ML20245G358
| ML20245G358 | |
| Person / Time | |
|---|---|
| Issue date: | 11/02/1984 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Vernon T COLORADO, STATE OF |
| Shared Package | |
| ML20245G297 | List: |
| References | |
| FOIA-89-242 NUDOCS 8908150379 | |
| Download: ML20245G358 (3) | |
Text
-
b.
~'
,1 I{q 3
4 Thomas M. Vernon, M. D.
Exe;'"1ve Director Colu do Department of Health 421v tast lith Avenue Denver, Colorado 80220
Dear'Dr. Vernon:
Thank you for your letter of July 31, 1984, responding to our comments and recoramendations following our 1984 review of your Department's radiation control program. / I also wish to acknowledge Mr. A. J. Hazle's letter of August 1,1984, responding to the technical portion of our coments and recommendations.
We.have completed our review of the Colcrado radiation control program and, as indicated in our letter to'you of July 11, 1984, have included an evaluation ~of the matters raised in a letter to Chainran Nunzio J. Palladino from the Environmental Defense Fund (EDF)' dated May P4, 1984. The EDF letter expressed major concerns over radiation exposures to the public in Uravan, Colorado, and other regulatory matters relating to the Uravan uranium' mill. A copy of our letter to EDF regarding our evaluation is enclosed.
i In response to the EDF letter, the Nuclear Regulatory Commission (NRC) formed e special study group to provide an overview of radiation exposures and the regulatory activities of the State concerning the mill and the town of Uravan, Colorado. A copy of the report of this study group was sent to Mr. A. J. Hazh of your staff on August 16, 1984. The results of the study group's efforts were factored into our overall review of the State's radiation control program for agreement materials.
We find, as a principal conclusion in our analysis of the Uravan matter, that the issuance, in the near future, of a renewal license for the facility will represent the culmination of the State's recent history of regulatory efforts at Uravan.
A significant portion of these efforts have been directed towards the elimination of radiation exposures to members of the public within the Uravan area. The issuance of this license is expected to occur after consideration of information gathered at the recent (August 22-23,1984) public hearing on the Colorado Department of Health's, " Preliminary Executive Licensing Paview Summary," (PELRS) for the Uravan uranium mill.
RCh N
ELD RA-RIV ED0 SGRFM URF0 RJDcdf/1t RDSmith WLBrown-F#
rr GHCunningham RDMartin WJDircks 11/l/84
/ /84 ll/l/84
(/bf84
/ /84
/ /84
/ /84
~
8908150379 890009
)$
7 mwh -
l Thomas M. Vernon, Colorado Department of Public Health i Significantly, infonnation brought to light during the public hearing included the presentation of an agreement between the mill licensee, Umetco, and EDF concerning plans and measures to address the radiation exposure problems of Uravan.
It appears, at this time, that the final licensing document may be able to include certain restrictions and schedules that will be applicable to an overall plan for the reduction of radiation exposures to members of the public in the Uravan area and, additionally, will be acceptable to both parties.
Notwithstanding the progress made towards the issuance of a renewal license for Uravan, we find that positive regulatory steps addressing the offsite radiation exposure problems have occurred in a painstakingly slow manner. Agencies regulating uranium mills and tailings have found the last few years to be difficult times in traversing the regulatory thicket that has existed since the passage of the Uranium Mill Tailings Radiation Control Act of 1C78 (UMTRCA) and existing to the present time.
We believe, however, that the CDH has taken reasonable and appropriate action in the regulation of. uranium mills and tailings since the passage of UMTRCA and continuing to the present time with the planned renewal of the Uravan license.
By no means, however, do we believe the radiation exposure levels within the town of Uravan to be acceptable over the long tenn. The difficulty of separating radiation exposure levels due to old operations from those due to current mill operations should not deter-the State from applying full attention to the resolution of this problem.
Your letter of July 31, 1984, included your responses to the two significant Category I coments we found during our program review in June of this year.
You indicated the State's inspection priority system would be updated to at least match the inspection frequencies of the NRC's system. We find this modification to be acceptable and ?re pleased to hear that it will impact the program and staff only to a minor degree. With regard to the second comment, you-indicated that a tracking procedure had been instituted for both routine enforcement actions and for civil penalties and that senior staff will monitor these procedures. We believe this will ensure the completion of followup actions to enforcement letters, when necessary. We plan to review this procedure during the next review meeting. We would like to reiterate our recommendation on increasing the staff of the Radiation Control Division and ask that you give this matter your personal attention.
Based on our overall program review, including an evaluetion of the issues in the EDF letter, your responses to the significant Category I coments indicated above, and the routine exchange of information between the State and the NRC, we believe the Colorado radiation control program is adequate to protect the public health and safety and compatible with the NRC's program for the regulation of similar materials. However, we plan to followup the requirements contained in the renewal license for the Uravan uranium mill and the timetable for planned steps t0 reduce radiation exposures to members of the public in the i, Uravan area.
If significant delays or regulatory violations occur, which the State is unable to resolve in a satisfactory manner, we will be in touch with you to discuss what further actions may be appropriate.
l l
N
e l.
Thomas M. Vernon, Colorado Department of Public Health I appreciate.the courtesy and cooperation you and your staff extended to our L
representatives during the program review meetings. and during our special study -
group's visits to various offices within the Colorado Dep-rtment of Health.
I L
12 also enclosing a copy of this letter for placement in the State Public Document Room or to otherwise be made available for public review.
Sincerely, Robert D. Martin Regional Administrator
Enclosure:
Ltr. to EDF cc: Mr. A. J. Harle, Colorado Radiation Control Divicion G. W. Kerr, Director, OSP-NRC R. E. Yuhnke, Environmental Defense Fund State Public Document Room NRC Public Document Room bec: W. J. Dircks, EDO R. D. Martin, RIV P. S. Check, RIV R. L. Bangart. RIV C. E. Wisner, IV W. L. Brown, RIV R. J. Everett, RIV R. J. Doda, RIV R. S. Heyer, RIV j
G. F. Sanborn, RIV J. Davis, HMSS G. Cunningham, ELD Colorado File DMB for Dist. (SP01) l i
- _ _. _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _