ML19350A533
| ML19350A533 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML19219A599 | List: |
| References | |
| FRN-45FR67018, REF-10CFR9.7, RULE-PR-20, TASK-PII, TASK-SE SECY-81-077A, SECY-81-77A, NUDOCS 8103160440 | |
| Download: ML19350A533 (3) | |
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February 20, 1981 SECY-81-77A
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POLICY ISSUE (Information)
For:
The Commissioners From:
William J. Dircks Executive Director for Operations
Subject:
OGC MEMORANDUM ON PROPOSED FINAL RULE TO AMEND PART 20 REGARDING DISPOSAL OF TRITIUM AND CARBON SECY-81-77
Purpose:
This memoreadum provides supplementary information regarding S ECY-81-77 Category:
This paper covers a minor policy question.
Discussion:
The OGC memorandum (Enclosure 1) to the Commission expresses the view that the rule might be subject to legal challenge "bacause of inadequacies in the analysis supporting the conclusion that the environmental effects of this rule would be insi1nificant."
This contention is based on a misinterpretation of the collective dose analysis described on page 9 of Attachment 2 of the value/
impact statement (Enclosure 2).
The pertinent section states :
"This report (0RNL-5269) indicates a collective dose commitment of 620 person-rem per curie of carb::n-14, or 3,720 person-rem in total for the 6' curies released each year via the rule. Again, using the 1 health effect per 10,000 person-rem from the BEIR-III report, we estimate a total of'0.37 health effects to the world population."
The 620 person-rem per curie of carbon-14 is a dose commitment, which in the case of carbon-14 means the dose results from integrating the exposure to the entire world population from the time of release to infinity.
Thus, it would take well over 50,000 years for the total 3,720 person-rem and the 0.37 health effect to accrue to the many generations of the world population which would come a.nd go during this period.
Even if we assumeo
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John R. Cook, NMSS 42-74240 8108160
. all the dose and the health effect occurred in a single year, the risk per person would be.37 + 4,000,000,000 (world population) =
9.25 x 1011, and this overstates the risk by a factor of at least 50,000. Such risks are inconsequential, and firmly support the conclusion that the environmental effects of this rule would be insignificant.
To preclude any further misinterpretation, we will add the following statement at the end of the discussion of collective dose quoted above to provide additional clarification of the rule's impacts:
"It should be noted that it would take over 50,000 years for the 3,720 person-rem and the 0.37 health effect to accrue to the world population."
In the memorandum it is suggested that the amendments should be compared with the occupational dose associated with the replace-ment of the Surrey steam generator (11 NRC 405). There is no comparison to be made between the risks associated with these two actions. The occupational dose is not a global dose commitment; it would accrue to perhaps a thousand people in a couple of years.
It is not to be compared with a dose commitment dis-tributed over billions of people and tens of thousands of years.
The individual risks are 10 orders of magnitude less in the latter case.
In addition, the last part of the OGC memorandum refers to a statement the staff made in its Environmental Assessment (page 10, Attachment 2 of value/ impact' statement) to the effect that even if results were in error by a couple of orders of magnitude, the collective dose and health effects would be negligible. This is a concluding statement concerning the assessment for disposal of tritium snd carbon-14 via the sanitary sewerage system. The OGC memorandum incorrectly links this statement to the'O.37 l
health effects for disposal of carbon-14 in scintillation media and animal carcasses.
In the case of sanitary sewerage, we have limited data as to the extent of use that would be made of the regulation change to dispose of carbon-14 and tri'.f am via the sanitary sewerage system.
Therefore, we made allowance for significant departures from the estimates upon which our calcula-tions were made. We have a much more firm data base for disposal i
of scintillation media and animal carcasses.
Therefore, a similar statement was not made in this case.
In order to make the concluding statement regarding sewage disposal more clear, we will change it to read:
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. "Even if our assessment of the sewer release amendment was in error by a couple orders of magnitude, the conclusion would remain the same:
the collective doses and health effects resulting from the rule are estimated to be so small that they are negligible."
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Willia
. Dircks l
Executive Director for Operations
Enclosures:
- 1. OGC Memorandum dated 2/9/81
- 2. Attachment 2 of Value/ Impact Statement DISTRIBUTION Commissioners Commission Staff Offices Exec Dir of Operations ACRS Secretariat l
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