ML20202F908

Forwards Comments on EPA Proposed Standard for U Fuel Cycle Facilities

ML20202F908
Person / Time
Issue date:	07/08/1975
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Mattson R NRC OFFICE OF STANDARDS DEVELOPMENT
References
NUDOCS 9902040204
Download: ML20202F908 (3)

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A E 1975 l

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i R. J. Mattson, Acting Director, Division of Siting, Health and j

Safeguards Standards, SD I

COMGDfTS ON EFA'S PROP 0gED STANDAkD FOR U-FUEL CYCLE - 40 CFR I

FAltr 190 l

We have reviewed EPA's proposed standard for the uranitsa fusi cycle facilities. Our comments on that propeeed standard are enclosed. We would appreciate participating in the final review of the consolidated NRC e-te on this proposed standard.

I a iginal.;icac' by DarrellG.Eisenhut Darrell Eisenhut Assistant to the Director Offica of Nuclear Raaetor Rigulation

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C0KTENTS ON EPA PROPOSED STANDARD FOR U-FUEL CYCLE - 40 CFR 190 1)

It is premature to propose this rule for implementation now. There i

are several aspects which need further clarification before the exposure limits are established. A delay is not critical, since NRC ALAP criteria are in effect and the potent'ial reduction of ad-verce_ impacts from the nuclear industry which might occur in the absence of this standard is small for many years.

2) The EPA standard and the NRC ALAP criteria in Part 50 Appendix I relate to the same concerns, although with different scopes and approaches.

The EPA standard considers the bases from which Appendix I is derived, but there vas no specific consideration as to possible inconsistencies with the Appendix I criteria. There are several specific instances where nuclear plants (multiple units) can meet Appendix I and not meet the EPA proposed rule (eg, 4 units on a site at 10 mrem /yr/ unit for an organ dose from only I

the liquid release can exceed the EPA limit of 25 mrem /yr for the whole fuel cycle).

In addition, the EPA limit includes direct radiation (shine) not included in Appendix I.

It is not appropriate that EPA issue e standard that is immediately in direct conflict with the NRC criteria, especially when the EPA rule is issued for i

implementation by NRC.

3)

It is also premature to issue this rule when it is unclear to the i

originating agency (EPA) as to how the inplementing agency (NRC) can put these standards into effect.

Before enactment of this rule there is need for a careful consideration as to whether and how the standards are to be useful: they must be susceptible to effective administration by operators of nuclear facilities and to meaningful licensing review and inspection / enforcement by our staff. Applicable NRC regulations and licensing and inspection /

i enforcement procedures should be drafted and examined as to their effectiveness.

This effort should be given substantive support by all affected NRC groups and coordinated with EPA.

4) Specific problems in application of the standards can be postulated for their application to an individual who spends parts of a year near several different fuel cycle facilities.

If the environmental doses from these facilitics are non-uniform with time, an individual theoretically could receive a dose in excess of the standard, even though the average yearly releases from the facilities may be within the standard's guidance.

The actual determination of the dose really incurred by an individual poses great technical and administrative difficulties.

If implementation of the EPA rule requires verifications of doses actually incurred, the practicality of the rule is dubious.

Such issues need careful resolutic, before this rule is adopted.

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'o k 5) 8 190.01 is not readily clear that the proposed

.uards apply to all components of the uranium fuel cycle '

.ept mining) collectively, and are intentionally nons*

.ic as to particular plant, area, etc.

6) a 190.02 (a) and (b) are not clear whether such exposures as those from radiographic sources and operations (in support of uranium fuel cycle operations) would be included in this regulation if the radiography was performed in construction, maintenance, repair, etc. of any component of the fuel cycle.

7) 8 190.02 (j) excludes the skin and cornea.

Does this mean that these anatomical components are not covered by the proposed standards?

"Whole body" is not defined, and one is at a loss to allocate doses to these components.

8) a 190.02 (1) is confusing as to whether or not occupational and nonoccupational doses are additive for the purposes of the proposed standards.

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