ML20247N236
| ML20247N236 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 05/02/1989 |
| From: | Frain R SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Reilly W ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| 25544, NUDOCS 8906050276 | |
| Download: ML20247N236 (7) | |
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. Environmental Protection Agency q,
8K Attention: Honorable William K. Reilly Administrator
'b p) h ng o bC 5460
Dear Mr. Reilly:
PROPOSED RULE ON NATIONAL EMISSION STANDARDS FOR RADIONUCLIDES-Advanced Nuclear Fuels Corporation's (ANF) comments on the proposed rule on air emission standards for radionuclides (40 CFR 61) have been submitted to the Centra,1 Docket Section-(copy enclosed).
. As noted in our enclosed comments, we are concerned that. the proposed rule will-have a negative impact on the operation 'of NRC-licensed. facilities such as ANF's in two ways.
First, the proposed emission standards are considerably lower than currently recommended values.
Second, implementation.
would appear to involve dual regulation 'by EPA and NRC for control of radionuclides emissions.
Three 'possible air quality standards are proposed for NRC-licensed-facilities.
The first and highest possible value of a dose limit for a member of the public of 10 mrem /yr is 2.5 times lower than the current value for air emissions recommended by the National Council on Radiation Protection and Measurement (NCRP) of 25 mrem /yr.
The second possib'e value is 8.3 times lower than the value recommended by NCRP while the third possible value is 833 times lower.
It is our position that the EPA staff should endorse or accept the recommendation of the NCRP on this issue unless there is an overriding, scientific reason for proposing an alternate limit.
In this instance, no such reason was presented.
Further, the proposed requirements for implementation would have NRC licenses ' meeting duplicate requirements for recordkeeping, reporting, and review and approval of plant modifications for both EPA and NRC.
It is our position that EPA should set the standard, and the NRC should implement the standard.
The additional cost of duplicate administration of the rule cannot be' justified.
8906050276 890502 PDR ADOCK 07001257 8
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' William W. Reilly April 25, 1989 Page 2 for the reasons stated above, we urge that EPA not allow this proposed rule to become final in its current form.
Thank you for considering our views.
Sincerely, s
R.
.' Frain Vice President, Operations Division RGF:jrs Enclosure As Noted cc: Secretary of the Commission, NRC
':!Leland: Cw Rouse n.NRC, I
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April 20, 1989 CWM:89:033 Environmental Protection Agency Attention: Docket No. A-79-11 Central Docket Section (A-130)
Washington, D.C.
20460
Dear Sir:
Subject:
PROPOSED RULE ON NATIONAL EMISSION STANDARDS FOR RADIONUCLIDES Advanced Nuclear Fuels Cr poration (ANF) has reviewed the proposed rule on air emissions standards for radionuclides which was published in the Federal Reaister in Vol. 54, No. 43, March 7,1989 (p. 9612).
ANF is a fabricator and supplier of light water reactor fuel and related services. ANF operates a uranium fuel fabrication plant which is located near the City of Richland in the southeast part of the State of Washington.
We are involved with the processing, handling, and containment of low enriched uranium in our facility, and have a Special Nuclear Material (SNM) License from the Nuclear Regulatory Commission (NRC) under 10 CFR 70.
We maintain i
uranium airborne concentrations well within acceptable limits, both inside and outside our facility.
We continuously sample each stack (or vent) to the atmosphere, and measure and report to the NRC the quantities of radioactivity discharged from each stack.
We currently operate under emission limits which assure that our discharges to the atmosphere are well below a quantity that could give a dose to a member of the public in excess of the limits given in 40 CFR 190.
Our comments relate to the standards proposed for NRC-licensed facilities and requirements proposed for insuring compliance with those standards.
Three possible air emission standards are proposed for a NRC-licensed facility.
These are defined as the amounts of radionuclides emitted to the air which, if exceeded, would cause a member of the public to receive an effective dose equivalent of 10 mrem /yr, 3 mrem /yr, or 0.03 mrem /yr. Although the risk basis for these dose levels is explained in the Supplementary Information, there is not an explanation as to why the dose level from air sources is being lowered from the value of 25 mrem /yr which was recommended by
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the National Council on Radiation Protection and Measurement (NCRP) to a value of 10 mrem /yr and below.
We do not see a compelling reason or evidence j
for this reduction in the recommended air emission standard.
The NCRP is a j
proper body to recommend dose levels, and its recommendations should not be I
ignored.
A Siemens Comwy i
_____-______-___________-______A
Environmental Proetection Agency CWM:89:033 April 20, 1989 Page 2 Further, the inclusion of the lower dose levels of 3 and 0.03 mrem /yr as possible choices for air emission standards does not appear to be realistic.
Those dose levels are within the variations in natural background, and are also orders of magnitude lower than other commonly accepted risks.
Our other comments concern the proposed requirements for compliance with air emission standards by NRC licensees.
Under the proposed requirements for Subpart I of the proposed amended Part 61, NRC, licensees would have to meet the requirements of proposed paragraphs 61.104, 61.105 and 61.106 for reporting, recordkeeping, and applications'to canstruct or modify.
As noted earlier under our current SNM license, we continually sample each stack (or vent) to the atmosphere, and measure and report our emissions of radionuclides to the NRC.
Our measured emissions are evaluated by the NRC for any adverse impact on public health and safety.
In 1987, the NRC estimated the maximum dose to the nearest resident and to the population within 50 miles of the ANF plant.
The total exposure to (2.1milesaway)wasestimatedtobeintheorderof4x10ghenearestresident
. mrem /yr, while the dose commitment from airborne effluents was estimated' to be 4.8x10-3 mrem total body dose.
The NRC also reviews for prior approval requests to modify our plant or to construct new structures for handling and containing low enriched uranium, our principal radionuclides.
We are also routinely inspected by the NRC to assure that we meet requirements for occupational and public health and safety.
It is clear that the public health and safety will be fully protected in regard to the air emissions of radionuclides by NRC-licensed facilities as long as the air emission standards are incorporated by the NRC into licensee requirements as they are now for 40 CFR 190. As a result, we request that the Administrator modify the final rule to exempt NRC licensees from the proposed compliance paragraphs 61.104, 61.105 and 61.106.
This exemption would be based on the understanding that the NRC continues to incorporate air emission standards into licensee requirements as they do now.
Thus, the NRC licensees would meet the promulgated air emission standards and continue to report their measured emissions to NRC.
They would continue their current record-keeping practices, and also would continue to obtain from NRC prior approval of modifications or new construction impacting on the containment or emission of radionuclides.
In this way, the only additional burden imposed on NRC licensees would be the burden of meeting a (possible) lower emission standard, rather than the additional reporting and licensing efforts needed to satisfy both NRC and EPA.
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Environmental Proetection Agency CWM:89:033 April 20, 1989 Page 3 We appreciate this opportunity to comment and thank you for considering our views.
Sincerely, hk$
f C. W.*Malody, Manage Corporate Licensing 4
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