ML20202F831
| ML20202F831 | |
| Person / Time | |
|---|---|
| Issue date: | 02/25/1975 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Train R ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 9902040187 | |
| Download: ML20202F831 (2) | |
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UNITED STATES 0
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Bonorable Russell E. Trs' 4u 431-St-apov N..
U. S. Environmental 2rotection Agency gg j
' Administrator j
Washington, D.C.
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Daar Mr. Train:
1 27, 1974, from the EPA Deputy l
This is in reply to the letter of December Assistant Administrator for Radiation Programs to the AEC. Director of I
Regulation requesting comments on EPA's proposed generally applicable standards for the -uranium fuel cycle'.
We note that' EPA's Federal Radiation Council radiation protection guidance All of the activities licensed by the Nuclear will remain unchanged.
Regulatory Commission are now and will continue to be carried out well within that guidance.
We recommend that before the proposed standards are issued, time be allowed
'for a decision in the proceeding now pending before the Nuclear Regulatory Co:xsission regarding the staff Proposed Appendix I to 10 CFR Part 50 to The define design objectives for effluent control'in light water regetors.
Atomic Energy Commission initiated, this rulemaking, and an exhaustive pro-ceeding vas conducted, including lengthy hearings with significantThe NRC participation by the public, industry, and government agencies.
The facts that-the will base its decision on the record of the proceeding.and that the record of the URC began operation on January 20, 1975,,
proceeding is technically complex and voluminous require that further tim We are advised that the Commission has be allowed for the final decision.
ii the matter under active consideration with high priority for an exped t ous
-decision.
We are pleased to have the opportunity to comment on the draft standard an We understand that the explain the 'importance of the NRC decision.
standards is the principal basis for the numerical limits in the EPA draftcost An orderly conclusion of the NRC rulemaking decision prior to publishing the EPA standards would allow the standards given level of exposure.
l to reflect the NRC's. findings as to the practicability of emission contro s.
The AEC also stated its intention to. issue nun:erical guidance on ALAP
_abjectives for other fuel cycle f acilities anAs of now some types of facilities future as operating experience is gained.
i erience on the in the uranium fuel cycle have little or no operat ng expIn these cases, co::ercial. scale.
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.xating limits is imprecise. Thus, it is inappropriate to establish
,.uerally applicable standards near the estimated operating capabilities of the technology and solely on the basis of projected cost effectiveness of emission controls.
We also note that the NRC decision on Proposed I
e' Appendix I will give definition to the as low as practicable concept and
=%, % ',r/'j thus influence the further application of the concept ' o fuel cycle t
facilities.
The staff has identified seve'ral specific areas where in its opinion the proposed EPA standard has been established too near or beyond the projected l
capabilities of the uranium fuel cycle technology. These are: a) for light water reactors, the adding of the dose contribution from direct and,
j scattered gamma radiation to the exposures from gaseou.s and liquid l
effluents; b) the inclusion of the blowing of tailings piles near operating l
uranium allis, and c) the proposed thyroid standard in the case of the l
milk exposure pathway from fuel reprocessing plants.
In all of these areas the incremental increases in the proposed standard, which would be required i
to provide for uncertainties in the practicability of emission controls for a developing technology, would be well within existing FRC Radiation Protection Guides.
The staff also believes that standards for the capture of Krypton-85 are premature at this time because the cost benefit justification requires the integration of very small individual doses over the entire world population without fully resolving the question of inter-national cooperation in Kr-85 capture.
Sincerely, t
f0 ee V. Gossick Acting Executive Director for Operations cc:
James T. Lynn, Director Office of Management and Budget l
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