ML20006C432

Discusses ACNW 16th Meeting on 900124-25 Re Commission Policy Statement on Exemptions from Regulatory Control. Agrees W/Commission Conservative Selection of Applicable Dose Rate Limits Re Potential for Individual Exposures

ML20006C432
Person / Time
Issue date:	01/30/1990
From:	Moeller D NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:	Carr K NRC COMMISSION (OCM)
References
FACA, NACNUCLE-R-0030, NACNUCLE-R-30, NUDOCS 9002080033
Download: ML20006C432 (6)

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NUCLEAR REGULATORY COMMISSION-

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ADVISOHY COMMITTEE ON NUCLEAR WASTE i

WASHINGTON, D.C. 20556

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1 January 30, 1990

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-The Honorable Kenneth M. Carr i

Chairman 1

.U.S. Nuclear: Regulatory Commission

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SUBJECT:

COMMISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL.

During its 16th meeting, January 24-25,

1990, the. Advisory 1

Committee on Nuclear Waste reviewed the above subject report (SECY-89-360)..Because'this has been a matter of continuing. interest to the Committee, we.take this opportunity to offer the following 1

comments..

1. -

We believe that expressing the Policy Statement in terms i

l of " Exemptions 'from Regulatory Control" is. a positive

. step.

We.have, for some time, believed that the term,-

l "Below Regulatory Control," was a misnomer. In fact, for l~

the caset of low-leve1' radioactive wastes, the objective

.is to. develop a system for granting approval for certain l(exempted) wastes to be : disposed of in facilities not l

licensed by the NRC.

2.

We agree that the Commission is wise.to be conservative

'in the' selection of applicable -dose rate limits until I

such time as more experience is gained ~ relative ' to assessing the potential for individual exposures from l.

multiple practicos.

However, we believe that the limits-of-1-mrem /yr for individual dose ~ rates and 0.1 mrem /yr-for the truncation of' ' collective doses are t o o l o w.-

l-Neither.would be directly measurable and both would!have large accompanying uncertainties.

From our perspective, it appears that the~ Commission would need to take experience into account only in the i

establishment of an-annual dose limit for individuals.

1 Even so, a' limit of 3 to 5 mrem /yr for each individual source or-practice would'not appear to be unreasonabic.

'In the selection of a limit for truncating collective dose calculations, we suggest that the Commission adopt the 1 mrem /yr value being used by the National Council on Radiation Protection and Measurements.

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R The Honorable Kenneth M. Carr

=2 January 30, 1990 3.

As stated in our letter dated - December 30, 1989,- we believe that-the collective dose limit should be variable.

Following this

approach, higher. annual collective dose limits would be permitted for exempted practices ; that contribute smaller. dose rates to individuals.

It should be noted that the - suggested collective dose rate limit of 1000. person-rem /yr may require the Commission to reconsider existing exemptions,-

such as those that permit the. incorporation of licensed materials in smoke detectors and in luminous watches and clocks.

Both of these applications appear to. yield annual collective doses exceeding the proposed limit.

4.

We believe the NRC staff is correct in urging that the Policy Statement include recommendations to discourage.

" frivolous" uses of radioactive materials.

Although which practices constitute such uses may be subject to interpretation, most people would agree that exemptions should not be granted for the purposeful introduction of radioactive materials into food.or. toys, regardless of how low the associated dose rates might be.

We hope these comments will be helpful.

Sincerely, Dade W. Moeller Chairnan

Reference:

SECY-89-360, Commission Policy Statement on Exemptions From Regulatory Control, December 1, 1989 (Predecisional) f I

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UNITED STATES 4

1 NUCLEAR REGULATORY COMMISSION I

1' ADVISORY COMMITTEE oN NUCLEAR WASTE WASHINGTON, D.C. 20806 January,30,1990 The Honorable Kenneth M. Carr Chairman U.S.= Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMMISSION POLICY STATEMENT ON EXEMPTIONS FROM REGUIATORY CONTROL.

-During its 16th meeting, January 24-25,

1990, the Advisory Committee on Nuclear Waste reviewed the above subject report (SECY-l 360).- Because this has been a matter of continuing interest to 1

the Committee, -we take _ this opportunity tc, offer the following l

comments.-

i

~1.

We believe that expressing the Policy Statement in terms of ' " Exemptions from Regulatory Control" is a positive

='

step.

We have, for some time, believed that the term, l

"Below Regulatory. Control," was a misnomer. In fact, for iL the case of low-level radioactive wastes, the objective

is'to develop a system for granting approval for certain (exempted)-_ wastes to be disposed of in facilities not

{

licensed.by the NRC.

]

I 2.

We: agree that the Commission is wise to be conservative in. the selection of applicable. dose rate limits until

-such - time as - more experience is gained relative to

. assessing the' potential for individual exposures from.

~

multiple practices.. However, we believe that the limits of 1 mram/yr for individual dose rates and 0.1 arem/yr-

- for. the ' truncation of collective doses are too low.

Neither would be directly measurable and both would have l

large accompanying uncertainties.

i From our perspective, it appears that the Commission i

would need to take experience into account only in the

. establishment of an-annual dose limit for individuals.

.Even'so,_-a limit of 3'to 5 mram/yr for each individual source or' practice would not appear to be unreasonable.

In the ' selection. of a limit for truncating collective dose calculations, we suggest that the Commission adopt the 1 mrem /yr value baing used by the National Council on Radiation Protection and Measurements.

_;s; 4-1 The~ Honorable Kenneth M. Carr 2

January 30, 1990 q

3.

As-stated in our letter dated December 30, 1988, we believe ~that the collective dose limit shoilld be variable.

Following this

approach, higher -annual J

y collective dose limits-would-be permitted for exempted j

practices that contribute smaller dose rates to individuals.

It should be noted that the suggested collective dose rate limit of 1000 person-ren/yr may

. require the Commission to reconsider existing exemptions, 4

such as those that permit the incorporation of licensed c-materials in smoke detectors and in luminous watches and clocks.

Both of these applications appear to yield annual collective doses exceeding the proposed limit.

q 4.

We believe the NRC staff is correct in urging that the-Policy Statement include recommendations to discourage "frivolouo" uses of radioactive materials.

Although which practices constitute such uses may be subject to interpretation, most people would agree that exemptions-should not be granted for the purposeful introduction of radioactive materials into' food or toys, regardless of how low the associated dose rates might be.

We hope these comments will be helpful.

Sincerely, h

N Dade W. Moeller 4

Chairman

Reference:

SECY-89-360, Commission Policy Statement on Exemptions From Regulatory Control, December ^1, 1989 (Predecisional) 4 4

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