ML20214N048
| ML20214N048 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/1986 |
| From: | Still N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Zwilsky B TECHNASSOCIATES, INC. |
| Shared Package | |
| ML20210Q655 | List: |
| References | |
| FRN-49FR46425, FRN-51FR24697, RULE-PR-40 AB56-1-01, AB56-1-1, NUDOCS 8609160054 | |
| Download: ML20214N048 (8) | |
Text
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[ 0 UNITED STATES
[
5 t kE NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20655
%, . . . . . p 9/4/86 MEMORANDUM FOR: Bobby Zwilsky Tech. Associates THRU: Jim McKnight Division of Technical Information and Document Control, ADM FROM: Nancy Still Division of Waste Management, NMSS
SUBJECT:
REQUEST FOR CHANGES TO DCS TO MEET REGULATORY HISTORY REQUIREMENTS We request your assistance with the following items in our effort to meet tne agency's regulatory history requirements for our rulemaking effort, 10 CFR 40, Uranium Mill Tailings Regulations: Groundwater Protection and Other Issues, published as a proposed rule 7/8/86, 51FR24697, Indicator No. AB56-1.
- 1. Add the Indicator No. AB56-1 to all records on the enclosed accessions list (Enclosure 1).
- 2. Please process all documents (packaged as Enclosure 2) through DCS, including AB56-1 in the record. These documents can then be forwarded directly to PDR- we do not require the copies back for oursubjectfiles.
- 3. Upon completion of the above requests, please send a complete accession listing of AB56-1 documents to me.
Thank you for your cooperation.
dHf
- Nancy Still Division of Waste Management, NMSS
Enclosures:
As stated 0609160054 060904 4 51 24697 PDR 4
O" yern%4#
THIS DOCUMENT WAS PRODUCED 8Y THi U.S. NUCLEAR REGULATORY COM418810 DOCUMENT CO.1 TROL SYSTEM OPERATED BY TECHNASSOCIATES, INC.
UNDER CONTRACT NO NRC=10-84-212 FOR THE O!V!8!0N OF TECHNICAL INFORMATION AND 00CUC
~
OPPICE OF ADMINISTRATION k
7/22/86 PAGE 1 U. S. NUCLEAR REGULATORY COMMIS$10N OCS PARTIAL RECORD FORMAT REPORT 8501070265 Comments on proposed rule 10CFR40 re plan to Incorporate portions of EPA 40CFR264,Suoperts F & K rules in NRC regulations. Recommends change in wording to allow 500 meter Buffer zone around teiltngs facility.
MICKS,F.D. Petratomics Co. (formerly Getty/Petretemics Co.)
y' FROM:
TO: Docketing & Services Branch ISSUED: 840920 AVAIL: POR upp. DOCUMENT TYPE: CLVTN FPAC 8501070265 TASK 00!D: 49FN#6425 001 FORMAL REPT NO:
DOCKET NO: FICHE: 28204 294 28204 297 RIOS: 03100 8501070323 Comments on proposed rules 10CFR40 re mill tailing regulations. eleting or modifying prescriptive requirements for std desi -
features not recommended.
FROM NEMETH=,E. Ecology / Alert To uocketing & Services Branch
/ !$3UED: 841229 AVAIL: P0R 2pp. DOCUMENT TYPE: CLZTN FPAC 8501070323 TASK 00!D 49FR46418 001 FORMAL REPT NO:
DOCKET NO: FICHE 28202 092 20202 093 RIOS: 08100 8501080404 Requests. extension to 850301 to comment on proposed rule 10CFR40 re U mill tailings regulations, groundwater protection & other issues. .
. FgoM STAUTER,J.C. Kerr=McGee Corp.
Office of the Secretary of the Commission TO: CHILK,S.J.
ISSUED: 850103 AVAIL: P9R 1p. DOCUMENT TYPE: CLVTN FPAC: 8501080404 i
TASK 00!D 49FH46425 FORMAL REPT NO 1
00CnET NO: FICHE: 28231 038 28231 038 RIOS OS100 8501080129 Requests extension of time to comment on proposed rule 10CFR40 re U mill tailings regulations.
FROM: 80GGS,L.A. American, Mining Congress TO: CHILK,3 Office of the See-stary of the Commission ISSUED: 850104 AVAIL: PUR 2ep. 00CUMENT TYPE: CLPTN FPAC 8501080129 TASK 00!03 49FH46418 FORMAL REPT NO:
DOCKET NO: FICHE: 28232 307 28232 308 RIOS: 05100 8501080415 Requests extension of comment due date on proposed rule l 10CFR40 re conformance of NHC mill licensing & groundwater stds to EPA active site radiological stos.
FROM 80GOEN,G. Western Nuclear, Inc. (sues. of phelps Dodge Corp.)
, TO: CHILK,S.J. Occketing & Services Granch i
ISSUED: 850104 AVAIL: POR 1p. DUCUMENT TYPE CLVTN FPAC 850100;415 TASK OD!O 49FH40418 FORMAL REPT NO DOCKET NO: FICHE 28230 223 28230 223 R103: OS100 L .-
7/22/86 PAGE 2 U. 3. NUCLEAR REGULATORY COMMISSION I
DCS PARTIAL RECORD FORMAT REPORT 8501140302 Comments on proposed rules 10CFR40 re U mill tailing regulations. Proposed changes fail to meet requirements laid down my Congress for NRC conformance.
FROM: YEAGEN,0.6 Sierra Club TO: vocketing & Services Branch TSSUED: 850110 AVAIL: POR 2po. DOCUMENT TYPE: CLZTN FPAC 8501140302 TASK 0010 49FR4e425 003 FORMAL REPT NO:
00CAET NO: FICHE 28360 125 28360 126 R!DS: 0S100 8501240447 Comments on proposed rules 10CFR40 to amend NRC regulations to conform to EPA 40CFR192 stds & advanceo notice of proposed rulemaning re groundwater protection provisions.
NHC & Agreement States should review changes to stds.
f FROM n!RNEH,N.P. Wasnington, State of TO: NUS$84UMER,0.A. Assistant Director for State Agreements Programs ISSUED: 850110 AVAIL: POR 3pp. DOCUMENT TYPE: CLSTN FPAC 8501280447 TASK 0010: 49FH4618 013 FORMAL REPT NO DOCKET NO: FICHE: 28564 053 28564 055 RIOS: 08100 8501150366 Comments on proposed rules 10CFR40 re conformance of NRC U mill tailings regulations to EPA stda. Substantive requirements of Solid Weste Olsposal Act snould be .
pcrophrased to apply directly to nill taillnes situation.
j' FROM dLANCHARD,8 Interior, Dept. of , .
TO: Office of the Secretary of the Commission ISSUED: 850111 AVAIL: p0R 2pp. DOCUMENT TYPE: CLOTN FPAC: 8501150366 TASn 0010: 49FH46418 009 FORMAL REPT NO:
DOCKET NO: FICHE: 28386 141 28386 142 RIOS: OS100 8501230394 Comments on proposed rules 10CFR40 re U mill tailings.
0; poses rule. Single unified set of NRC regulations e incorporating comparaole portions of Solid Waste Disposal Act, appropriate.
FROM LACKER,0.K. Texass State of TO: Occketing & Services Bronch ISSUED: 850111 AVAIL: POR 3po. DOCUMENT TYPE: CLSTN FPAC: 8501230394 TASK ODIO: 49FHoo418 011 FORMAL REPT NO:
DOCKET Not FICHE: 28512 171 28512 173 RIOS: 05100 8502050474 Comments on proposed rule 10CFR40 re incorporating EPA requirements into NRC regulations for U & thorium. EPA regulations should me rewritten to include site-specific fcetor regulated oy NRC.
FROM: DEGu!RE,M.F. Dawn Mining Co.
TO: Jocketing & Services Branch ISSUED: 850124 AVAIL: POR 40p. DOCUMENT TYPE: CLGTN FPAC: 8502050474 TASK 00!D 49FN#6425 007 FORMAL REPT NO:
l 00ChET NO: FICnt 28724 032 28724 035 R103: OS100
7/22/86 PAGE 3 U. S. NUCLEAR REGULATORY COMMISSION DCS PARTIAL RECORD FORMAT REPORT 8503080096 Comments on oroposed rule 10CFR40 re incorporation of EPA groundwater provisions into NRC regulations on U mill tailings. Commission decision to solit rulemaking activities into two stages justitiaele.
FROMt FORT,0 New Mexico, State of j
T0 Ch!LK,3 Office of the Secretary of the Commission ISSUED: 850226 AVAIL POR 6po. DOCUMENT TYPE: CLSTN FPAct 8503050096 TASKI 0010 49FHoo425 011 FORMAL REPT NO 00CnET NO: FICHE 29275 062 29275 067 RIOS: 05100 8503070407 Comments on proposed rule 10CFR40 re amenos to Commission U mill tailings regulations. Commission should move expeditiously to implement LPA stds & protect human health
& environ from nonradiological nazards.
FROM MARTIN,J.S. Environmental Defense Fund TO: Docketing & Services eranch ISSUED: 850224 AVAILt POR 17po. DOCUMENT TYPE: CLZTN FPAct 8503070407*
TASnt 0010 49FH46425 008 FORMAL REPT Not DOCKET Not FICNE: 29255 211 29255 287 N!DS: 08100 8503070407 01 Comments on proposed rule 10CFR40 re amends to Commission U mill tailings regulations. Commission should move expeditiously to implement EPA stds & protect human health ,
& environ from nonradiological hazards.
FROMs MARTIN,J.6 Environmental Defense Fund .
T08 uocketing & Services Branch ISSUED: 850228 AVA!La POR 17po. DOCUMENT TYPE: CLZTN FPAct 8503070407*
TASK 00!D 49FH46425 008 FORMAL REPT NO:
DOCKET Not FICHE 29255 211 29255 287 RIOS8 08100 8503070407 02 Comments on proposed rule 10CFR40 re amends to Commission U mill tailings regulations. commission should move expeditiously to implement LPA stds & protect human health
& environ from nonradiological hasards.
FROM MARTIN,J.S. Environmental Defense Fund Tot pocketing & Services $ ranch 17pp. DOCUMENT TYPE CLZTN FPACs 8503070407*
IS$utot 850224 AVA!La POR TASKt 00!D 49FHue425 008 FORMAL REPT NO:
FICHE 29255 211 29255 267 RIOS 03100 DOCKET NO 8503070412 Forwards response to several questions ce implementation of EPA 40CFR192 stas by Agreement States, i PROM NUSS84UMER,0.A. Assistant Director for State Agreements programs T08 Texas, State of 831114 AVAIL: PJR 40o. DOCUMENT TYPE CLNTS FPAct 8503070407A ISSUED TASnt 0010 49FH46425 FORMAL REPT Not DOCAET Not FICHEt 29255 228 29255 231 R103:
i
7/22/86 PAGE 4 U. 3. NUCLEAR REGULATORY COMMISSION DCS PARTIAL RECORD FORMAT REPORT 8503070412 01 Forwards resoonse to several questions ce implementation of EPA 40CFR192 stds by Agreement States.
FROM NUSS8AUMER,0.A. Assistant Director for State Agreements Programs Tot Touas, btate of ISSUED: 831114 AVAIL: PJR 49p. DOCUMENT TYPE: CLNTS FPAct 8503070407A TASnt ODIO: 49FH46425 FORMAL REPT NO:
00CMET Not FICHE 29255 228 29255 231 RIGS 8 8503070415 Provides. sentence in Item 4 inadvertently omitted frow 831114 submittal re implementing EPA 40CFR192 sta. EPA has no role in implementing sto.
FROM8 NUSSSAUMER,0.A. Assistant Director for State Agreements Programs Tot Texas, State of ISSUED: 831215 AVAIL POR lo. DOCUMENT TYPE: CLNTS PPAC 85030704078 '
TASKt 00!08 49FH46425 FORMAL REPT Not DOCKET Not FICHE 29255 232 29255 232 RIOS ,3 8503070415 01 Provides sentence in Item a inadvertently omitted from 831114 submittel re inolementing EPA 40CFR192 std. EPA has no role in implementing stu. .
. FROMt NUSSSAUMER,0.A. Assistant Director for State Agreements Programs Tot Texas, State of ISSUED: 831215 AVAIL: PuR to. DOCUMENT TYPE CLNTS FPAct 85030704078 TASMt 00!D 49FH46425 FORMAL HEPT Not 00CMET NO: '
FICHE 29255 232 29255 232 RIOS 8503070417 Discusses actions taken to resolve inconsistencies netween C0CFR192 & 10CFR40, Ara A.Haview of monitoring program cgainst enc) acceptance criteria to determine whether mods necessary requested.
FROMt SMITM,R.D. Uranium Recovery Field Office 708 Eamon Corp.
ISSUED: 84071U AVAIL POR 48pe. DOCUMENT TYPEt CLNTV FPAC 8503070407C TASK 00!04 49FH46425 FORMAL REPT Not DOCKET Not FICHE 29255 233 29255 287 RIOS 8503080323 Comments on proposed rule 10CFR40 re U mill tailings, grCundwater protection & otner issues. Supports comments su'mitted by American Mining Congress.
FROMt KENNEDY,E.E. Momestate Mining Co.
Tot CH1LA,S.J. accketing & Services Branch ISSUE 01 850228 AVAIL POR 10 DOCUMENT TYPEt CLGTN FPAct 8503080323 TASMt 00!0 49FHoo425 012 FORMAL REPT Not 00CnEt Not FICHE 29277 118 29277 118 RIOS 05100 i
7/22/86 PAGE 5 U. 3. NUCLEAR REGULATORY COMMISSION DCS PARTIAL RECORD FORMAT REPORT 8503050408 Comments on proposed rule 10CFR40 re U mill tailings regulations.NRC should undertake thorough & independent reevaluation of EPA Solla deste Disposal Act requirements in course of promulgating conforming regulations.
FROM DESANTI,R.J. Covinston & Burling TO: NdC = No Detailed Affi1Iation Given ISSUED: 850301 AVAIL: PuR 29po. DOCUMENT TYPE: CLLTN FPAC: 8503050408.
TASK 0010 49FN46425 009 FORMAL REPT NO:
DOCKET NO: FICHE: 29206 045 29206 141 RIOS: 03100 8503050412 Comments on proposed rule 10CFR40 re disposal of' tailings or
! eastes at U mills. Amends ao not so far enough in conforming to requirements of EPA stos & 1983 U Mill fallings Radiation Control Act.
FROM
- Covington & Burling j TO: NRC = No Detailed Affiliation Given ISSUED: 850211 AVAIL: POR 67pp. DOCUMENT TYPE: CLLTN FPAC: 8503050408A TASA 0010 49FH46425 FORMAL REPT NO:
DOCKET NO: FICHE: 29206 074 29206 141 RIOS:
4 8503050409 Comments on proposed rule 10CFR40 re U mill tailing PCgulations.NRC overstating complexity & magnitude of l 00 plying new EPA stds to licensees since new U mills not -
expected in forseasole future.
FROM 8 ERICA,0 Environmental Policy Institute .
CHILK,3 TO: Office of the Secretary of the Commission ISSUED: 850301 AVAIL: POR 10po. DOCUMENT TYPE: CLPTN FPAC 8503050409 TASK 00!D: 49FH46425 010 FORMAL REPT N0:
00CAET NO: FICHE: 29206 035 29296 044 RIOS: 0$100 8503120337 Comments on proposed rule 10CFR40 re U mill tailings 1
regulations. EPA concurrence not required in site-specific t
otternative to satisfy 4RC or Agreement State requirements for level of protection from hazards.
FROM HAZLE,A.J. Colorado, State of T0: Cocketing & Services Branch ISSUED: 850301 AVAIL: POR 420pp. DOCUMENT TYPE: CLSTN FPAC: 8503120337 i TASM 0010: 49FH46425 014 FORMAL REPT NO:
DOCKET N0: FICHE: 29318 214 29319 272 HIDS: 03100 8503120421 Comments on proposed rule 10CFR40 re U mill tailings groundwater protection & otner issues. EPA radiological &
nonraetological stds exceed agency jurisdiction.
- , FROM OVERTON,J.A. American Mining Congress TO
- CHILK,S.J. Office of tne Secretary of the Commission ISSUED: 850307 AVAIL: POR 12po. DOCUMLNT TYPE: CLPTN FPAC 8503120421 TASK 00!Os 49FH40425 013 FORMAL REPT NO:
00CNET NO: FICHE: 29316 009 29316 020 HIDS: 05100
r 7/22/86 PAGE 6 U. 3. NUCLEAR REGULATORY COMMISSION DCS PARTIAL RECORD FORMAT REPORT i
8503190097 Ceements on proposed rule 10CFR40 re 0 mill tailings 4 ccoulations on groundwater protection & ohysical stability.
Little difference exists notween EPA & NRC prescriptive i provisions to assure physical staoility of tailings piles.
FROMs HIRSCH,A. Environmental Protection Agency 70s CHILK,3 Office of the Secretary of the Commission ISSUED: 850308 AVAIL: POR 7po. DOCUMENT TYPE: CLOTN FPAct 8503190097 TASKt 00I0 49FH46425 015 FORMAL REPT NO:
DOCnET Not FIChEt 29406 313 29406 319 RIDS DS100 8503200430 Forwards supolemental info omitted from 850301 comments on proposed rule 10CFR40 re U mill tailings regulations.
J l FROMs aEAVER,K.L. Colorado, State of uocketing & Services Branch TO l ISSUED: 850314 AVAIL POR 11po. DOCUMENT TYPE: CLSTN FPAct 8503200430 TASKI ODIDI 49FR46425 014 FORMAL REPT N08 DUCKET Not F!ChEt 29427 318 29427 330 RIOS 0810D 8503260421 Forwards comments on proposed rule 10CFR40 re U mill toilings regulations & conforming NRC requirements to EPA stds. -
FROM ELKINS,C.L. Environmental Protection Agency -
j Tot PALLAGINO,N. Commissioners
!$3UE08 S50318 AVAIL POR 10. DOCUMENT TYPE: CLOTN FPAct 8503260421e l
TASK 0010 49FH46425 FORMAL REPT NO DOCKET Not FICHE 29505 033 29505 044 RIDS 05100 8503260425 Comments on proposed rule 10CFR40 re conforming NRC U mill toilines regulations to EPA stds.NRC reasons for conforming only portion of regulations to EPA stds insufficient.
FROM HIRSCH,A. Environmental Protection Agency Tot CHILK,3 Office of the Secretary of the Commission ISSUED: 850114 AVAIL: POR 4po. DUCUMENT TYPE: CLUTN FPAct 8503260421A TASK 00I0s 49FH46425 FORMAL REPT Not l l DOCKET N08 FICHE 29505 034 29505 044 RIOS:
8503280326 Comments on proposed rule 10CFR40 re U mill tailings.Any j rev to rule necessary to conforn to groundwater protection 1 requirements estaolished oy EPA should ensure that NRC
! maintains licensing flexioility.
I FROMt HUPHAM,J.W. Tennessee Valley Authority T08 vocketing & Services Branch
- !$3UED
- 850321 AVAIL: POR dos. DOCUMENT TYPE: CLUTN FPAct 8503280326 TASKt ODIDI 49FHoo425 016 FORMAL REPT NO:
DOCKET Not FICnEl 29552 061 29552 064 RIDS OS100 I
o
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- UNITED STATES ction: Davis. NMSS
- #o Tys: Dircks Philips
!" f, NUCLEAR REGULATORY COMMISSION 5 :i W ASHIN GTON, D.C. 20555 Roe Besaw "oj Rehm Shelton July 10, 1984 Stello DMartin,NMSS
'%*****M GCunningham Dragonette, OFFICE OF THE Minogue NMSS SECRETARY Kerp Felton MEMORANDUM FOR: William J. Dircks, Executive Director fo Operations 4
FROM: ;_ muel J. Chilk, Secretary
SUBJECT:
SECY-83-523/523A - PROPOSED AMENDMENTS TO URANIUM MILL TAILINGS REGULATIONS AND ADVANCE NOTICE OF PROPOSED RULEMAKING This is to advise you that the Commission (with Chairman Palladino and Commissioners Asselstine and Bernthal agreeing) has approved the following course of action in regard to
, these pape,rs,:
l' . 'The Commission agreed to address the question of whether the EPA mill tailings standard exceeds EPA's jurisdiction in a Implementation and Enforcement Policy Statement as described by Commissioner Asselstine in his comments (Attachment 1) . The Policy Statement should be finalized and forwarded to the Commission for approval and publication.
(EDO/NMSS) (SECY SUSPENSE: 8/13/84)
- 2. The Commission also agreed to issue the proposed rule and advanced notice of proposed rulemaking (ANPR) based upon the attached April 24, 1984 drafts with modifications as indicated (Attachments 2 and 3). In addition the above implementation and enforcement policy should be incorporated into the Statement of Consideration for both rulemaking actions.
The revised proposed rule and ANPR should be forwarded for signature and publication in the Federal Register.
(EDO/NMSS) (SECY SUSPENSE: 8/13/84)
- 3. The appropriate Congressional Committees should be g advised. (OCA) (SECY SUSPENSE: 8/13/84)
- 4. You should provide a copy of the proposed rule and ANPR to all affected licensees and interested parties and issue a press release.
l (BBe/OPA) (SECY SUSPENSE: 8/13/84) b l
Rec'd 0ff. EDO , ,p wouem ,. 't,";;;;;.?.t: s =
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Commissionier Roberts approved, but preferred the proposed rule and ANPR presented in SECY-83-523.
Action on this item Uas completed prior to Commissioner ,'-
Zech's Oath of Office.
Attachments:
As Stated ec: Chairman Palladino Commissioner Roberts Comr.iissioner Asselstine .
Commissioner Bernthal Commissioner Zech OGC OPE F
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1 3
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.L Comissioner Asselstine's Coments on SECY-83-5:3: ;
.I would address the question of whether the EPA mill tailings standard exceeds EPA's jurisdiction in the proposed Implementation and Enforcement Policy. I would also include the Implementation and Enforce-ment Policy in both rulemaking packages.
We should squarely face the jurisdictional question. I would suggest the following as an outline of the approach for addressing the' jurisdictional issue. A reasonable argument can be made that the Co6gress did n'ot intend that EPA develop the type of standar'd con'tained in 40 CFR 192. The . legislative history of the provision when it was first adopted by the Senate Environment and Public Works Comittee indicates an intent that EPA establish a general environmental standard for both radiological and nonradiological hazards. This legislative history indicates that EPA was not to establish such elements as cover i
requirements or liner requirements as part of its standard. However, the legislative history is contradictory in that some other statements indicate a Congressional intent that the EPA standard include such requirements.
Given these conflicting statements in the legislative history, the Comission is left with the question of whether the EPA standard consti-tutes a reasonable approach for mill tailings disposal. I conclude that the EPA standard is a reasonable approach in the circumstances. Unlike a power reactor or other operating facility, a mill tailings disposal
2 -
site is not intended to have a fixed and permanent site boundary.
Rather, the emphasis is on stabilization of the pile in a manner that will assure long-tem protection after institutional controls such as fences and guards are gone. In such circumstances, on-site and off-site distinctions appear to make little sense, and it is difficult to argue that the types of requirements adopted by EPA, including radon emanation limits, groundwater limits and groundwater control measures, are legally impemissible. I would therefore not question EPA's jurisdiction to adopt the types of requirements contained in 40 CFR 192, even though there is some basis for concluding that this may'not have been what Congress had in mind.
However, there is one aspect of EPA's standard that I believe clearly exceeds its jurisdiction, and we should say so. That is the requirement for EPA concurrence in NRC case-by-case deviations from elements in the EPA standard. In essence, the EPA position establishes a system of dual regulation that c1carly was not intended.by the Con-gress. Section 84 of the Atomic Energy Act, in my view, gives the NRC exclusive authority to allow case-by-case deviations from the EPA standard based upon a practicability detemination. I would suggest that we assert our exclusive jurisdiction in this area, point out that we believe EPA has exceeded its jurisdiction in this regard, and state that we do not intend to seek EPA concurrence on these case-by-case determinations.
IMPLEMENTATION AND ENFORCEMENT POLICY (NOTE: LANGUAGE WHICH MIGHT BE USED IN ONE OR ALL OF THE FOLLOWING: LETTERS TO LICENSEES AND AGREEMENT STATES, IN THE ANPRM ON FURTHER REVISIONS TO APPENDIX A 0F PART 40, OR IN A FORMAL POLICY STATEMENT.)
f h N$$ WA* d $ SM b'd
& h fW, THE COMMISSION BELIEVES THAT BOTH THE NRC AND THE AGREEMENT
~
ARE LEGALLY OBLIGATED UNDER SECTION 275D OF THE' ATOMIC ENERG TO IMPLEMENT AND ENFORCE THE EPA STANDARDS FOR URANIUM AND THORIUM MILL TAILINGS IN 40 CFR 192, SUBPARTS D AND E. SINCE THE -
EFFECTIVE DATE SPECIFIED IN THE EPA STANDARD WAS DECEMBER 6, 1983, THE COMMISSION BELIEVES THAT THE LEGAL OBLIGATION FOR NRC AND AGREEMENT STATES INCLUDES ENFORCEMENT IN THE INTERIM WHILE CONFORMING AND IMPLEMENTING RULE CHANGES ARE MADE.
l
N THUSjCOMMISSION LICENSEES ARE EXPECTED TO: 1) BE IN COMPLIANCE ~
WITH THE EPA STANDARDS IN 40 CFR 192 OR, 2) BE WORKING TOWARD COMPLIANCE, OR 3) SUBMIT PROPOSED ALTERNATIVES FOR COMMISSION 40 THE REVIEW IN COMPLIANCE WITH DATES ESTABLISHED IN CFRX192.
COMMISSION BELIEVES THAT LICENSEE PROPOSALS FOR ALTERNATIVES CAN BE AN IMPORTANT AND EFFECTIVE WAY TO HELP DEAL WITH THE PROBLEMS ASSOCIATED WITH IMPLEMENTING THE NEW EPA STANDARDS. NRC'S CURRENT REGULATIONS LACK NECESSARY IMPLEMENTATION FEATURES CALLED FOR IN
,THE PREAMBLE TO THE EPA STANDARDS AND CONTAIN PROVISIONS IN NRC 'IS UNDER,/
CONFLICT OR INC0ASISTENT WITH THE EPA' STANDARDS.
~
CONGRESSIONAL MANDATE TO MODIFY ITS RULES TO CONFORM TO EPA'S ,
STANDARDS' AND DEVELOP ' GENERAL REQUIREMENTS COMPARABLE, TO THE MAXIMUM EXTENT PRACTICABLE, TO REQUIREMENTS APPLICABLE TO SIMILAR HAZARDOUS MATERIALS REGULATED BY EPA UNDER THE SOLID WASTE .-
DISPOSAL ACT, AS AMENDED. THE COMMISSION EXPECTS THAT IT MAY REQUIRE SEVERAL YEARS TO FULLY MEET THIS DUAL MANDATE AND EXPECTS TO USE THE FLEXIBILITY PROVIDED BY SECTION 84 IN THE INTERIM TO CONSIDER AND APPROVE ALTERNATIVE PROPOSALS FROM LICENSEES.
SECTION 84 C PROVIDES NRC SUFFICIENT AUTHORITY TO INDEPENDENTLY AF? ROVE ALTERNATIVES SO LONG AS THE COMMISSION CAN MAKE THE REOUIRED DETERMINATION.
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.. .- N N* ' 14 M 'W T Requestor's ID:
JPK' '2 Author's Name:
DRAG 0NETTE K Decument Comments:
Draft FRN on Revised Appendix A to 10 CFR Part 40 e
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J3M FT~ +/z4 r4 NUCLEAR REGULATORY COMMISSION 10 CFR PART 40 Uranium Mill Tailing Regulations: Conforming NRC Requirements to EPA Standards AGENCY: Nuclear Regulatory Commission.
ACT:0N: Proposed rule.
SUMMARY
- The Nuclear Regulatory Commission (NRC) is proposing to amend its regulations governing the disposal of uranium mill tailings. The proposed rule changes are intended to conform existing NRC regulations to the regulations published by the Environmental Protection Agency for the protection of the environment from these wastes. This. action is -
N -m to comply.with the legislative mandate set out in the-Uranium Mill Tailings Radiation Control Act and the NRC Authorization Act for Ye ' "o
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FY 1983. u.c T >" -
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A b u c.< - wi ),ht ' .4 /.-
DATE: The comment period expires on (30 days after publication). Comments l
received by the Commission after that date will not be considered.
ACDRESSES: Mail comments to Secretary, U.S. Nuclear Regulatory Commis-sier., Washington, DC 20555, Attention: Docketing and Service Branch.
JePyer comments to Room 1121, 1717 H Street NW., Washington, DC between
. S:15 a.m. and 5:00 p.m. weekdays.
e 1
o m Raciation Control Act of 1978 (UMTRCA). Under Section 18(a) of Pub.
L.97-415, the Nuclear Regulatory Commission Authorization Act for fiscal years 1982 and 1983, the Commission was directed to conform its regula-tions to EPA's by no later than March 31, 1984, with notice and oppor-tunity for public comment. Today's proposal addresses that responsibility.
Previous Actions In keeping with Section 18(a) of the NRC Authorization Act, the Comission suspended portions of its October 3,1980 mill tailings regu-lations after notice and opportunity for public comment (48 FR 35350; August 4, 1983). As required by the Act, this suspension terminated autcmatically April 1, 1984. Those portions of the Commission's regula-tions which were suspended 'were those that were determined to be in conflict or inconsistent with EPA's proposed requirements. More specifically, the suspended portions were those that would require a
- major commitment or major action by licensees which would be unnecessary if (1) the EPA proposed standards were promulgated in final form without modification, and (2) the-Commission's regulations were modified to conform to the EPA standards. The objective of the suspension was to avoid a situation where a licensee or applicant might make a major comitment or take a major action which would be unnecessary or ill-N, acvised af ter subsequent rulemaking to ermanently ,odify the existing
-egulations on the basis of EPA's final standards.
The final EPA standards are very similar to those that were proposed.
Nevertheless, tne Commission has reconsidered the appropriateness of changes
.c A:pencix A to 10 CFR Part 40 in lign of the new EPA standards, and the 2
L /WO-01]
, need for additional supporting documentation. The changes proposed today
~
are more modest than the previous suspension.
Sco:e of This Proposal In addition to conforming its existing regulations to new EPA sta derds, under the provisions of the UMTRCA, the Commission has a further legislated responsibility; it must establish' general requirements, for the management of byproduct material, with EPA concurrence, which are, to the maximum extent practicable, at least comparable to requirements applicable to the management of similar hazardous material regulated by the EPA under the Solid Waste Disposal Act (SWDA), as amended. The Commission deliberated as to how best.to deal with these r. elated rule-
~
making ne'eds and decided'on the course of action resulting in this pro-posal and the accompanying ANPRM. This proposal addresses all the changes to the existing Commission regulations in Appendix A to 10 CFR Part 40 that can be legally promulgated without additional supporting documentation. Other changes to the Commission's regulations for mill l tailings management resulting from the EPA standard are the subject of i
the accompanying ANPRM.
The content of these two rulemakings also may be characterized in l
.erms of the need for EPA concurrence, although that was not the deciding factor. This proposal consists of modifications not requiring EPA con-currence, including conforming changes to existing NRC rules and incor-port.. ton of EPA requirements not deriving from the SWDA. Those modifi-cations that are the subject of the ANPRM accompanying this proposal certving from the SWDA require EPA concurrence pursuant to section 84 of /
tr.e 1.t:mic. Energy Act. Modifications accressed in the ANPRM include 4
1,7590-0 Q
. A;;endix A criteria. The due date originally set for submittals is past.
A new due date for revised submittals is not considered necessary.
(c) Add the following paragraph at the end: Licensees or applicants may propose alternatives to the specific requirements in this Appendix.
Such alternative proposals may take into account local or regional condi-tions, including geology, topography, hy'drology, and meteorology. The Com-ission may find that the proposed alternatives meet the Commission's requirements if the alternatives will achieve a level of stabilization and containment of the sites concerned,.and a level of protection for public health, safety, and the environment from radiological .and nonradio-
\ t logical hazards associated with such sites, which is equ extent practicable, or more stringent than the level which would be .
' achieved by the requirements of this Appendix and the standards pro.ulgated by the Environmental Protection Agency in 40 CFR 192, Sub: arts D and E.
Reason: The flexibility to propose alternatives to the Commission's and EPA standards was included in Pub. L.97-415 changes to the A:J. The added paragraph paraphrases the language in Section 84c. The added paragraph explicitly acknowledges the legislative intent and provides licensees and applicants the opportunity to propose alternatives as a routine er j
licensing matter. Licensees would have to provide g site-specific rational 4,
'x N to enaole 6WISIfan.LTo the recuired C -s14
- . a k-
.-. finding. This generic approach was taken instead of modifying individual criteria to provice flexibility. A generic .
asp-cach avoids tne chance of not identifying all areas where flexibility ay se neecec anc preserves the existing support for Appendix A. Admin-is , atively, a'ternatives are easier to process under an explicit crovision
! :.a exce;; ions to -uies.
l l 7 i
v;w .
j Regulations, Part 440, " Ore Mining and Dressing Point Source Category:
Eff'uent Limitations Guidelines and New Source Performance Standards, Subpart C, Uranium, Radium, and Vanadium Ores Subcategory," as codified on January 1, 1983."
Reason: These new paragraphs incorporate EPA requirements imposed under 40 CFR 192.41(d) and 40 CFR 192.32(a)(3), respectively.
- 8. Criteria 2, 7, 9, 10, 11, and.12~are not affected by the new EPA standards or editorial changes and no modification is proposed for any portion of those criteria.
Imcact of the proposed Amendments Compliance with Subparts D and E to 40 CFR Part 1 EPA's regula-tions is ,
lished requirement. Under ution 275d. of the Atomic
+' ommission believes that it is oblicated Energy Act of 1954, as' . ,
to implement and enf - ne new - ndar sofDecember6,1983(,
~.m..
the date t .ecame effective. This Ccmmission ity is being s
- - ed out on an ad hoc, case-by-case basis in individual lic .N s
actions.
The Commission's action in proposing these modifications to its regu-lations in Appendix A to 10 CFR Part 40 is to conform them to the new EPA standards. These changes are.for the. purpose of avoiding conflicts and irc:nsistencies, and for clarifying previously existing language se as
.c be compa.ible with the new requirements. The action propcsed re e :y
- ne Ccemissien is a consequence of previous actions taken by ine Cer;-ess a-: the'E?A, and is legally mandated in Section 275b(3) af ine 't: ':
Ere gy Act of '.954, as amended.
13
. - - m
'L#999o8Q Commission action in this case is essentially nondiscretionary in nature, and for purposes of environmental analysis, rests upon existing
. environmental and other impact evaluations in the following documents:
(1) " Final Environmental Impact Statement for Standards for the Control of Eyproduct Materials from Uranium Ore Processing (40 CFR Part 192),"
Volumes l'and 2, EPA 520/1-83-008-1 and 2, September 1983, and.(2) "Regula-tory Impact Analysis of Final Environmental Standards for Uranium Mill Tailings at Active Sites," EPA 520/1-83-010, September 1983, both prepared in support of Subparts D and E of 40 CFR Part 192, and (3) " Final Generic-Environmental Impact Statement on Uranium Milling," NUREG-0706, September 1980, prepared in support of Appendix A of 10 CFR Part 40. The Commission believes that these supporting analyses for the new EPA standards and the existing Commission regulations provide a more than adequate environmental review for the standards addressed herein, and that no additional impact v/
e analysis is warranted by the conforming actions proposed herein. The EPA engagedinandcompletedase++$ HU ened p d::i:':r :'v n; process with full con-i 1 h' s ; sideration of environmental concerns, and for the purposes of this rule-U making action, can be viewed as the lead agency. {.
PAPERWORK REDUCTION ACT STATEMENT This preposed rule does not contain a new or amenced information collection requirement subject to the requirements of the Paperwork Recu: tion Act of 1980 (44 U.S.C. 3501 et seq.). Existing requirements
-ere accroved by the Of fice of Management and Budget approva,1 number 1150-0020.
14
-e , .-- -. .r _
M:c=en: Naze:
- FRN :C CFR 40 ANPR h TT A t. y n ig n y it:ues:cr's ID: _
UPK 3 Author's Name:
CRAGONETTE K 3 :ument C:mments:
Ycu MUST return this sheet when submitting corrections
-f
/
m 7 r$ w 5 6c Y n 3 bnotos ce
?1od,*(.*ec) G .s ch c ess e/ in
( ?T. i. O of J~ ft t Y
'O S E O$
0?
enf $ntQ Cb Qn ($~
ab A
/
l
[7590-01) fol'owing closure. The EPA rule sets a performance standard for a limited
-ime period. In addition, the preamble to the EPA standard and the :
sup:orting environmental evaluation indicate that the EPA consciously c:nsidered the acceptability of relying on active maintenance to provide sta:ility following closure, and did not prohibit it. Rath r, the EPA standard requires that, for nonradiological hazards the need for active mair.tenance only be minimized. Al AC #s A pf en c b N f /4 / ly p r e $ M . Y s ans le n n cd fe {.% n c e an sc. /.'se msln fen A n c e. .
/ he Commission requests comments on whether it should delete or t:
modify additional provisions of Appendix A including prescriptive f requirements for specific design features which may not be necessary to <
O mee. the EPA standard, h ;;rti a .i, ,he C om.;;ica p;; tion: "Mther
+~ 9 4 1 % ,m; = = t~ m m-e e:e engt ,
rehted tr ; rx;i;n;- t'a.; - . s ~;p nd:d befer: /.p. i , 1-^ The prescriptive r'equirements in question include those for minimizing up-stream drainage area, siting where there is-good wind protection, relatively flat slopes, mandatory vegetative or rock cover, cobble size roc (, high quality rock cover, and rock armoring. The Commission also considered deleting.the prohibition on reliance on active maintenance,
.c ;' t :d modifying Criterion 3 mandating be ow l gra de disposal as the l
i prite option, and deleting the requirement for background radium concentra- -
tic 9s in cover materials. Relief from these retained provisions is vail- f acie through case-by-case proposals by licensees as noted in proposed N % W *sssick $ e < f;ks....;
-""*daa de Ct>sufficient
- W" dY E IS N accitiens to the intr 0 duction. A N ,
exi:ility in v* ew of the Commissiori's intent to consider alternative r::csais as rou .ine licensing actions?
c
, , [7H0-01]
- i. Subpart F:
40 CFR 264.91 Required programs 40 CFR 264.95 Point of compliance q
40 CFR 264.96 Compliance period h
O 40 CFR 264.97 General ground water monitoring requirements 40 CFR 264.98 Detection monitoring program l 40 CFR 264.99 Compliance monitoring program c
n Subpart G:
$9 ii.
40 CFR 264.117 post closure care and use of property
% 4 L 111. Subpart K:
8' 40 CFR 264.226 Monitoring and inspection (of impoundment liners),
E <, >s ippli. cable h 40 CFR 264.228 Closure and postclosure care, as applicable."
( d
.The above quotations from the EPA's October 7,1983 Notice serve to clarify the substance of EPA's standards, the respective agency respo(si-gE+ 1, bilities under the UMTRCA, and the nature and scope of the rulemaking the NRC is herein considering undertaking. The NRC has reviewed the language quoted and elieves it to be factually correct and a fair representation
- T 4 4
! 4 of the issues addressed.
9 h
5 II. Issues for Public Comment i3%
l The NRC requests public comment on the general question of how best to proceed to fulfill its responsibilities under the Atomic Energy Act, with res:ect to establishing SWDA-ccmparacle requirements for the marage-me r.: of miil tailings, to the maximum extent practicable. In this
- ntext, ::mmer.ts are re:uestec Or. :noices and decisions the NRC must l
l 8
, [/WD-01) make concerning issues and actions that are within its discretion.
Comments on the basic value, validity, lawfulness, or appropriateness of the EPA's SWDA regulations, the SWDA, or the UMTRCA are not requested.
A. Tentative NRC Approach for Ground Water Protection The NRC has developed a tentative approach to place SWDA-comparable requirements in its regulations, based on planning and development efforts conducted to date. This approach is tentative, and is made a part of this public announcement so efforts spent in providing public comment might be better guided. It involves the development of a block insert to NRC regulat.icns (either at the end of 10 CFR Part 40 or perhaps by crea 3 '
tion of a new Part 41) which wou'id contain the entire set of SWDA-comparable requirements. .
The insert would be organized in terms of design, operating, closure, and post-closure requirements, and would to the fullest extent feasib ,
N be a complete statement of the requirements without refer to EPA requirements in Title 40 of the Code of Federal Regulations. In this way, the requirements could be stated in a self-contained, unified manner in one place. Coverage would include at least the SWDA requirements already imposed by EPA (40 CFR 264.92-94, 264.100, 264.111, and 264.221),
and appropriate portions.of the SWDA requirements mentioned by the EPA explicitly as " examples of areas which NRC must address" (these include 40 CFR 264.95-99, 264.117, 264.226, and 264.228).
The insert being considered for prooosal by the NRC would likely
'nclude all of Subpart F (40 CFR 264.90-100), cue to tne close relation-sni; and 'ntercecendency o# :ne seca ate ;rovisions, and because all ou.
9
[7590-01)
- ~
40 CFR 264.90, " Applicability," is either imposed or mentioned as an example by the EPA.
The remainder of the EPA's SWDA regulations, including Subparts A (except Section 264.3), B, C, D, E, F, G, H, and K would be reviewed in developing a proposal to determine which of those requirements would need to be incorporated in NRC regulations to establish NRC requirements which are to the maximum extent practicable, at least comparable to the EPA's SWDA requirements for similar hazardous material.
In developing this proposal the NRC would distinguish between substantive requirements and EPA's procedural permitting requirements because it does not believe the UMTRCA mandate requires the NRC to adopt
~
any. portion of the procedural permitting aspects of EPA's regulations.,
The NRC's established procedures.for licensing, inspection, and enforce-ment would be used with respect to~ implementation. ,
B. Issues and Ouestions The NRC seeks public input with respect to all aspects of the ques-tion of how best to fulfill its responsibilities under Section 275 and 84 of the Atomic Energy Act of 1954, as amended, for protection of ground water. TheNRCalsoseekspubliccommentwithrespecttothefollowirk Nj s
issuesandquestions(Inprovidingpubliccomment,commeny[rsare recuested to provide the basis in fact for any opinions of fered or asser- ;
tions made):
- 1) Shouic tne SWDA-ccmoarable requirements to be placed in NRC regulattens :e exclicitly restated to neecisely duplicate EPA's language, cr snould sucstar.tive recuirements be :araphrased?
10
p m -u y
- 2) Should all of Subpart F be included? What should not be included?
- 3) What should be included in a hofhazardousconstituet.
for mill tailings to replace the 375-item long list in Appendix VIII to 40 CFR Part 261 referenced in 40 CFR 261.93? Should constituents not usually present or not present above trace levels be included? What
\ criteria should be applied to decid k what constituents should be included?
- 4) The NRC must establish SWDA-comparable requirements to the maximum extent practicable. In this context, what is practicable given current practice and the current state of technology?
- 5) Should NRC retain the basic sequence embodied in Subpart F where licensees who detect ground water contamination progress through a graduated scale of action, from detection monitoring, through compliance monitoring, and on to corrective action, with significant time delays 4
allowed between steps while plans and programs are being de'veloped, reviewed, and implemented? Would it be advisable, practicable or appro-priate to require, for example, that all NRC licensees have approved compliance monitoring programs that are automatically activated and implemented when needed?
- 6) Should the basic SWDA scheme for the timing and duration of a
" compliance" period, a " closure" period, and a " post-closure care" period i be maintained? What modifications, celetions, acditions should be made?
- 7) To wnat extent, how, and under what conditioris should leak i
detection systems under single-liner impoundments be allowed to fulfill
~
the recuirements for a detection monitoring program that otherwise recuires a men'toring well in the uppermost aquifer?
11
[7590-01]
- l
- 8) How detailed should NRC's regulations be, and what should and should not be required in areas such as well construction, sampling and sample analysis, determinations of annual average and seasonal background concentrations, minimum detection levels, statistical treatment of data and determinations of statistically significant differences, recordkeeping and reporting, quality assurance, etc.?
- 9) To what extent must the NRC provide supporting environmental impact analyses considering the nature of the requirements under consid-eration, some of which have already been imposed by EPA and are effective?
If supporting environmental evaluations are needed for SVDA-comparable rule changes except for the requirements already imposed by the EPA, should the NRC continae'to proceed with only a single ruimmaking to, establish a complete set of SWDA-comparable requirements?
- 10) Is the flexibility cited in the proposed addition to the 3 Introduction of Appendix A 10 CFR Part 40 sufficient or should the NRC 7
\ : -d f . ..;::: y _;;r ::: t: develop and support additional modifica-tions to conform to the physical stability aspects of the EPA standard? l l
l l
l 12
ge
<r
~.
} cc: frT3G g ,M LBN mr Proposed Rules r d-i "+-
fN/
Vol. 50. No.11 /)-
Wednesday. January 16. 1965 l
The secean of me FEDEUL REGISTER Post Fusmeen uspoessArtost CostTAct: may be examined at the NRC Public contans noeces e me outec of me Robert Fonner. Office of the Executive Document Room.1717 H Street NW.,
preceed neuence of rules and Legal Director, on (301) 492-4002, or Washington. D.C.
regulomons. h purpose of nieen nonc" K try S. Dragonette Division of Waste Poa pusmeen imponesarion cowTAct:
," , Management on (301) 427-430G. U.S.
Robert Fonner. Office of the Executive memng pnw a me acognon of me nnel Nuclear Regulatory Commission. Legal Director. on (301) 492-8002. or rules Wa shington. D.C. 20555. Kitty S. Dragonette. Division of Waste Dated at Washmston. D.C., this tith day of Management on (301) 497-4300. U.S.
january.1985. Nuclear Regulatory Commission.
NUCLEAR REGULATORY For the Nuclear Regulatory Coaunission. Washington. D.C. 20555.
Samuel J. Qilk. Dated at Washington D.C this 11th day of Sectwtaryof the Commission. january 1986..
10 CPR Part 40
[nt Doc. 86-1254 Filed 1-15-48: 8-48 am) For the Nuclear Regulatory Co==iamun.
Uranham BM Tamreg Reguistione,. oums ones pson. ewes 5aneel J. Chilk.
Aonferneing NRC Reaguiremente to EPA Secretary ofthe Commission.
Densierde . 1 CFR Part 40 (FR Doc. es-1237 Filed 1-15 45: a:44anl e.ame csee _
Urentuise RM TedBnge Regulamen; Asenscv: Nuclear Regulatory Ground Water Protection anal Outer Commission. leeuse
. Actiese Proposed rtile: extension of ggy g cement pated. .
Asesecv: Nuclear, Regulatory Commiselon. Pederal Aviation AdministroessF suusansm On November 28,1984. (90 FR Actiose Advanced notice of proposed 46418), the NRC published for public rulemaking: extension of comment ,.
comment a proposed rule amending its Penod.
(Deseret fee. 84-4016131-A01 auona go arning e po of
, g susessaav: On November 28,1964 (49 FR 46425). the NRC published for pub ic AltworWtinese Direedvest Boedrig changes are latended to conform teodel 737 Series Airpimwe W existing NRC reguleHons to the regulations published by the
[po Ru! k indi that the NRC le considering further amendments Aemscy: Federal Aviation c mme p ri t a propo rule
" * " ' ' " " " " ' '""'" " #'" " ^^I was to have expired on January 10.1965' in rPorate ground water protection Actions Notice of Proposed Rulemaking provisions and other requirements (NPRM).
A number of commenters have reyested an extension of the comment established by EPA for similar period. In view of the importance of the hazardous wastes into NRC regulations. sussesAny:This notice proposes a new proposed rule, and the desire of the The comment period for this proposed airworthiness directive (AD) which rule was to have expired January 25, would require inspection and Commission to allow all parties to fully express their views. the NRC has 1965. A number of commenters have replacement, as necessary, of certain requested an extension of the comment Air Cruisers evacuation slides installed decided to extend the comment period for an additional thirty days. The period. In view of the importance of the on Boeing Model 757 airplanes.Wie proposed rule. and the desire of the notice is prompted by reports of extended comment penod now expires on February 10.1985. Commission to allow all parties to fully excessive slide fabric porosity, which express their views, the NRC has results in leakage of the evacuation slide oATes:ne comment Perded has been decided to extend the comment period. could result in an unuseable slide and extended and now e February 10. The extended comment now expires on jeopardize successful emergency 1985. Comments after this date March 1.1985. evacuation of an airplane.
wt!! be considered if it le practical to do oATes:De comment period has been oAft: Comments must be received on or so but assurance of consideration extended and now exptres March 1. before March 8.1985, cannot be given except as to comments 1985. Comments received after this date received before this date. Aeonesses: Send comments to Seattle will be considered if it is practical to do Aircraft Certification Office. FAA.
aaa==aaaa Send wntten comments or so but assurance of consideration Northwest Mountain Region.17900 suggestions to the Secretary of the cannot be given except as to comments Pacific Highway South.C aansa Seattle.
Commission. U.S. Nuclear Regulatory received before this date. Washington 98168.
Commission. Washington. D.C. 20555. aaaaa Send wntten comments or The service documents cited in this Attention: Docketing and Service suggestions to the Secretary of the AD may be obtained upon request from Branch. Copies of comments received Commission. U.S. Nuclear Regulatory the Boems Commercial Airplana may be examined at the NRC Public Commission. Washington. D.C. 20555. Company. P.O. Box 3707. Seattle.
Document Room.1717 H Street NW. Attention: Docketing and Service Washington 90124 or may be examined Washington. D.C. Branch. Copies of comments received at the FAA. Seattle Aircraft Certification l
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