ML16295A178

Proposed Revisions of 10 CFR 20, Standards for Protection Against Radiation

ML16295A178
Person / Time
Issue date:	06/07/1988
From:	Kerr W Advisory Committee on Reactor Safeguards
To:	Zech L Advisory Committee on Reactor Safeguards
References
D880607
Download: ML16295A178 (2)

Text

D880607 The Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 2055

SUBJECT:

PROPOSED REVISIONS OF 10 CFR 20, "STANDARDS FOR PROTECTION AGAINST RADIATION" During the 338th meeting of the Advisory Committee on Reactor Safe-guards, June 2-4, 1988, we met with the NRC Staff to discuss the pro-posed revisions to 10 CFR 20, "Standards for Protection Against Radi-ation." This was also the subject of a meeting of our Subcommittee on Occupational and Environmental Protection Systems held on May 31, 1988.

We also had the benefit of the documents referenced.

As a general comment, we commend the NRC staff for its efforts in revising these regulations. They have sought to make the regulations compatible with the recommendations of the International Commission on Radiological Protection (ICRP) and the National Council on Radiation Protection and Measurements (NCRP), as well as with the standards of other Federal agencies, such as the Environmental Protection Agency (EPA). In addition, the NRC staff has carefully reviewed and evaluated comments received from several hundred outside organizations and indi-viduals, and has revised the regulations to include the latest scien-tific data on radionuclide decay schemes and the behavior of specific radionuclides within the human body. Finally, the regulations have been expanded to include dose limits for the embryo/fetus in an occupational setting and for members of the public.

In presenting the revised regulations, the NRC staff stated that a number of related issues, such as the designation of radioactive wastes that are below regulatory concern and the establishment of procedures for estimating doses to the embryo/fetus, would be covered elsewhere.

Several of these issues are to be handled via regulatory guides. To ensure that all licensees are aware of the subsequent guidance to be provided, it would be helpful if a tabulation were prepared for each of these issues, coupled with the mechanism and time schedule on which they are to be resolved.

In addition we offer the following specific comments:

1. We agree that application of the committed effective dose equiva-lent is the proper approach to follow in planning for radiation protection and in controlling exposures from nuclear activities.

However, the committed effective dose equivalent does not consti-tute a sufficient basis in itself for evaluating the potential health effects of radiation exposures in individuals. Such evaluation should be based on estimates of the actual absorbed dose for the period of exposure appropriate to the individual case. For this reason, in the case of radionuclides having long effective

half-lives, it is recommended that licensees be provided the option of using the annual effective dose equivalent in the determination of compliance with 10 CFR 20.

2. The proposed regulations exempt "medical research programs" from the given dose limits; in a similar manner, they exempt excreta from medical patients for release to sanitary sewers. We suggest that an analysis be made of the potential health impacts of these exemptions. Also of possible benefit would be a survey of related practices in other countries.

3. Several of the definitions included in the proposed revision appear to be incomplete or to contain errors. These are:

a. "Natural background" - this should emphasize that the exempted sources do not include those of natural origin that have been "technologically enhanced."

b. "Whole-body" - this definition states that a dose equivalent to the head will be recorded as to the whole body. Consider-ation should be given to the development of weighting factors for converting partial external body exposures into equivalent whole-body doses.

4. The revised regulations do not allow any exemptions from the security requirements that cover access to licensed materials.

Quantities of certain radionuclides that represent minimal risk to health should be exempted from these requirements.

5. The proposed regulations require that recipients monitor for radioactive contamination and external dose rates all transpor-tation packages labeled as containing radioactive materials. We believe that monitoring for external radiation levels should be required only for those packages that are required to have a warning label for external radiation.

We trust these comments will be helpful.

Sincerely, W. Kerr Chairman

References:

1. Memorandum dated May 20, 1988 from B. M. Morris, NRC Office of Nuclear Regulatory Research, to R. F. Fraley, ACRS, transmitting Proposed Final Rule, 10 CFR Part 20, "Standards for Protection Against Radiation."

2. National Council on Radiation Protection and Measurements, "Recommendations on Limits for Exposure to Ionizing Radiation,"

Report No. 91, Bethesda, MD, June 1, 1987