactivity that allow release for unrestricted use.

Pending codification of radiological criteria for decommissioning, NRC applies a variety of guidance and criteria to determine whether sites have been sufficiently remediated so that they may be released for unrestricted use.

These criteria are applied on a site-specific basis, with emphasis, as appropriate, to ensure that residual contamination levels are "as low as is reasonably achievable" (ALARA).

State groundwater priories under CSGWPPs could be considered by NRC in its ALARA determinations.

NRC could also assess... Low-Level Radioactive Waste Compacts to site low-level radioactive waste....

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