Compliance with 40 CFR 190, EPA Uranium Fuel Cycle Standard (Generic Letter 79-41)


                           UNITED STATES NUCLEAR 
                          WASHINGTON, D.C. 20555 

                            September 17, 1979 



The effective date for implementation of the EPA Uranium Fuel Cycle 
Standard, 40 CFR Part 190 for light-water reactors, is December 1, 1979. By 
agreement, NRC is responsible for the implementation of this standard for 
licensed power reactors. Compliance with Radiological Effluent Technical 
Specifications (RETS), NUREG-0472 (Rev. 2) for PWRs or NUREG-0473 (Rev. 2) 
for BWRs, implements the LWR provisions to meet 40 CFR Part 190. Due to the 
delays in receiving and processing these Technical Specifications as 
scheduled in the letter to you from B. Grimes, Assistant Director for 
Engineering and Projects, dated November 15 1978, the Radiological Effluent 
Technical Specifications may not be in effect for your facility on December 
1, 1979. 

The lack of Technical Specifications which implement the provisions of 40 
CFR Part 190 does not relieve you of the responsibility to conform to the 
EPA standard. Therefore, you should determine how you will demonstrate to 
the NRC conformance with the provisions of 40 CFR Part 190 until such time 
as the revised RETS are issued. A commitment to the provisions of 
Specification 3.11.4 of the RETS, Revision 2, as explained in Chapter 3.8 of 
NUREG-0133, "Preparation of Radiological Effluent Technical Specifications 
for Nuclear Power Plants" is an acceptable method for demonstration of 
conformance. This commitment or an alternative method of demonstrating 
compliance with 40 CFR Part 190 should be submitted to NRC no later than 
November 1, 1979. 

If you have any questions, please contact us. 


                                   William P. Gamill, Acting Assistant 
                                     Director for Operating Reactor Projects
                                   Division of Operating Reactors 


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