ML090900138: Difference between revisions

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{{#Wiki_filter:April 7, 2009 Mr. Felix M. Killar, Jr.
{{#Wiki_filter:April 7, 2009 Mr. Felix M. Killar, Jr.
Nuclear Energy Institute 1776 Street, NW, Suite 400 Washington DC 20006-3708  
Nuclear Energy Institute 1776 Street, NW, Suite 400 Washington DC 20006-3708


==SUBJECT:==
==SUBJECT:==
SOLUBLE URANIUM INTAKE CRITERIA IN SUPPORT OF 10 CFR 70.61  
SOLUBLE URANIUM INTAKE CRITERIA IN SUPPORT OF 10 CFR 70.61


==Dear Mr. Killar:==
==Dear Mr. Killar:==


We have completed our review of your report entitled "Acute Chemical Toxicity of Uranium with Application to 10 Code of Federal Regulations (CFR) 70.61" (ML090070576) dated October 14, 2008. The focus of our review was your proposed resolution of our comments contained in the July 24, 2008, meeting summary that was issued on August 18, 2008 (ML082210440).  
We have completed our review of your report entitled Acute Chemical Toxicity of Uranium with Application to 10 Code of Federal Regulations (CFR) 70.61 (ML090070576) dated October 14, 2008. The focus of our review was your proposed resolution of our comments contained in the July 24, 2008, meeting summary that was issued on August 18, 2008 (ML082210440).
Most comments appear to have been addressed adequately. However, the report does not adequately address qualitatively and quantitatively the uncertainties in toxic health effects from exposure to soluble uranium which primarily arise from not having sufficient soluble uranium exposure data. As such, the report appears to lack the technical basis for substantiating significant increases in soluble uranium intake criteria in support of 10 CFR 70.61. A meeting at the U.S. Nuclear Regulatory Commission (NRC) Headquarters is being scheduled for May 12, 2009, to discuss this apparent shortfall and other specific NRC comments that appear as highlighted text in the enclosed report. In the meeting, the NRC staff would also like to discuss other related issues such as dermal exposure to hydrogen fluoride derived from a uranium hexafluoride release and potential effects of revised soluble uranium intake criteria on existing Integrated Safety Analyses.
If you have any questions regarding this matter, please contact Peter Habighorst at (301) 492-3136, or via e-mail to peter.habighorst@nrc.gov.


Most comments appear to have been addressed adequately. However, the report does not adequately address qualitatively and quantitatively the uncertainties in toxic health effects from exposure to soluble uranium which primarily arise from not having sufficient soluble uranium exposure data. As such, the report appears to lack the technical basis for substantiating significant increases in soluble uranium intake criteria in support of 10 CFR 70.61. A meeting at the U.S. Nuclear Regulatory Commission (NRC) Headquarters is being scheduled for  May 12, 2009, to discuss this apparent shortfall and other specific NRC comments that appear as highlighted text in the enclosed report. In the meeting, the NRC staff would also like to discuss other related issues such as dermal exposure to hydrogen fluoride derived from a uranium hexafluoride release and potential effects of revised soluble uranium intake criteria on existing Integrated Safety Analyses.
F. Killar                                       In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov.reading-rm/adams.html.
If you have any questions regarding this matter, please contact Peter Habighorst at  (301) 492-3136, or via e-mail to peter.habighorst@nrc.gov.
Sincerely,
F. Killar           In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov.reading-rm/adams.html.       Sincerely,  
                                                /RA/
        /RA/       Daniel H. Dorman, Director Division of Fuel Cycle Safety         and Safeguards, Office of Nuclear Material Safety   and Safeguards  
Daniel H. Dorman, Director Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards


==Enclosure:==
==Enclosure:==


NRC comments in the form of highlighted text in Nuclear Energy Institute report cc: Janet Schleuter, NEI       John Nagy, NFS       Richard Burklin, AREVA Kevin Roberts, NFS         James Salsman F. Killar           In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov.reading-rm/adams.html.       Sincerely,  
NRC comments in the form of highlighted text in Nuclear Energy Institute report cc: Janet Schleuter, NEI John Nagy, NFS Richard Burklin, AREVA Kevin Roberts, NFS James Salsman
        /RA/       Daniel H. Dorman, Director Division of Fuel Cycle Safety         and Safeguards, Office of Nuclear Material Safety   and Safeguards  
 
F. Killar                                       In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov.reading-rm/adams.html.
Sincerely,
                                                /RA/
Daniel H. Dorman, Director Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards


==Enclosure:==
==Enclosure:==


NRC comments in the form of highlighted text in Nuclear Energy Institute report cc: Janet Schleuter, NEI       John Nagy, NFS       Richard Burklin, AREVA Kevin Roberts, NFS         James Salsman  
NRC comments in the form of highlighted text in Nuclear Energy Institute report cc: Janet Schleuter, NEI John Nagy, NFS Richard Burklin, AREVA Kevin Roberts, NFS James Salsman DISTRIBUTION:
 
FCSS r/f           RidsNmssOd                   M. Bailey           C. Haney   M. Weber B. Smith           D. McIntyre,OPA             J. Henson, RII       P. Silva   M. Kotzalas T. Hiltz           S. Sherbini, FSME ML090900138 Office           AFCB                 MOX                   AFCB             FCSS Name             YFaraz               CGibbs P. Jenifer for PHabighorst      DDorman Date               4/02/09             4/06/09               4/06/09         4/07/09 OFFICIAL RECORD COPY}}
DISTRIBUTION:
FCSS r/f RidsNmssOd M. Bailey C. Haney M. Weber B. Smith D. McIntyre,OPA J. Henson, RII P. Silva       M. Kotzalas   T. Hiltz S. Sherbini, FSME ML090900138 Office AFCB MOX AFCB FCSS Name YFaraz CGibbs P. Jenifer forPHabighorst DDorman Date 4/02/09 4/06/09 4/06/09 4/07/09 OFFICIAL RECORD COPY}}

Latest revision as of 08:32, 14 November 2019

Soluble Uranium Intake Criteria in Support of 10 CFR 70.61
ML090900138
Person / Time
Issue date: 04/07/2009
From: Dan Dorman
NRC/NMSS/FCSS
To: Killar F
Nuclear Energy Institute
Yawar Faraz, NMSS/FCSS/AFCB 301492-3207
References
Download: ML090900138 (3)


Text

April 7, 2009 Mr. Felix M. Killar, Jr.

Nuclear Energy Institute 1776 Street, NW, Suite 400 Washington DC 20006-3708

SUBJECT:

SOLUBLE URANIUM INTAKE CRITERIA IN SUPPORT OF 10 CFR 70.61

Dear Mr. Killar:

We have completed our review of your report entitled Acute Chemical Toxicity of Uranium with Application to 10 Code of Federal Regulations (CFR) 70.61 (ML090070576) dated October 14, 2008. The focus of our review was your proposed resolution of our comments contained in the July 24, 2008, meeting summary that was issued on August 18, 2008 (ML082210440).

Most comments appear to have been addressed adequately. However, the report does not adequately address qualitatively and quantitatively the uncertainties in toxic health effects from exposure to soluble uranium which primarily arise from not having sufficient soluble uranium exposure data. As such, the report appears to lack the technical basis for substantiating significant increases in soluble uranium intake criteria in support of 10 CFR 70.61. A meeting at the U.S. Nuclear Regulatory Commission (NRC) Headquarters is being scheduled for May 12, 2009, to discuss this apparent shortfall and other specific NRC comments that appear as highlighted text in the enclosed report. In the meeting, the NRC staff would also like to discuss other related issues such as dermal exposure to hydrogen fluoride derived from a uranium hexafluoride release and potential effects of revised soluble uranium intake criteria on existing Integrated Safety Analyses.

If you have any questions regarding this matter, please contact Peter Habighorst at (301) 492-3136, or via e-mail to peter.habighorst@nrc.gov.

F. Killar In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov.reading-rm/adams.html.

Sincerely,

/RA/

Daniel H. Dorman, Director Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards

Enclosure:

NRC comments in the form of highlighted text in Nuclear Energy Institute report cc: Janet Schleuter, NEI John Nagy, NFS Richard Burklin, AREVA Kevin Roberts, NFS James Salsman

F. Killar In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov.reading-rm/adams.html.

Sincerely,

/RA/

Daniel H. Dorman, Director Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards

Enclosure:

NRC comments in the form of highlighted text in Nuclear Energy Institute report cc: Janet Schleuter, NEI John Nagy, NFS Richard Burklin, AREVA Kevin Roberts, NFS James Salsman DISTRIBUTION:

FCSS r/f RidsNmssOd M. Bailey C. Haney M. Weber B. Smith D. McIntyre,OPA J. Henson, RII P. Silva M. Kotzalas T. Hiltz S. Sherbini, FSME ML090900138 Office AFCB MOX AFCB FCSS Name YFaraz CGibbs P. Jenifer for PHabighorst DDorman Date 4/02/09 4/06/09 4/06/09 4/07/09 OFFICIAL RECORD COPY