ML20042D082
| ML20042D082 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1988 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 8810060195 | |
| Download: ML20042D082 (21) | |
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September 14. 1988 THOMPSON
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l MEMORANDUM FOR: Victor Stello, Jr.
t Executive Director for Operations FROM:
Hugh L. Thompson, Jr., Director, Office of Nuclear Material Safety and Safeguards
SUBJECT:
NMSS CONCURRENCE ON THE BRC POLICY STATEMENT This memorandum supersedes the HMSS nonconcurrence on a portion of the proposed BRC policy statement which discussed the application of 10 mrem per year as the dose level for which exemption could be granted without further analysis contained in the September 8,1988 memorandum to you. For the reason noted below, NMSS now concurs that the revised BRC policy statement can provide adequate protection to public health and safety.
The NMSS preference for the few mrem per year dose level (identified as "on the order of 1 mrem /yr" in the earlier policy paper) was based on two L
considerations. The first consideration was related to the ability to achieve I
broad national and international agreement and support. As noted in the l
earlier memorandum, other regulatory agencies.and several international organizations currently favor the few mrem per year levels for BRC levels.
few mrem per year range (policy viewpoint,)HMSS believes a dose icvel in theis more From a pure e.g.,1-4 mrem /yr L
less likely to confuse the public because of different regulatory standards for The current EPA proposed standard for disposal of low-level the same hazard. ~
radioactive waste, which is before OMB for review, sets a 4 mrem /yr limit for dose from unregulated radioactive waste release. That limit includes doses from all other low-level radioactive waste streams which have been classified as having radioactivity levels which are Below Regulatory Concern. Moreover, disposal of these BRC wastes would be ' allowed only in those ways expressly permitted by NRC, Agreement States, or the Department of Energy. Although adequate to protect public health and safety, a BRC dose level of 10 mrem /yr and a cumulative population dose of 100 person-rem /yr for a single practice I
may be far more controversial than necessary and result in delays in getting Thus, those policy concerns that lead NMSS to favor the program implemented.
the lower levels (e.g., a few millirem as stated in the Commission BRC policy statement for waste streams) remain as discussed in the earlier memorandum, i
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THOMPSON 2-The second consideration was of possible dose accumulation that could result from multiple exposure pathways, resulting in some individual doses ap) roaching or possibly exceeding the 100 mrem per year dose limit. That concern las been reevaluated and is now superseded. Based on further discussions '-tween the Offices of Research and HMSS, the intent of the proposed BRC pol'.o statement has been clarified to consider combined radiation exposure from rd.ciple exempted practices in a more rigorous way (see the revised page 9 of the proposed policy statement). The changes made are sufficient to resolve the The extent of the effort and the resources required NMSS technical concern.
to evaluate the possibility of multiple exposure pathways will be determined by the experience gained in implementing this BRC policy.
In sumary, NMSS concurs that the proposed BRC policy statement provides an This assurance is adequate approach to protect public health and safety.
provided by the 100 person. rem guidance and the evaluation by the NRC staff to identify and to require further analysis if the potential exists for an individual to accumulate significant exposures from multiple practices.
g Hugh @
gp Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards cc:
E. S. Beckjord, RES l
T. E. Murley, NRR H. R. Denton, GPA l
p DISTRIBUTION HLThompson RBernero DACool Wlahs, RES l
RECunningham BMorris, RES GLSjoblom JHickey l
FCongel, NRR JAustin RFonner, OGC MLamastra LRoche, EDO IM0B R/F NRC File Center IMNS Central NMSS r/f NMSS Office r/f l
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NAME:HLTrRim) son:bsp DATE:9/lLl/88 UttAL1AL Kt.UURU LUPY
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PROPOSED POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL STAFF PRESENTATION TO COMMISSION JUL'Y 11, 1989 l.
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- BACKGROUND
- PURPOSE OF PRESENTATION
- OBJECTIVE OF POLICY STATEMENT i
- ACTIONS TAKEN IN RESPONSE TO COMMENTS
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- POLICY' CLARIFICATIONS
- PROPOSAL ON MAJOR POLICY ELEMENTS
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SUMMARY
-KEY' POLICY ELEMENTS
- OTHER IMPORTANT POLICY CONSIDERATIONS-i l
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BACKGROUND SRM-NOV 1987-IDENTIFY RISK LEVEL BELOW WHICH G0v'T REGULATION UNWARRANTED
't SECY 88-69, MAR: 1988-CONCEPT DISCUSS 10N' SRM-MAR 1988-REQUESTS POLICY STATEMENT SECY 88-257,-SEPT 19EC-PROPOSED POLICY COMMISSION AUTHORIZESLPUBLICATION OF
- ADV. NOTICE SOLICITING COMMENTS ON o
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e PURPOSE'0F PRESENTATION TO DISCUSS REVISED POLICY STATEMENT AND THE RATIONALE FOR STAFF PROPOSALS ON KEY POLICY ELEMENTS CONSIDERING INPUTS FROM:
- THE INTERNATIONAL WORKSHOP-0CT 1988
- PUBLIC COMMENTS RECEIVED ON ADVANCE l
u NOTICE ISSUES (DEC 1988-APR 1989)
- PUBLIC MEETING-JAN 1989 1
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i OBJECTIVE OF POLICY STATEMENT i
To ESTABLISH GUIDELINES AND CRITERIA FOR DEVELOPMENT OF REGULATIONS OR LICENSING DECIS!CNS WHICH COULD EXEMPT PRACTICES FROM SCME OR ALL REGULATORY. CONTROLS i
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POTENTIAL POLICY APPLICABILITY TYPICAL PRACTICES DISPOSAL ~OF VERY LOW LEVEL RADWASTE RELEASE OF LANDS AND STRUCTURES WITH RESIDUAL LEVELS OF RAD 10ACT!Y1TY CONSUMER PRODUCTS CONTAINING SMALL AMOUNTS OF RADICACTIVE MATERIAL RECYCLE AND REUSE OF' RESIDUALLY' l.
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CONTAMINATED MATERIALS AND EQUIPMENT a
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ACTIONS TAKEN AS A RESULT 0F COMMENTS.
ON ADVANCE NOTICE OF-POLICY DEVELOPMENT CATEGORIZED AND RESOLVED-!SSUES IN 18 i
SUBJECT AREAS
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REVISED POLICY IN NEY AREAS CLARIFIED' COMMISSION POSITIONS IN OTHER AREAS l
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t POLICY ELEMENTS ON WHICH COMMENTS SOUGHT
- HOW SHOULD FUNDAMENTAL PRINCIPLES OF RADIATION PROTECTION BE APPLIED?
(JUSTIFICATION OF PRACTICE, DOSE I
LIMITS, AND ALARA)
- IS A COLLECTIVE DOSE CRITERION NEEDED?
- HOW SHOULD CUMULATIVE EFFECTS FROM MULTIPLE PRACTICES BE DEALT WITH?
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FOR A JUSTIFIED PRACTICE 1
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1 10 100 1,000 10,000 100,000 CoIIective Dose (Person-rem)
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" JUSTIFICATION OF PRACTICE" NEEDED' (1) NO EXPOSURE TO IONIZING RADIATION PERMITTED W/0 COMMENSURATE BENEFIT (2) WIDELY-ACCEPTED RADIATION PROTECTION GOAL s
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PROPOSALS ON MAJOR POLICY ELEMENTS (' CON'T)
COLLECTIVE DOSE CRITERION ADDED TO DEFINE " FLOOR" TO THE ALARA PROCESS (1) C010f0NLY USED BY REGULATORY BODIES AS MEASURE OF l
SOCIETAL DETRDfENT IN OPTDEZATION ASSESSMENTS ll2) USED BY OTHER U.S. AGENCIES & INCLUDED IN INTERNATIONAL GUIDANCE il3) ADDS ASSURANCE THAT DOSE LIMITS NOT EXCEEDED L
Il EXPOSURES TO MULTIPLE PRACTICES)
(4) REFLECTS POSITION THAT INDIVIDUAL DOSE CRITERION NOT "DE MINDES" eene es**ume T-
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't PROPOSALS ON MAJOR POLICY ELEM'TS (CONT.)
- MULTIPLE PRACTICE ISSUE ADDRESSED BY:
(1) BROAD DEFINITION OF " PRACTICES" (2) REQUIRING PRACTICE JUSTIFICATION (3) COLLECTIVE DOSE CRITERION (4) APPROPRIATE' PERIODIC ASSESSMENT (5) COMMITMENT TO CONSIDER ISSUE IN EACH EXEMPTION-DECISION 4
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OTHER MAJOR POLICY ISSUES RETENTION OF 10-MREM ANNUAL INDIVIDUAL i
DOSE CRITERION ALLOWS EXEMPTIONS WHET,' ABOVE NUMERICAL CRITERIA s
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- q POLICY CLARIFICATIONS CONSTRAINTS ARE ASSOCIATED WITH EXEMPTION DECISIONS NUMERICAL ALARA-CRITERIA ARE NOT LIMITS EMPHASIS INCREASED ON NECESSITY'TO
- DEFINE SCOPE OF PRACTICE APPROPRIATELY L
REFERENCE.To "BRC" RESERVED FOR' WASTE l
DISPOSALS UNDER'LLRWPAA oF 1985 L
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DIFFERING VIEWS ON MAGNITUDES OF l
EXEMPTION DOSE CRITERIA
- EPA, ACNW, AND INTERNATIONAL
- 1 COMPARABILITY OF EXEMPTION DOSE CRITERIA AND " ACCEPTABLE" DOSE STDS.
- TREND IN RISK COEFFICIENTS DEVELOPED FROM EXPOSURES AT HIGHER DOSES s
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'- KEY POLICY ELEMENTS r
REQUIRES. PRACTICE JUSTIFICATION AS BASIC POLICY ELEMENT PROVIDES CRITERIA FOR " CURTAILING" ALAP.A "0PTIMAL" RESOURCE USE INCLUDES FEATURES TO ADDREES THE
" EXPOSURE TO MULTIPLE PRACTICE",lSSUE L
PERMITS EXEMPTIONS BASED ON DEMONSTRATION OF ALARA IF NUMERICAL CRITERIA NOT MET a
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e INTERACTIONS WITH EPA STAFF PROPOSES THAT RESOLUTION OF ANY RESIDUAL DIFFERENCES WITH EPA CAN BEST BE.
ACCOMPLISHED THROUGH THE PROCESS OF DEVELOPMENT OF FEDERAL GUILANCE BY AN INTERAGENCY TASK FORCE.
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RECOMMENDATIONS
- - THAT THE COMMISSION APPROVE:
(1) PUBLICATION OF THE PROPOSED POLICY AND RESPONSE-TO PUBLIC COMMENTS IN u
THE FEDERAL REGISTER.
t (2) CONTINUING STAFF EFFORTS TO. WORK i
WITH EPA TO PLAN FOR DEVELOPMENT OF t
FEDERAL' GUIDANCE.
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