ML20042D112
| ML20042D112 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1989 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 8904070159 | |
| Download: ML20042D112 (22) | |
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MEMORANDUM FOR:
Bill M. Morris, Director
' Division of Regulations Applications--
Office of Nuclear Regulatory Research-FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
COMMENTS ON INTERIM POLICY STATEMENT c
ON RESIDUAL RADI0 ACTIVE CONTAMINATION LIMITS FOR DECOMMISSIONING As requested by your memorandum dated February 14,'1989, the
-interim policy statement on residual radioactive contamination limits for decommissioning has been reviewed and our connents are enclosed.
If you have any questions concerning our comments, please contact Kevin Ramsey of py staff (x20534).
L l
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated
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(c IMNS COMMENTS ON THE INTERIM POLICY STATEMENT ON RESIDUAL RADIOACTIVE CONTAMINATION LIMITS FOR DECOPHISSIONING DATED FEBRUARY 14, 1989.
l
Contact:
Kevin Ramsey, 492-0534 l-1.
This document does not clearly state the NRC policy on release criteria.
Af ter the supplementary information,- there should be a separate paragraph t
identified as the policy statement. This paragraph should simply and
- clearly state the NRC policy on residual radioactive contamination limits for decommissioning.
l' 2.
The second paragraph of the sumary section references the proposed
-l Comission Policy Statement on Exemptions from Regulatory Control For Practices Whose Public Health and Safety Impacts Are Below Regulatory
~
Concern. Only the advance notice of this policy statement has been published and we suggest referencing the advance notice only.
3.
Minimizing the impact on public health and safety is not necessarily the same as protecting the public health and safety.' We suggest rewording the third paragraph of the introduction to read, "...in a timely manner consistent with protection of the public and occupational health and safety and the environment and..."
4.
Delete " Application for license termination is made at the time of initiation of decomissioning" from the third paragraph of the introduction.
It implies-that decommissioning should be deferred until license termination. Decomissioning is required to permit license termination, but license termination is not required to perform decomissioning. Many large material and fuel cycle facilities decomission buildings and site areas as activities are discontinued.
It is preferable to have licensees perform decomissioning while an income is still being generated and they are not suffering a loss of management or technical staff.
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- 5.
The Current Radiological Criteria section should emphasize that final
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approval to release facilities for unrestricted use is performed on a case-by-case basis. NRC may establish site specific decontamination requirements and release criteria that are not specified in existing guidance.
6.
Delete the reference to 100 mrem /yr in the fifth sentence of the section on residual radioactivity below regulatory concern. The 100 mrem /yr dose-limit for members of the public is not currently in effect.
It is in the proposed revision to Part 20 and therefore subject to change. However, thegenericstatementthattheselevelsarebelowthedoselimit-(number unspecified)isappropriate.
7.
The last sentence on page 4 implies that inspection / compliance activities may-be' required for operations below regulatory concern (BRC).
It should be clarified to state that inspection / compliance activities will be required to determine if a licensee is complying with any conditions necessary to assure that the operation is BRC. Regulatory involvement is limited or ceases only after release,-not while the material is under the control of the licensee.
- 8.
The word " draft" should be deleted when describing the NRC Branch Technical Position in paragraph 3 on page 6 (occurs three times).
Neither the Commission Paper (SECY 81-576,10/5/81) informing the Commission that the staff was adopting the position, nor the published technical position (46 FR 52061, 10/23/81) used the term "draf t."
The published notice stated that any coments received would be considered in any subsequent revision.
9.
Recommend adding a paragraph at the beginning of the Planned Expanded Guidance section that briefly lists exactly what the existing guidance covers and what.it does not cover.
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, 4; 10.- Protection of groundwater has been the subject of increasingly restrictive regulation in recent years. The policy statement should address the protection of groundwater when discussing release criteria in the Planned Expanded Guidance section.
- 11. The first paragraph of the Planned Expanded Guidance section states that release criteria will be consistent with "the recently revised regulations in 10 CFR Part 20."
The major revision to Part 20 will not be effective until 1991. Suggest rewording the statement to state that the release criteria will be consistent with the revision of 10 CFR Part 20 currently under consideration.
- 12. -It is essential that decommissioning guidance retain the flexibility for licensees to propose alternative decontamination and disposal methods as presentlyauthorizedin10CFR20.302(a). A statement should be added to the end of the first paragraph in the Planned Expanded Guidance section that licensees who find that decommissioning at their facilities can be accomplished better by alternative methods, should apply under 10 CFR 20.302(a). A similar statement referencing 10 CFR 20.302(a) should also be added to the Release For Unrestricted Use section.
- 13. Please note the word " maximum" is misspelled on the first line af page 9.
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4, CG/2/89 NRC.NUMARC NEET. NOTES -
!UIR 0 2 999 MEMORANDUM FOR:
- Regis Boyle, Section-Leader Regulatory Branch
,-'~
Division of low Level Waste Management
- and Decosnissioning, NMSS' FROM:
Chad Glenn Regulatory Branch t
Division of low Level Weste Management and Decoraissioning, letSS
SUBJECT:
NRC.NUMARC MEETING MINUTES On February 23, 1989, representatives from the NRC and the Nuclear Management and Resources Council (NUMARC) met to discuss the content of a u
L petition for designating some nuclear plant wastes as Below Regulatory Concern.
The minutes for this meeting are enclosed for your infonnation.
(Original Signed by /
.)
Chad J. Gle Division of Low. Level Waste Management l
l and Decommissioning
Enclosure:
-As' stated Distribution:
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t NRC NUMARC NEETING ON-CONTENTS 0F BRC PETITION v
DATE:
- Thursday, February. 23, 1989 TIME:,
10:00 to 11:30 a.m.
LOCATION:
NRC White Flin't Bldg.
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-ATTENDEES:
See Attachment
' PURPOSE:
L On February 23,1989,_ NRC staff met with representatives of the Nuclear-H Management and Resources Council (NUMARC) to address questions concerning the
-content of a petition for designatin0 some nuclear power plant wastes as Below-Regulatory Concern (BRC).
DISCUS $10N:
NUMARC is preparing the petition with support from EPRI and EEI on behalf of;54' nuclear utilities.. NUMARC indicated that they expect to submit the petition to NRC in the Spring / Summer 1989 timeframe. The current thinking by NUMARC is
.that the submittal will consist of the petition with two attachments. One attachment will'be-a technical-support document prepeted by EPRI and-the second attachment will'be a sussnary of some 14 contractor reports on nuclear plant wastes.
NUMARC'had specific questions concerning information-needs relative'to criteria L
in NRC's Policy Statement on BRC waste Federal Register 30839, August 29, 1986). These questions-included: (1) should the regulatory anal environmental analysis be presented separately or combined; (2) ysis ano should the petition address the requirements in both 10-CFR 2.802 and the Commission
>PolicyStatement;(3)canthestaffciteexamplesofthetypeofinformation needed to address " Economic Ispact on Small Entities"; (4) should the.cid or new version of 10 CFR Part 20 be used when referring to Part 20; (5) does NRC L
have specific-sampling requirements or procedures for characterizing BRC waste.
l The NRC, staff provided the following guidance with respect to these questions.
- First, the petition should contain an environmental and-regulatory 3nelysis and these analyses should be presented as two separate; sections.
Socorn the p
petitioner should address both the requirements in'10 CFR 2.802 and the Commission Policy Statement. Third, the staff suggested that'NUMARC refer to-NUREG/BR 0053 or recently published rulemakings for examples of the type of information that should be included under " Economic Impact on Small Entities".
L Fourth, in reference to Part 20, the staff suggested that the petitioner use the definition of tenns contained in the proposed new version of Part 20.
This would facilitate processing of the petitien in the event the new proposed version of Part 20 is adopted prior to impleu ntation of the petitioner's
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proposal. This would also expedite a backfit if the new Part 20 becomes effective after implementation of the petitior.er's proposal.
Finally, the staff indicated that it had no specific requirements regarding sampling requirements or procedures for characterizing BRC waste. Rather, the staff indicated that the petitioner is in the best position to select the appropriate sampling procedure for the specific waste under consideration. The staff indicated that if new sampling procedures are adopted, the nuclear utility may have to amend its Part 50 license to reflect the change.
At the request of NUMARC, the NRC staff committed to provide NUMARC with a copy of the "NRC Regulations Handbook" (NUREG BR-0053).
NUMARC indicated that they l
nay request to meet.with the NRC staff again as they proceed in finalizing l
their petition.
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CONCEPT OF BRC BASED ON BELIEFS THAT RISKS FROM SOME REGULATED PRACTICES INVOLVING RADIOACTIVE OR OTHERWISE HAZARDOUS-MATERIALS MAY BE SUFFICIENTLY SMALL THAT EFFORTS TO REDUCE.THEM FURTHER f ARE UNWARRANTED. 5 -t FOLLOWING THIS CONCEPT, A' NUMBER OF DECISIONS ON EXEMPTION FROM REGULATORY CONTROL'HAVE BEEN MADE ON A CASE-BY-CASE L i BASIS (E.G., APPENDIX I, RELEASE OF MATERIALS INTO SANITARY. SEWERS, RELEASE 10F CONSUMER PRODUCTS, DECOMMISSIONING ACTIONS). l i HOWEVER, THERE IS NO GENERAL AGENCY POLI,CY OR GUIDELINES ON l HOW SUCH DECISIONS SHOULD BE MADE. l THE COMMISSION.HAS DIRECTED THE' STAFF TO DEVELOP SUCH.A' POLICY'FOR COMMISSION CONSIDERATION. L I
,gr ~a ~ i PERSPECTIVE ON-ANNUAL ~1NDIVIDUAL EXPOSURE LEVELS
- BACKGROUND EXPOSURE EXCLUDING RADON 100 mrem
- PROPOSED 10 CFR PART 20 DOSE LIMIT 1
UNRESTRICTED AREA' FROM : LICENSEE PRACTICES 100 mrem'- 1
- VARIATION IN COSMIC RADIATION WASHINGTON,DC. vs DENVER, CO
~ 25 mrem a
- EPA GENERALLY -APPLICABLE ENVIRONMENTAL STANDARD (FUEL ' CYCLE) 25 mrem
- CLEAN AIR ACT (under reconsideration) 25 mrem
- PROPOSED EPA BRC LEVEL-WASTE DISPOSAL 4 mrem
- COMMISSION ~ POLICY. STATEMENT (8/25/88)-
j i MAX. DOSEL CRITERIA-EXPEDITED HANDLING WASTE DISPOSAL PETITIONS a few mrem 1 10 CFR PART 50, APP.1-REACTOR EFFLUENTS .3 mrem liquid-1 = 10 f mrad air .f =.
- q -:y. PERSPECTIVE #ON EXPECTED EXEMPTED PRACTICES r PRACTICES INVOLVING WIDESPREAD DISTRIBUTION & USE OF RADIOACTIVE MATERIALS BY THE PUBLIC? l - CONSUMER PRODUCTS - RECYCLE OF SLIGHTLY CONTAMINATED EQUIPMENT & MATERIAL PRACTICES ANTICIPATED TO RESULT IN ONLY. LIMITED-INTERACTIONS WITH THE PUBLIC w - LAND DISPOSAL OF LOW LEVEL RADIOACTIVE WASTE - RELEASE-OF SLIGHTLY CONTAMINATED LANDS & STRUCTURES FOR UNRESTRICTED USE- - RADIOACTIVE EFFLUENT RELEASES 1 1 __...__...,4 m. c .,ean er,+.,,,- 9%.. g.___ _..3 si9..+.
. - ~. s o 4-
- b PROPOSED NRC POLICY P
i BASED ON FUNDAMENTAL PRINCIPLES OF RADIATION PROTECTION JUSTIFICATION OF PRACTICE DOSE LIMITS T0' DEFINE MAXIMUM ALLOWED' RADIATION LEVELS ENHANCED PROTECTION BASED ON ALARA PRINCIPLES [ RECOGNIZES THAT INDIVIDUALS MAY BE EXPOSED TO RADIATION FROM MORE THAN-ONE LICENSED OR EXEMPTED' SOURCE r ASSUMES LINEAR NON-THRESHOLD RELATIONSHIP BETWEEN LOW l RADIATION DOSE AND STOCHASTIC CANCER RISK. L MAJOR ELEMENTS OF PROPOSED POLICY EXEMPTIONS GRANTED ON DEFENSIBLE ALARA ANALYSIS, ASSUMING DOSE LIMITS ARE MET INDIVIDUAL RISK LEVEL DEFINING GENERIC FLOOR TO ALARA E (OR INDIVIDUAL RISK, COLLECTIVE RISK BOX) 4
-l ) PROPOSED'EXEMPTlON POLICY SCHEMATIC A 100D = N CLEARLY NOT EXEMPTABLE N l ts i A too eveuc oose umr-g D POSSIBLY 3o 7 O S E E i CLEARUf EXEMPTABLE I 5 EXEMPTABLE M R h o,, ~ ,,i,ii. 1 10 100 1000 10000 COLLECTIVE DOSE - PERSON-REM
INTERNATIONAL WORKSHOP ON EXEMPTION FROM REGULATORY CONTROL a i ON OCTOBER 17-19, 1988, AN INTERNATIONAL WORKSHOP WAS HELD IN WASHINGTON, D.C. IT WAS SPONSORED BY NRC IN COOPERATION WITH l NEA. REPRESENTATIVES OF 11 COUNTRIES AND SEVERAL INTERNATIONAL ORGAN!ZATIONS ATTENDED. KEY OBSERVATIONS OF PARTICIPANTS: JUSTIFICATION OF PRACTICE SHOULD BE FIRST PRINCIPLE IN MAKING EXEMPTION DECISIONS. l I PROPOSED NRC POLICY IS CONCEPTUALLY SIMILAR TO lAEA { GUIDANCE. THE PROPOSED NRC INDIVIDUAL DOSE CRITER10N IS HIGHER BY ONE ORDER OF MAGNITUDE THAN THE IAEA GUIDANCE. i COLLECTIVE DOSE CRITER10N -- NO CONSENSUS WAS REACHED ON THE NEED FOR THIS CRITERION -- NOTE THAT IAEA GUIDANCE INCLUDES A COLLECTIVE DOSE CRITERION. l PROCEEDINGS OF THE WORKSHOP WILL BE PUBLISHED AS A NUREG 1 REPORT. l 6
t 4e .= PUBLIC MEETING ON EXEMPTION FROM REGULATORY CONTROL I 9 MEETING WAS HELD ON JANUARY 12, 1989 -- 95 PEOPLE ATTENDED. i COMMENTS FROM INDIVIDUALS FROM THE NUCLEAR INDUSTRY SUPPORTED THE NEED FOR A POLICY RECOMMENDED A 25 MREM INDIVIDUAL DOSE CRITERION. l COMMENTS FROM PUBLIC INTEREST GROUPS: 10 MREM IS UNJUSTlFIE'), LIMIT SHOULD BE A LOT LOWER. NRC IGNORED SOME OF IHE INFORMATION AVAILABLE IN THE LITERATURE. [ i COMMISSION SHOULL WITHDRAW THE PROPOSED POLICY STATEMENT. COMMENTS FROM HEA TH PHYSICS SOCIETY 3 REEVALUATION OF THE HIROSHIMA-NAGASAK1 DATA EXPECTED TO RESULT IN AN INCREASE IN RISK COEFFICIENTS. i EMERGINf, INFORMATION REGARDING CELL REPAIR MECHANISMS AND WHOLE BODY PROTECTIVE MECHANISMS MIGHT HELP TO COUNTERBALANCE THE INCREASE. l COMMENTS FROM EPA -- SEE NEXT PAGE. l i 7
L.- ,JP EPA POSITION ON EXEMPTION FROM REGULATORY CONCERN RICHARD GUIMOND, DIRECTOR OF THE OFFICE OF RADIATION f PROGRAMS, COMMENTED ON EPA'S BEHALF. GENERIC LIMITS IT IS EARLY TO ESTABLISH GENft,1C LIMITS. DECISIONS SHOULD BE ON A CASE-BY-CASE BASIS. PROPOSED NRC POLICY 10 MREM IS TOO HIGH. COLLECTIVE DOSE OR SOME OTHER MEASURE OF SOCIETAL IMPACT MUST BE INCLUDED. POLICY STATEMENT IS BASED ON OUTDATED INFORMATION. POLICY WOULD NOT ADEQUATELY PROTECT PUBLIC AND t l ENVIRONMENT. j-l EPA ROLE EPA IS RESPONSIBLE FOR COORDINATION AND POLICY GUIDANCE. AT AN APPROPRIATE TIME, EPA WILL PROPOSE GENERIC LIMITS. NRC SHOULD WAIT WITH ISSUANCE OF GENERIC LIMITS. EPA AND NRC SHOULD WORK TOGETHER. CLEAN AIR ACT 8
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b-PROPOSED SCHEDULE PROPOSED POLICY STATEMENT TO COMMIS$10N (SECY-88-257). SEPT 1988 INTERNATIONAL WORKSH0P................................ OcT. 1988 PUBL!c MEETING........................................ JAN. 1989 REVISED POLICY STATEMENT TO COMMIS$10N................ APRIL 1989 PROPOSED POL 1cY STATEMENT ISSUED FOR PUBL1c C,0MMENT... JUNE 1989 FINAL POLICY STATEMENT ISSUED......................... JUNE 1990 9
o EXEMPTION PO!!cy Coments A number of commenters stressed the need for making any exemption regulation a matter of exact compatibility with Agreement States. All comenters who favored the development of the policy, and addressed the monitoring question, supported the need to monitor and enforce licensee's compliance with any developed exemption l regulations. International consistency was considered as desirable, but not necessary. 1. l l' l l t 1 l i
= l c' ?- t ( %' i ) e i t EXEMPTION POLICY Comments Comments evenly split on need for NRC exemption policy. Most commenters agreed that a criterion should be included to establish a floor below which it would be unnecessary to expend resources to further comply with ALARA principles. Essentially all supporters of the'need for a policy believed that flexibility should be maintained in the decision-making process. I l l i i m . m
i t< s. e i i s e a i EXEMPTION POLICY Comments 11r' JMNF Comment letters received thus far. 33 Subject areas, including those explicitly solicited. t Comment letters received from: 135 Indivicuals 21 Public Interest Groups l 18 Utilities or Representatives i 11 Industry l. 7 State and local organizations 3 Professional Societies l 2 Herbers of NCRP l-2 Members of Congress EPA i ? r I t t t
E .l r r i EXEMPTION POLICY Status Advanced Notice Published in Federal Register December 12, 1988 International Workshop - October,1988 Public Meeting - January,1989 r Yl y O I tazza tw za& sa-se 09 Achsn kra 2 tv a< 044 [m ( t en4+y ) h
4 .g. A I EXEMPTION POLICY l t Principles f 1. The application or continuation of regulatory controls on the practice does not result in any significant reduction in dose received by individuals within critical groups and by the exposed population. 2. The costs and resource implications of the regulatory controls that could be imposed for dose reduction are not balanced by the comensurate reduction in risk that could be realized. a g-Q p p g c % 6 3 f.r~ s us G <nus 4s e t cse2ub IA sen*CLl ct,/.:c9 aM i ,s l l 4K.<s7Y f'WY! k'L'M &fLA IN" " cied Ow% l -a. m m e w v.. -p-.- --r-u-
l ~ i s e l f EXEMPTION POLICY Purpose r To establish the basis upon which the Comission may initiate the development of appropriate regulations or make licensing decisions to exempt from regulatory control persons who receive, possess, use, transfer, own, or acquire l-certain radioactive raterial To e<suas a ce4aJ aJ ("" k " ' 4"" /* "O % "' O w., r a n.. nu, w l l-t l l { l I 1
= i o. a l i i T. d -t s EXEMPTION POLICY future Plans Analyze coments and prepare revised policy.for Comission consideration in late Spring,1989. Publish Proposed Policy Statement for public coment upon approval by the Comission. Consider further public coments in preparation of final policy statement. l. j'CC b m c & a.1 <Q .A s ch trrtIA ffr9 3 <<t4/40' f/td Cte' d ~ 4 770 mod & if ttu < u a c h $ xt-f.a, Du r a& t+ Tau o ty.Ted %1 wt kW k u ruaa! & X4 tuf<ahn q 254g.a.eq 1' w4 ,,w u F&l 6.wkaw c&nspA uOtt ct'A, 3 L ar ~ a,~ u & nw l
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1 ) } } PROPOSED EXEMPTION POLICY FOR A JUSTIFIED PRACTICE 10o0 3 ,,,,,,,,i i E Clearly Not Exemptable 100 s- --- - -- - -Public Dose Limit- - - ---s 2 E E au et i k 30 g-. _. _. _. _. e. 1 O o Possibly Exemptable s 1 r-4 l i Clearly j i l E Exemptable l 4 0.1 s s i E l E l ,,,,,,,1 ,,,,,1 ,,i...I ,,,, i i,1 ,,,,,I 1 10 100 1,000 10,000 100,000 Collective Dose (Person-REM) i ~ o t. i L ..}}