ML20011B189
| ML20011B189 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1977 |
| From: | Case E Office of Nuclear Reactor Regulation |
| To: | Rich Smith NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML20011B132 | List:
|
| References | |
| FOIA-81-303 NUDOCS 8112040395 | |
| Download: ML20011B189 (3) | |
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%.g UNITED STATLS 4+ -
4 NUCLEAR REGULATORY COMMis33CN E
WASHINGTON, D. C. 2C555 3,,', #
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iiEMORANDUM FOR:
R. G. Smith, Acting Director Division of Siting, Health and Safeguards Standards Office of Standards. 0eveloprient FROM:
Edson G. Case, Acting Director Office of Muclear Reactor Regulation 5'JBJECT:
OCCUPATIONAL RADIATION EXPOSURE AT NRC LICENSED FACILITIES,1975 We have reviewed the subject draft HUREG dccument.
We believe it is a good summary and analysis of the limited 1975 occupational radiation exposure data on the licensees not currently covered by 120.407.
We concur in the distribution of this dccument to all licensees for cccment.
'.?e do not believe, Pwever, that any further benefit is to be derived frcm having yet ano:ner round of cer=ents on the proposed rule. The aaad for :.RC to ' n;s the radistica dosas haing accruad as a result of A
its licensing actions is clear. The reporting cost to ifcensees would be small.
The cost of the NRC computer operation (appioximately S50,000 for FY 1977) could be increased by 15 to 20?..
The reasons for going ahead promotly with issuance of an effective rule, forwarded with our memo (Rusche to Mattson, 3/11/76, copy attached), are still valid.
The draft HUREG document demonstrates clearly that significant occupa-tional radiation exposures are occurring among licensees not covered by 520.407.
It would therefore be prudent for NRC to initiate action to promulgate this information to the general public. Let us get on with the job, and issue the rule in effective form.
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'm Edson G. Case, ing Director
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Office of Nuclear Reactor Regulation
Enclosure:
Proposed Rule to Extend
$20.407 to Include All Licensees Enclosure "J" 8112040395 810902 PDR FOIA COTTINO81-303 PDR
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REASONS FOR PROCEEDING WITH PUSLICATION IN EFFECT!'!E FORi4
~.0F PROPOSED ROLE PUSLISliED FOR COMMEili ON t%Y 20. 1975 T0' EXTEND s20.407 70 tiiCLUDE ALL LICENSEES l
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Uith recard to a substantial fraction of its licensees, the Commission does not receive data to evaluate ne icact of aersonnel radiation excosuras.
Iha present exposure reporting requirements in 10 CFR Part ~2u, Section-20.407 applies only to four categories of licensees, including powerreactor licensees (a total of less than 500 out of nearly 50C0 Commission licensees). For these 500 licensees, tne -
Commission now receives relevant data and prepares routine, widely-distributad summary reports of personnel. radiation exposure, including the total man-rsm impact for each of the covered categories.
Compari-sons amonc licensees wit.hin each category are also possible.
Exposure data for the remaining nearly 95% of Commission licensees would be recuired for the first time under the proposed amendment to 520.407.
The only exposure da:a presently available.to the Comission for these latter licensees are those included in required overexposure reports.
2.
The Envirennental Drotection h encv. the National Council on Radiatic7 Pret ction and Mstuurements and the United M tions Scientific Co ni;;ca CG INe Effects of MEOm1C RCGiation nave recent.iV made formal reouests ice decaliac :n orination on astima:aa carsonnai encosures resultino from NRC-licansa activitics.
Eacn of tnese bodies functions to scme extent as an acvisory cocy, within its jurisdiction, with r. elation to radiation protection.
Each, on 'a continuing basis, systematically evaluates as best it can the magnitudes of radiation exposures frca
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all sources, estimates potential biological effects that might result therefrom, and derives appropriate conclusions and recommendations.
The implementation of the proposed amendment to 10 CFR Part 20 will provide the basis for subsequent recomendations, which will, in turn, be used in development,of future NRC radiation protection regulations.
3.
Based on information available on oower reactor licensees, total occucational raciation execsures are likely to be sicnificantiv in excass of the total raciation exoosures ceiiverso to memcers of tne pubiic from rel9ases of er.aicactive paterials tn the environment in tne effluents.
Tnese non-occupational exposures have caused a considerable {
degree of public concein in recent years. ~As a' result, the NRC has developed, after extensive di.scussions and exhaustive public hearings, a fomal implementation of the. ALARA concept, in Appendix I to 10 CFR Part 50.
A significant increase in utility expenses'has resulted therefrom,' in the area of waste treatment capability.. Public interest appears,likely to be focussed more on the much larger total occupational radiation es:posure in the future.
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There were rele.tively few necative resconses to f!RC oublication of
_the Proc 0 sed ?,uie for oublic cor: ent.
In accition to publication
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for connent in tite Feueral Kegister, copies of the Proposed Rule were distributed to the nearly Sii60 Com:lission licensees, specifically including the nearly 500 licensees who have been subject to the same requirements since January 1974.
In response, only 35 letters of comment were received. Of these,12 stated specific opposition to issuance of the Proposed Rule in effective form. iiineteer of the 1ettars either reflected misunderstanding of the 1)roposed Rule or suggested various minor chan:;es.
Five specifically favored the amendment.
Included among these favorable responses were strong endorsements for proceeding with issuance of the proposed amendment frcm the Environmental Protection Agency and the Oil, Chemical, and the Atomic Worker International Union.
5.
The total costs to licensees involved in orecaration of these crocosed
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reoorts would be minimal.,less of licensee staff time per exposedIn nearly every c suffice.
Two minutes or person should be all that is needed in assembling the data for the report.
Even less licensee staff time would be involved if the data were processed iut:matically, or if the data were kept in a cumulative form suit:bie for reporting exposures to individuals, as they may
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request annually in accordance with Sectica 19.13(b).
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