ML20033F833
| ML20033F833 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Zech NRC COMMISSION (OCM) |
| Shared Package | |
| ML20033D930 | List: |
| References | |
| NUDOCS 9004030226 | |
| Download: ML20033F833 (2) | |
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UaHTED STATES NUCLEAR REGULATORY COMMISSION
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MEMORANDUM FOR: Chairman Zech FROM:
Victor Stello, Jr., Executive Director for Operations l
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SUBJECT:
DRAFT (PARTIAL)CANADIANREPORTONDEMINIMISDOSERATE l
The purpose of this memorandum is to respond to your request of July 26, 1988, for NRC staff review and comments on the subject proprietary document. The staff will further address this subject in its efforts to develop a Comission policy statement on exemptions from regulatory control for practiets uhose public health and safety impacts are below regulatory concern.
Htwever, the staff wreuld like to take this opportunity to discuss teveral points regarding the Canadian report which should enhance a common understanding on this subject.
The policy statement being developed by the NRC staff incorporates many of. the features of the Car,adian proposal; however, the staff's proposal is directed at all practices involving vse of radioactive m6terial including cors.umer products and recycled ecuipment and materialr as well as waste. These practices involve l
possible wide cistribution of radioactive material directly to members of the general public -- a fact which forces consideration of exposures to multiple I
exempt practices. The Canadian proposal is principally directed at disposal of l
low-levelradioactivewaste(seepage 9).
In its use of de minimis dose, the I
Atomic Energy Control Board (AECB) has stated that the value applies only if the radiological impact is localized and the potential for exposures of large populations is small.
The Canadian proposal for 50-uSv yr*I (5 mrem / year) individual dose Gr exempt disposal of waste is related to the I AEA recomendation of 10-uSv yr (1 mrem / year) for an exemption based on the assumption that a single individual might be exposed to as many as 10 exemptions, including those from consumer products, etc. However, this conservatism can be subject to legitimate argu-ment if the concept of de minimis dose rates is intended to cover this single practice and other exposures resulting from consumer products and recycled equipment and materials. As a point of comparison, the NRC policy statement, General Statement of Policy and Procedures Concerning Petitions Pursuant to 62.802 for Disposal of Radioactive Waste Streams Below Regulatory Concern, (51 Fit 308392) dated August 29, 1986, indicated that petitions for a specific disposal practice which involves individual doses in the range of a "few mrem" would be acceptable as candidates for expedited exemption consideration.
l The Canadian position also includes a collective dose rate of the one person-Sv yr"y (100 person-rem / year). This collective dose is consistent with the IAEA recomendation. Since this collective dose criterion apparently involves cost-benefit considerations (page 8 - NRPB), the staff, in its current thinking, j.
would not describe these radiation dose rates j "de minimis" but as "below 9004030226 900316 1
Chairman Zech 2
regulatory concern," a term which the staff believes connotes a cost-benefit assessment, j
1 In summary, there are significant differences in the subjects covered by the
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staff's proposed Comission policy and the Canadian proposal; however, the use l
of a risk-based approach and the definition of acceptably low-levels of
' individual and collective dose as a practical basis for exempting practices 1
from regulatory control are similar in both documents.
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d-s Victor $ ell'o, Executive Director for Operations cc: Comissioner Robercs i
i Commissioner Carr Comissioner Rogers SECY H
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