ML20202D450
| ML20202D450 | |
| Person / Time | |
|---|---|
| Issue date: | 04/12/1973 |
| From: | Muntzing L Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| SECY-R-671, SECY-R-671-R, NUDOCS 9902010400 | |
| Download: ML20202D450 (7) | |
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SECY-R 671 April 12, 1973 POLICY SE_SSION ITEM y The Commissioners UPDATED STATUS OF AEC-EPA INTERF For:
Commissioner Background information preparatory t
Subject:
blems.
Purpose:
In the attached paper, an effort has beenhistorica j
d r understanding the Commission with a few relevant servational perspectives tu afford broa eof issue issues, along with Discussion:
and clarity in comprehension of these ith the AEC's a brief resume of the current statusEP ssly impact understanding of EPA's authorizefor im r duplicate AEC functions.
und on tae attempts A few comments are made by way of backgro lear boundary of Me %%r made when EPA was formed to draw a c 110 l functions of separation between the respective It E/r be M and EPA, respectively, and the principa A
f2d e noted.
A peged.u g /f interest to AEC clearly assigned to EPA arw be b gfg variety of added functional roles is no g' yg-$-12.t kN AEC-EPA prob'am by EPA.
The status of five particular current For each the relationships are discussed briefly.
onflict, or the of disagreement, the nature of the These issues ted.
f Populatior g>a. are; EPA's Development of Annual Assessme ay o
zs 8g 1 Exposure to Radiation Surveillarce dy
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EPA's Proposed Involvement in Onsite
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EPA's Establishment of S t)
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EPA's Involvement in Accident Consie a ons noted that the As incidental observations, i'
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characteristics and aspirativns of EPA's inherited 1
staff and laboratory personnel, plus the adopted organizational structure of EPA's Office of Radio-l logical Programs, may not be irrelevant to the In direction of EPA's expanded claim of functions.
environmental fields other than radiological, there are proper technological, developmental, surveillance, In the radiological field, and enforcement functions.
such aspirations encounter AEC's prior responsibility J
and authority.
1 Further substantial difficulties have been encountered through failure of EPA management to obtain staff An even observance to agreed on relationships.
larger problem arises by way of the uncoordinated and unpredictable relationship of EPA field offices to headquarters agreements with AEC.
There are useful and validly assigned functions that Recomendations:
EPA should address.
There should not be two responsible Federal agencies attempting to perform the same functions, and one responsible Federal agency should not be in the position of monitoring the performance, or of being monitored by another responsible Federal agency.
There should be full and free communication and flow of information between agencies as each performs its respective functions.
On these premises, the following conclusions and observations are made:
The separation at the boundary of licensed 1.
facilities that was intentionally defined in the order of formation of EPA should be reaffirmed--
and honored both literally and figuratively.
AEC will follow through with the present agreement i
2.
to collaborate with EPA in developing a limited number of typical " pathway models" by furnishing necessary onsite portions of field measurement data while EPA performs offsite measurements.
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OFFlM.IlSE DELY
.. 3.
For infor
.onal purposes AEC is willing for EPA staff acconpany AEC inspectors on a limited nur's of AEC inspections of licensees when this huuld be helpful to EPA in the performance of its appropriate functions.
4.
EPA in the development of " generally applicable environmental standards" should choose methods which they can support largely within their own resources.
AEC has serious doubts that the cost-risk benefit approach now being taken can be practically im-plemented by EPA.
A feasible alternate approach should be considered.
5.
The role that can be beneficially played by EPA in relation to reactor accidents is extremely limited; if there is any such role at all.
No advantage to EPA or to the progress of the Rasmussen study can be foreseen by EPA's becoming involved in this study; the study in fact would be disadvantaged by disruptions.
No useful contribution is being made by EPA's accident issue statements in individual licensing actions or in general actions.
The effect is detri-mental.
In its coments on environmental impact statements, EPA should be confined to issues and areas properly within the sphere of their assigncJ responsibilities.
Their comments have been con-tinuously broadened until they now cover wide ranging matters as, for example, the accident issues where they possess little in-depth technical competence.
6.
The Technology Division of EPA apparently exists mainly to provide comments on environmental impact statements.
A suggestion could be made that the functions of the EPA Technology Assessment Division and the Inspection Division (now " Operations") be reassessed.
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Drek 221
, The AEC-EPA interface pro'blems would be substantially improved by management discipline and control of staff and field offices.
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To be discussed with the Corlission prior to the l
Scheduling:
Commissioners' meeting with EP April 23.
I I
O; L. Manning Munt ng Director of Regulation
Contact:
Clifford K. Beck Extension:
7568 NOTE FOR MR. BENDER In view of the Commission-EPA meeting on this subject scheduled for April 23, this paper should be placed on the Policy Session agenda for April 18.
,d Lee V. Gossick l
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OmCIA1.!!SE KY l
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OFFHCHAL USE ONE""
l NO. OF COPIES DISTRIBUTION 11 Secretary 6
l Chairman Ray 2
Commissioner Ramey 2
Commissioner Larson 2
Commissioner Doub 2
Commissioner
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1 General Manager 1
Deputy Gen. Mgr.
2
' Exec.' Asst.-to Gen. Mgr.
4 General Counsel 1
Controller 2
Information Services 1
Inspection 3
Off. of Planning 6 Analysis 1
Asst. GM for Admin.
1 Director of Regulation 1-Deputy.Dir'. of Regulation 1
Asst. Dir. of Regulation 3
Dir., Off, of Admin.-REG.
6 Dir.,0ff.of Gov't. Liaison-REG.
1 Dir., Program Analysis-REG.
1 Dir.,0ff.of Tech. Advisor-REG.
r 3
Dir. of Regulatory Standards 7.
Dir. of. Regulatory Operations 1
Dir.,0ff.of Operations Eval.,RO 2
Director of Licensing 1
Dep.Dir.for Reactor Projects,L 1
Dep.Dir for Fuels 6 Mats.,L 1
Chf.0ff.of Antitrust 6 Indemnity,L 1
Chf.0ff.of Plans G Schedules,L 1
Dep.Dir.for Tech. Review,L o
1 Asst. Gen. Counsel for-L6R i
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UNITED STATES I
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L ATOMIC ENERGY COMMIS510N W ASH t NGTON. D.C.
20545 April 12, 1973
<a l
Chairman Ray Commissioner Ramey Commissioner Larson Commissioner Doub THRU: Director of' Regulation UPDATED STATUS OF AEC-EPA INTERFACE Background - Attempt-Upon EPA Formation to Draw a Clear Boundary _
An aggressive determination to acquire a participatory operational role in AEC's regulation of atomic energy was variously exhibited for several years by the Bureau of Radiological Health before a major portion of that staff As EPA was being formed, was shifted in 1970 into the newly formed EPA.
this existing friction and aspiration toward onsite operational was clearly recognized; hence, numerous conferences were held in attempts to draw a sharp boundary line between the new EPA agency and the AEC to eliminate any tendency to duplication for lack of clarity in the boundary.
Section 2.(6) of Reorganization Plan No. 3, by which EPA was formed, containc as one result of these efforts to establish a clear boundary the followinq limitation on EPA's assigned responsibility for establishing generally applicable environmental standards for the protection of the general environ ment from radioactive materials; namely, "As used herein, standards means limits on radiation exposures or levels, or concentrations or quantities of radioactive material, in the general environment outside the boundaries of_
locations under the coMtrol of persons possessing or usinia radioactive _
materi al s. "
(Underlining added.)
Thus, it was clearly understood by all the AEC partic standards in the offsite environment and no responsibility or authority of any sort within the boundaries of licensed sites or with A problems or issues.
The transfer to EPA of the total role of the FRC did not enlarge these particular functions.
i d dut
.The functions of interest to AEC which clearly lie within the ass gne of EPA include:
Preparation of an annual cumulative report on population exposure to 1.
radioactivity from all sources.
'2 Comission 1
Operation of the national offsite environmental radio 1F n. networks--
2.
milk,. water, tritium,. diet, etc.
.,9 to radiologic exposures.
3.
Advising the states on assorted matters reb l
Establishment of generally applicabl
.nvironmental standards for the L4.
protection of the general-environ.at.
Comenting within its area of responsibility on the environmental impact statements issued by the 'AEC in relation to licensing actions on proposed 5.
ruclear facilities.*
IAdditional Area' of Responsibility Claimed by EPA In a number of previous memos'the Comission has.been advised of EPA's persistent efforts to become operationally involved with AEC licensees,.to exercise duplicatory surveillance over AEC act'vities and to seek a participatorv role in some of AEC activities over and beyond the clearly appropriate functions SECY-R-650 of March 9,33, identifias some of these problem The transmittal on March 21, 1973, to the Commission on " Additional listed above.
In par-Information on EPA-AEC' Interface". supplies additional information.
. areas.
ticular, the March 1973 EPA ~" Draft Proposal for Coordinated AEC/ EPA' Efforts to Resolve Issues Concerning the Environmental Risk of Reactor Accidents" i
e seeing
. handcarried, unofficial) gives extensive insight into the extens ve ov r (role sought by EPA.* %
Status of Particular AEC-EPA Relationships Specific issues on which conflicts of one sort or another have or do exist are discussed briefly below:
EPA's' Development of Annual Assessment of Population Exposure to Radiatio 1.
EPA in the past has -insisted on an onsite role in verifying licensee data and even including AEC's independent audits of licensee data;.however, as of now EPA has agreed to accept effluent data from licensees as reported to AEC in accord with AEC monitoring guides, a for evaluating population exposures from licensed facilities.
- In!many of ;1ts coments on radiological matters, EPA has reg _!arly co
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on and raised questions about detailed technical de expertise; in. fact, EPA's staff have on occasions r L
on _ these areas on AEC impact statements.SECY-R 650, " Current Status o I
- Secretariat Note:
was discussed at Limited Attendence Session 3, Relationship,3.
March 15, 197 l,
memorandum is in the Record, Secretariat.
~Dr. Beck's March 21, 1973 L
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