ML20029C367

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Informs That Commission Vote Sheets Re Below Regulatory Concern Policy Statement Submitted & Staff Requirements Memo Can Be Expected within Next 2-3 Wks.Initial Meeting of Steering Group Will Be Held on 900524.Draft Guide Encl
ML20029C367
Person / Time
Issue date: 05/18/1990
From: Taylor J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
NRC
Shared Package
ML16252A423 List:
References
FOIA-90-415, FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9103270225
Download: ML20029C367 (26)


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UNITED STATES NUCLEAR REGULATORY COMMISSION I

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MAY I 81990 MEMORANDUM FOR:

See attached list FROM:

James M. Taylor Executive Director for Operations StJBJECT:

INFORMATION DISSEMINATIM ON BRC POLICY - STEERING GROUP ESTABLISHMENT Comission vote cheets regarding the Below Regulatory Concern policy statement have been submitted and a staff requirements memorandum can therefore be expected in the next 2-3 weeks. The Comission has requested the staff to proceed expeditiously with a program for disseminating inforv. ton on the BRC

- policy to Congress, media representatives, other Federal agendes, State and local authorities, Indian Tribal Organizations and the public. To accomplish this task, I concur with the Chairman's view that a working (steering) group

.of NRC managers should be established to develop and iglement a comprehensive strategy for releasing the BRC policy. This steering group will be chaired by Hugh L. Thompson, Jr., and will include the following membership:

JoeFouchard))

Public Affairs Carl Kansnerer State Programs CongressionalAffairs(DennisRathbun)

Technical Staff: HMSS Bob Bernero RES Bill Morris NRR FrankCongel)

Regions (Carl Paperiello)

OGC (Asneeded)

The charter of this steering group will include, but not be limited to, the following activities:-

Ass %ning the development of and. submitting to the

= E00.or-his approval, the briefing materials to be used by i.: spokespersons to support the release of the BRC policy.

Recommending to the EDO a list of NRC spokespersons from both headquarters and the regions.

Reconnending schedules and spokes >ersons to the E00 to accomplish specific briefings to r deral agencies, State e

and local authorities, Congress, etc, I

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9103270225 910320 bKE o 415 PDR i

.k Addressees Assigning the development of and submitting to the EDO -

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-for his approval, the content of letters to Congress and Governors and the material to be used by the Chairman and EDO in their telephone contacts.

As appropriate, the Comission will be informed or requested to approve Steering Group products or activities.

A tentative schedule of activities is attached along with the latest draft of a briefing booklet currently being developed by GPA with the help of an outside contractor. Copies of the Comissioners' vote sheets (Limitad Distribution) on the BRC policy will be provided separately, i

The initia1' meeting of the' steering group will be held on Thursday, May 24, 1990 in conference room 8B11 from 10:00 a.m. to 2:00 p.m.

The agenda for i

this. meeting will include a discussion of the charter and activities of the steering grou).

I am also asking that you be prepared to present your opinions on tle scope and content of the briefing booklet as well as suggesting potential candidates to act as NRC spokespersons.

aies M. T lor ecutive irector for Operations

Attachment:

As stated

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i BELOW REGULATORY C0t!CERN A GUIDE TO THE HUCLEAR REGULATORY COMMISSION'S POLICY OH THE EXEMPT 10H OF YERY LOW-LEVEL RADIDACTIVE MATERIALS, WASTES AND PRACTICES 5/7/90 l

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"Be1w Regulatory Concern" (BRC)

What is BRC Tho Huclear Regulatory Comission (NRC), is the Federal agency who cission is "to ensure that the uses of nuclear materials, facilities and activities are conducted in a manner consistent with the needs of pubit Ar. part of that siission, the NRC health, safety and environmental quality..."

is introducing a new policy related to the safe managerwnt of extreme leveis of radiation.

Termed "Below Regulatory Concern" -- or BRC, this new policy define d

radiation levels with such a small health risk that further effo those levels are unwarranted.

The BRC policy statement does not represent a decision to exempt any specific consumer products, waste or any other material or fractice Instead it creates guidelines for exemptions of radiation regulatory control.

e.xposure levels that are equal to or less than changes in radiation in one's natural surroundings or normal daily activity.

In the past, the Comission has exempted certain types, uses and Now quantities of materials from regulatory control on a case-by-case ba it is introducing a policy that will allow it to consider exemptions on a more consistent basis.

. Dfa The granting of such eFetaptions, based on carefully considered crittiia could allow the better allocation of resources, of both the NRC and its Itcensecs, to matters core essential to protecting the health and safety of workers, the public and the environment.

The HRC is not alone in the practice of exempting from regulation The materials that pose very little hazard to the public health and safety.

Envfronnental Protection Agency (EPA) uses a BRC-type concept when def hazarcous waste, approving residual levels of pesticides and deciding "how Similarly, the Food and Drug Admints-clean is clean enough" in site cleanup.

tration(FDA)definesacceptablelevelsofpotentialcarcinogensinprocessed The goal of NRC, as well as foods and approves the use of certain drugs.

other regulators is to ensure that the public is not exposed to unacceptable risks associated with regulated activities.

We In this booklet we will provide some background on this new policy, We will explain the criteria and the will explain why BRC is needed.

And we will describe how this nolicy will be reasoning behind them.

topiemented in acccrdance with existing NRC rules and pocedures.

Why a BRC Policy is Needed There are a number of reasons why the NRC is issuing its BRC policy.

Primarily, such a policy is needed to establish a consistent risk framcwork 2

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for regulatory exemption decisions, to ensure an adequate and consisten of protection of the public in their use of, and exposure to, radioactive r.aterials, and to focus the Nation's resources on reducing the most significant radiological risks.

The average U.S. citizen should benefit from the implementation of the BR policy through:

timely cleanup of contaminated nuclear sites; increased assurance that adequate funds are available to decomission operating nuclear facilf tfes; potential improvement in medical treatment and other services that use radioactive materials afforded by optimal use of federal, State and-licensee resources; enhanced low-level radioactive waste management practices commensurate with potential risks, and increased assurance that consumer products containing radioactive material under the Comission's jurisdiction are safe.

All of these benefits should eventually accrue as a result of a well-implemented BRC policy.

3

  • ' DRAFT,

Why BRC flow Wny does tiRC need a BRC policy now? Why can't it just continue business To answer this it is necessary to as usual, as we have in the past 25 years?

understand some of the factors requiring new policy direction in the regulation of-nuclear activities. These factors run a gamut of needs, including those to deal more effectively with the wastes from the country's many nuclear power plants,-to clean-up contaminated comercial nuclear facilities, to avoid hanrds that might be associated with the growing number of consumer products containing radioactive materials,-and to assure the continued safety of the expanding practice of nuclear medicine and use of radiation and radioactive All of these areas of concern involve the need to materials in research.

reexamine and reconsider regulation involving very low levels of radiation.

Part of the impetus for the NRC to develop a BRC policy statement has Section 10 of the Low Level Waste Amendment Act of come from the Congress.

1985 directed the Comission to consider the merits of "...(exempting) specific rt.dioactive waste streams from regulations...due to the-presence of.

radionuclides...in sufficiently low concentration or quantities as to be below Such direction from the Congress gave legislative regulatory concer n."

emphasis to the need for the NRC to esteblish a BRC policy, one that would set forth a consistent risk framwork for exemption decisions -- that woulu apply the same risk yardstick in all cases.

A foremost need for the BRC policy is related to NRC's responsibility for regulating the cleanup of contaminated comercial nuclear facilities around This can be more bmadly categorized as the "decomissioning the country.

4

' DRAFT.

6 In brief, it involves the NRC's need to ensure that the funds put issue.'

aside by licensees for closure of a facility at the end of its operating lifetime are sufficient to get the job done.

In order to do that the In other Comission must determine target levels for residual rooicactivity.

words, it must decide on how clean is clean nough. BRC policy will establish a framework for those criteria.

It is important to set forth this policy in a timely fashion so that the responsible parties are able to provide the necessary resources to perform the cleanup needed to satisfy the regulatory Such sites, having been deeined safe, would then be available for standards.

other valuable public or private use.

The exemption of certain consumer products that contain radioactive There is materials is another area addressed by the Comission's BRC policy.

a need to ensure that current and future exemptions of consumer products are Some degree of inconsistency from a risk perspective adequate and consistent.

A well-conceived may have existed in the past when exempting certain products.

ar.d well-implemented BRC policy car 2 void this in the future.

Another issue involved in the BRC policy is the management of wastes that ccntain very low levels of radioactivity, and therefore, according to BRC criteria, may not need to be disposed of in licensed low-level waste sites.

This is the y st controversial of the BRC issues from the public's point of from disagreement over what constitutes a ' safe"

. t view. The

'troversy s ems or ' risk-f ta level of radioactivity.

As will be discussed in some detail-below, in creating its BRC policy the NRC has used highly conservative criteria, based on'the latest scientific research findings, to estaSlish at v-w

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.y what level these very low level radioactive wastes may be exempted from being placed in licensed radioactive waste disposal facilities and yet be manage safely.

BRC as an Economic Issue In formulating its BP'., policy, the Comission considered first and forecast its mission to protect the henith and safety of people and the For However, it recognizes that BRC is an economic issue.

environment.

example, the management of wastes -- all kinds of wastes -- involves costs.

And those costs can vary greatly fepending on such factors as handling, The latter might range from packaging, transportation and final disposal.

recycling to incineration to landfill burial to some type of engineered Aside from their diract costs, these approaches vary in their containment.

impact on the environment, and hence also involve broader considerations a trade-offs.

In addition, the cost of regulation itself was a f actor beyond establishing a BRC policy. Considered were the costs to NRC to conduct ifcensing and other regulatory activities as well as the costs to its licensees to comply with the regulations.

In both cases resources, including And the time of highly trained personnel, must be allocated to these needs.

in many instances, particularly where health care and medical research are involved these are resources that might better benefit the public by being devoted to other activities, incluaing many that would be more proCuctive in furthering public health and safety.

6

DRAFT

  • i The policy will not allow the NRC and those who use nuclear materials simply to walk away from costly regulations and profit from decreased c the expense of public health and safety.

On the other hand, no amount of regulation, short of that which would completely eliminate an activity, can guarantee its zero risk.

Regardless of whether organizations " profit" directly from less regulation, the cost of regulation ultimately is paid for by the public in Thus the forms of the higher costs of products and.ervices and higher taxes.

And these are all regulatory matters do inyolve economic considerations.

invariably factored into the risk / benefit thinking which shape public policy.

One objective of a policy related to health, safety and the environment --

whether it involves clean air, water pollution, chemicals, waste managnent or The Comission's radiation - -should be to define a level of acceptable risk.

BRC policy does this. -To demonstrate how, it is necessary to provide some perspective on the matter of rediation and health.

Radiation: Some Background and Perspective s

"kat does this -

It is sometimes said, "We live in.a sea of radiation."

meant For one thing, it means that-this planet is continually bathed by vartuus kinds of radiation from the sun and space..This includes the photons 7

D_ RAFT "

4 that produce visible Itght, infrared rays, x-rays, microwaves, and other forms cf cosmic radiation.

The earth itself is also a source of radiation, which comes from the These materials, called radioactive materials in its soil, rock and water.

radioactive isotopes -- or radioisotopes -- are unstable variations of There are a great many of these, the most natural, non-radioactive elements.

comon being uranium, thorium, radium and the radioactive isotopes of carbon, Also comon in nature is radon gas, a radioactive by-potassium and sodium.

product of the small amounts of uranium found in the soil and rock of many All these, along with certain cosmic rays, are natural parts of the country.

sources of ionizing radiation.

Ionizing radiation is the most concern because, in its various forms --

I-rays, alpha and beta particles, and gama rays -- it can disturb the structure of the atoms it strikes, and therefore damage the cells of % s But we In most cases these damaged cells repair or replace themselve.

body.

also know that in some cases the damage can result in genetic autations and cancer. The possibility and incidence of this depend to a great extent on the amount of exposure to the radiation -- more precisely, the intensity and The units of radiation dose length of time of 1,he exposure called the dose.

are the " rem," and the " millirem" (abbreviate mrem) which is one-thousandth of a rem.

We all receive doses of naturally occurring radiation every day. They come from space, from the air we breath, the water we drink, the food we eat, the buildings we live and work in, and even the people we-live and work with.

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All together such sources (.ontribute about 80 percent of total average dose J

p The remaining 20 percent or so corxs from received in the U.S. popult m n.

man-made spurces of radiation, including medic.a1 x-rays and nuclear redicinc

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technologies, which together account for about 15 percent, and consumer l

products, occupational exposures and various othe* sources, whkh account for 2

the small remaining K rcentage. A more detailed breakdown of these percentages can be seen in Ng.1, prepared by the flational Council on Radiation Protection and Measurement.

(Fig.8.1fromNCRP93).

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While a knowledge of thase percentages is importan6, perhaps were inportant to an understanding of SRC policy is some perspective on radiation Large, quick doses of rcdiation, to the whole body, in the range of dosages.

a fa hundred rens and upward, are usually lethat or result in cancer or The risk of developing tha latter oiseases, however, d)es drop off leukemia.

as the dosage decreases.

r There is some evidence that the risk of cancer following radiation exposure 1s proportionate to dose, that it is dependent on the rate at which-I the dose is received, and that there is no threshold belov which there is no This set of assumpt b e has been adopted in the interest potential problem.

of being conservative where human lives might be effected.- The International Consission on Radiological Protection (ICRP) and the U.S. National Council on RadiationProtection_andMeasurements(NCRP)havebothendorsedthe"no threshold" approach, therefore endorsing the philosophy that radiation The U.S.

exposure should be kept at the lowest--leYe1 reasonably achievable.

  • 1110ws this principle, S

NuclearRegulatoryCocnission'(NRC t

9

'URAFT Bearing all this in mind, as well as the higher levels of radiation we discussed, let's move way down the scale to the level of radiation dosage the average citizen receives in the course of his or her daily life. And to do this we must begin at a level that is only a minute fraction of those higher doses. For the fact is that the average annual effective dose of radiation in the U.S. population is about 360 millirems (mrcm), thousands of times below the lethal doses we initially discussed.

Of that 360 mrems, about 300 cotes from natural sources -- the earth, cosmic rays, our food, bodies and natural surroundings, as we pointed out earlier. A little more than 50 mrems comes from medical diagnosis and treat-ment using radioactive sources. And the remaining amount, less than 10 mrems, comes from a variety of sources, including nuclear facilities and consumer products.

Our life styles and daily activities vary these amounts to some extent.

For example, if you live in Denver, "the Mile High City," rather than a sea-icve.1 city such as Boston or San Diego, you receive an additional rnnual e.xposure of some 50 mrems, since the dose from cosmic radiation essentially doubles with each 6,600 feet of altitude in the lower atmosphere.

By the same token, air travel increases your exposure to cosmic rays et the rate of about 2 mrems per nour for high altitude flights.

Also, if you choose to live in a brick home instead of one of wood you may add up to 10 mrems per year to your annual radiation exposure.

In addition, should your hote be in a certain area of the country where there is more uranium or radium in the soil you may have a high concentration of radon 1e

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'-c Rddon in the home has become recognized as the largest and in your house.

potentially most hazardous of these natural variations of radiation exposure.

As a result, more attention is being devoted to reducing its concentration in the how through ventilation systems and other technologies.

Few of these variations of natural radiaticn exposure, however, can be With the exception of vary large radon exposure, the cffectively controlled.

y amounts of radiation involved are relatively small, compared to thz average exposure to backgrouno radiation. Also, their health risks are low, as compared to other risks we freely face every day.

. l It is at a level of radiation dosage well below these variations in exposures resulting from natural sources that the NRC has created the framework for its new policy, it is at these very low levels, involving extremely low risks, that the NRC w(ild consider broader exemptions from concern.'

regulation and deem certain sources and practices "bolow regulate let's Turn to the specific principles and With this as backgroune criteria that the W ' used in establishing a BRC policy and how it-plans to implement that policy.

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BRC Criteria What levels of radiation and risk. place p-oducts and practices in the C

And how uid the HC arrive at category considered below regulatory concern?

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TORAbe Jits new criteria, along with its principles of exemption, for a formal BRC

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.First-the. principles major consideration in exempting any pracuce from regulatory control hinges on the question of whether the control is

nscessary for public health and safety and cost effective in reduelog a smail

. hen it comes to-radiation, the need for regulatory control decreaset W

risk.

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- as the-dose:and its risks to the exposed population decrease below the public dosallimit.

At a sufficiently low level of risk, the NRC believes that the granting of. specific exemptions from regulatory controls should depend

'assentially onian_ evaluation of whether the. risks are-sufficiently small.

(Therefore,- the HRC believes that individual and population dose criteria Eshould beibasic features'of?its overall polig. That polig.Muld define the repen where reductions in e,posure are no longer warranted.

' The questio'n then is:

Howl low is low?..-.or more precisely-sufficiently l

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Tow.,4when it= comes to risks and frems?- At wh't p< rt hould there be i

negligible merit in paying-more to' further reduce the risk or dose?

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In_ deciding' this11n! terms; of radiation dose? to' the individual.;the NRC -

3 Tooked at the matter from two perspectives. -The' first related to quantitative

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1 risk lehels.- Based on' analysis of-voluntary and involuntary risk connonly iaccepted by?the public without significant concern.Ethe NRC believes that most.

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therefore risks, knowingly or unknowingly tolerated by individua s Related to this the

-factors such as their lifestyle or where they live.

il Comission noted that people don't spend resources to reduce th diation; for exposures associated with variations ir natural background ra ived in

-_ example, the _50-60 mrem per year difference between annual-do i

Nor do they spend more to Denver, Colorado vs. Philadelphia, Pennsylvan a.brick or frame house, or to reduce the difference in' doses between living.in a t air eitminate the 5 mrem dose 'one mid receive in a round trip coast-to tion iflight,or to lower the dose from other activ ies involving a small frac o

- of. background radiation.

Taking all this into consideration. -as_ well as the uncertainties ivolvsd in risk assessment-at low doses. NRC decid

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'cose ai 10-miem per year would be appropriateffori use as the criter t additionalf resources need to be, spent to reduce -

twould define whether:or no further the dose 'as'sociated with a practice., However, until m ltiple sources,

-wa', gained with the' potential:for individual:exposuin:from mu Comission decided that an interim individualdose cr I he t

idespread

mrem per year, would be applieo to. those practices involving w distrib'ution of material containing radioactive-substances, such as w

d products or recycled material:and equipment. The interim sinLa.small fraction of HRC's' (additional assurance that public. doses will public dose _ limits forL licensed nuclear activitles -and of _ba 131 4

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(Seefigs.2&3: " Comparisons of BRC Practices to Exposures Lifestyle Choices & Hedical Technologies.")

The 10 mr.:m per year How do these dose levels translate into risks?

The 1 corresponds to an annual risk of developing cancer of 5 in 1 million.

crem per year corresponds to a risk of 5 in 10 million.

These values will provide a consistent risk basis for future rulemaking cr licensing decisions, making such implementation a practical undertaking.

FFC believes that regulatory exemptions under the 10 mrem and 1 mrem criteria will provide reasonable assurance that individual exposures to the public from all-licensed activities and exempted practices would not exceed 100 mrem per Such assurance is based on the fact that the NRC:

year.

Believes individuals will be exposed to only a few practices, Intends to define practices broadly, so that the effect of an exemption decision on-any individual or population will be evaluated in its entire?, and not in piecemeal fashion, Will evaluate potential ex b res over the lifetime of the a

practice, Plans to monitcr.and verify hov exemptions are implemented under this policy, Will verify dose calculations through licensing reviews and rulemakings with full benefit of public review and connent, 14

J

. DRAFT Plans to inspect and enforce licensee adherence to requirements imposed by HRC on exempted practices, and Will impose a companion criterion to limit the sum of all individual doses -- the collective dose.

It is the sum of individual More precisely, what is a " collective dose?"

doses received in a given period by a specified population from a specific If the collective dose resulting from a given practice source of radiation.

is less than 1,000 person-rems per year (equivalent to 1,000,000 individuals receiving 1 mrem per year), resources would be better spent address.ag more

.at this collective dose level, the number of significant health issues.

health eff+ cts for an exempted-practice is calculated at less than one annually.

BRC c licy Implementation o

With the above criteria for both individual ud collective exposures the NRC would have a strong basis for granting exemption from regulatoly control However, other specified conditions would fcr certain products or activities.

also have to be met such as determining that the risk from an accident or from The Comissicn also may place certain conditions or misuse would be very low.

constraints on the activity that generates or manufactures the exempt

- material, such as limits on the total quantity of radioactivity and the In addition,

' transfer of materials from controlled to treontral?ed status.

liRC would continue its comprehensive pro p a uf licensing, inspection and enforcement for that process.

15

-' DPf5T Acti ities that could be considered for exemption under the NRC pol-lcy include:

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Release of decontaminated lands and buildings for unrestricted public use, Distribution of consumer products containing very small amounts of radioactive material, Recycling of slightly contaminated equipment and materials, Otsposal of very-low-level radioactive waste at places other than p

licensed low-level radioactive waste disposal facilities and Y

Release of materials with very low radioactivity levels from licensed facilities.

Issuance of the BRC policy statement does not represent a decision to exempt any specific consumer products, wastes or other materials or practices from regulatory control. Rather the policy statement is a guideline for such exemptions.

The policy will be implemented principally through the NRC's rulemaking process. However, exemption decisions coula also be made through specific licensing actions.

1b

DRAFT In the first case, a proposal for ( u ption, whether initiated by the NRC or requested by outside parties in a petition for rulemaking, would have to provide a basis up:n which the Comission could determine if the basic policy conditions have been satisfied.

Such a proposal would have to address the individual and societal impact that could result it the exemption were granted. To do this the proposal would have to consider the uses of the radioactive materials, their pathways of exposure and their levels of radioactivity.

It would also have to consider the methods and constraints for assuring that the assumptions uscd to define a practice ruain appropriate as the radioactive materials nave from a controlled to an uncontrolled status.

Ano.her requirement would be publication of the proposed rule in order to solicM public coment on it. The rulemaking action would also include an appropriate level of environmental review under the National Environmental Policy Act.

The second means of implementing the BRC policy would involve exemptions granted through licensing actions.

Before any specific exemption is granted, an announcement would be published in the Federal Register to explain clearly P

the details and particular circumstances associated with th yoposed exemption. The public would then have an opportunity to.cmment on the proposed exemption.

And their connents would be considered before the Con::ission made its final decision.

'1

ORAFT How, what happens af ter a product or practice goes through all the n2cessary pro %dures and receives an exemption?

Is it then free of further surveillance? No. The NRC will verify that licensees adhere to exemption constraints and conditions through HRC's licensing, inspection and enforcement programs.

In addition, the Comission will require some type of labeling so that consumers could rake informed decisions about the purchase of a product containing exempted materials.

Such labeling is presently required by the Comission for smoke detectors containing radioactive material.

The NRC may determine on the basis of risk estirates and associated uncertainties that specific practices should not be considered candidates for exemption. A prime example woulo be the introduction of radioactive materials into products to be used primarily by children.

Such practices would be specifically evaluated to determine if they could result in greater risk levels to exposed members of the public than those found acceptable by the Comission in formulating a BRC policy.

BRC -- A Final Thought The aim of this booklet on the Below Regulatory Concern policy is to

_ provide information about any changes that might be seen as affecting the health and safety of the public and the environment. NRC believes that this policy will not compromise health and safety. Also, by allot ing better allocation of resources, the NRC policy will ultimately improve opp.tunities to serve the public better.

It will allow the NRC to d' vote snore of its time, trained pe sonnel and limited funds to nuclear related matt!:rs that must i

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. receive r. ore re'gulatory-attention.. It will allow other organizations, in isuch fields as health care, scientific research ed the development of new and useful products and services, to devote more of their resources to activities that best serve the public.

'i But the-success of any public policy depends largely on its understanding cand acceptance by the public.

We hope that this booklet, and its explanation of our new Below
Regulatory Concern policy, contribute towartf these ends. -

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' INITIAL' IDENTIFICATION 0F SPOKESPERSONS BY STEERING' GROUP-30'-

' STAFF' REQUIREMENTS MEMORt.NDUM ISSUED'(EARLIEST ESTIMATED DATE'- IF.SRM ISSUED

'LATER,tDATES FORL* ITEMS'MAY BE REVISED).

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PRELIMINARY' BRIEFING PACKAGE APPROVED BY STEERING GROUP FOR USE IN? INTERNAL;MRC:PRIEFINGS' t

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' REVISED BRC POLICY STATEMENT 10 C0ff4ISSION WITH PRELIMINARY

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AUGUST 14 -

BOOKLET ON BRC AVAILABLE FOR DISTRIBUTION'-(PA CONTRACTOR) i-14/20

BRIEFINGS TOLOTHER GOVERNMENT AGENCIES *-

' (EPA.ON.14TH, THRU DOE; FDA ETC.).

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PUBLISH BRC-PCLICY: STATEMENT IN FEDERAL REGISTER *

.J CHAIRMAN CARR'S LETTER-T0 CONGRESS / GOVERNORS /ETC.;

REGIONS TO DISTRIBUTE TO.-SELECTED LOCAL OFFICIALS (PREPARED BY GPA/SP..AND' APPROVED BYJ: STEERING GROUP)*

1 ISSUE!PUBLIC: ANNOUNCEMENT (PR.ESS RELEASE)*~

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21/30 DO INDIVIDUAL PRESS INTERVIEWS / EDITORIAL BOARDS *

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HEMORANDUM FOR: See attached list FROM:

James M. Taylor Executive Director for Operations

SUBJECT:

INFORMATION DISSEMINATION ON BRC POLICY - STEERING GROUP ESTABLISHMENT Commission vote sheets regarding the Below Regulatory Concern policy statement have been submitted and a staff requirements memorandum can therefore be expected in the next 2-? weeks.

The Commission has requested the staff to proceed expeditiously with a program for disseminating information on the BRC policy to Congress, media representatives, other federal agencies, State and local authorities, Indian Tribal Organizations and the public. To accomplfsb this task, I concur with the Chairman's view that a working -(steering) group of HRC managers should be established to develop and implement a comprehensive strategy for releasing the BRC policy.

This steering group will be chaired by Hugh L, Thompson, Jr., and will ir.clude the following membership:

PublicAffairs(Joetouchard))

State Programs (Carl Kammerer CongressionalAffairs(DennisRathbun))

Technical Staff: HMSS Bob Bernero BillMorris))

RES frank Congel NRR Regions CarlPaperiello)

OGC Asneeded)

The :harter ef this steering group will include, but not be limitc; to, the following ~ activities:

Assigning the development of and submitting to the LD0 for his approval, the briefing materials to be used by NRC spokespersons to support the release of the BRC policy.

Reconnending to the EDO a list of NRC spokespersons from both headquarters and the regions.

Recommending schedules and spokes aersons to the EDO to r deral agencies, State accomplish specific briefings to e

.and local authorities, Congress, etc.

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