ML20042F717
| ML20042F717 | |
| Person / Time | |
|---|---|
| Issue date: | 02/07/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Geoffrey Miller HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20042F715 | List: |
| References | |
| CCS, MILLER-900207, NUDOCS 9005090300 | |
| Download: ML20042F717 (5) | |
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i QUESTION 2.
What are the BRC standards and policies adopted or recomended by the U.S. Environmental Protection Agency,' International Atomic Energy Agency, the National Council on Radiation Protection, Canada, the United Kingdom, V.;;
Gemany, France and other nations or organizations that have considered this issue?. Please explain any differences between these BRC policies-and the one currently under consideration by the NRC, h
ANSWER.
The U.S. Environmental Protection Agency (EPA) has incorporated below regulatory
-concern (BRC) criteria in its draft proposed Environmental Standards for the Management. Storage and Land Disposal of low-Level Radioactive Waste and 1
Naturally Occurring and Accelerator-Produced Radioactive Waste, 40 CFR Part'193 and 40 CFR Part 764. The EPA's criteria are focused only on waste disposal and do'not address other exemption decisions in which radioactive material can 1
^ -be released to the environment or to unlicensed members of the public. With i
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~ regard to s61Ect' ion ~of ~a' TridiVidual ~ dose Value, EPA considerelieveral ophons~
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- one which would require regulated disposal of all' waste from regulated radioactive material, and others which would allow BRC disposals as limited by individual dose values of 0.1, 1, 4, and 15 millirem per year.
After considering the results from cost-effectiveness analyses, risk levels used by other government programs, as well as other factors, EPA has tentatively
-chosen a maximum individual dose criterion of 4 millirem per year for potential 9005090300 900 30
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i Question 2(Continued)'
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. exposures to all-BRC waste streams combined, calculated for all future time, i
EPA would also require record-keeping and tracking of waste shipments. EPA has not developed any numerical collective-dose criterion, but EPA would require '
that collective dose'be considered'in the BRC' decision and would expect the collective dose to be small.
In addition,'the criterion is included only in draft waste disposal standards which EPA:has not yet proposed for conenent.
The International' Atomic Energy Agency (IAEA) has recently issued Safety.
Series No. 89, which addresses the subject of exemptions from regulatory control. The principles and criteria contained in this document:were the subject of extensive discussions at the NRC-sponsored International Workshop on Rules for Exemption from Regulatory Control. From this document, it would appear that the.IAEA considers the level of " trivial" individual! effective ' dose i
-l equivalent to be in the range of I to 10 millirem per year.(i.e. 100 micro--
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sievertsperyear). To ensure that individual exposures do not rise above this
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' level'(i.e., from' exposure ~to inultiple" exempt practices), tihe IAEA Lrecommend
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I that individual exposures from any single exempt practice not exceed:a few millirem per year. The exemption policy now being considered by the Consnission -
q reflects many-of the principles and concepts expressed in the IAEA document.
l However, the NRC's BRC policy does not. include the somewhat arbitrary reduction r
factor adopted by IAEA to account for exposures to multiple exempt practices.
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.1 Question 2(Continued)
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.t Instead, the Comission policy proposes a series of measures to provide assurance' that individuals are not likely to exceed 'the -100 m1111 rem.
individual dose limit from exposures to all exempt an'd licensed practices involving the use of radioactive materials.
y In its Report No. 91, the National Council on Radiation Protection.and Measurements (NCRP) has recomended a value of 1 millirem per year as a
" negligible" individual risk level.. The NCRP has proposed the value in response to "... the_need for a reasonable negligible risk level to avoid excessive control actions and expenditures to reduce individual risks.,..."
In their view, it is not-justified to: attempt "... to reduce detriment 'to levels so low or trivial as to be inappropriate in relation to reasonable-
. priorities for expenditure of health protection _ resources." Thus, the NCRP has used a negligible risk argument to achieve an objective similar. to'the
' Commission's; that is, to avoid inappropriate expenditures-of health protection resources. TCRP'also ~ recommends'that indiv'id0al ' dose's less thiri ~ f equal to l'
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millirem per year be disregarded in assessing collective doses.
l The documented positions of other nations and organizations on this issue:are t
included in the proceedings of an international workshop (Record No.151). The-
- differences between these positions.and the-provisions of the Comission's exemption policy principally involve the-issues previously referred to; that I
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't Question 2(Continued) is. (1) the bases for risk aversion underlying the dose criteria- (e.g.,
De minimis); (2) the scope of: applicability of the positions; and (3) the
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- approach taken to address the potential ~for multiple exposures from exempt
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practices. The table below provides a concise comparison of our understanding I
1 of the various approaches either under. consideration or in place for. exempting-radioactive materials from comprehensive regulations.
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- Country,or IndividualL Collective 1 Scope' Basis 2
Orcanization Dose (mr/vr)
Dose (D-R/vr)3 LNRC 1 to 10/ practice-1000
. General BRC 1
EPA' 4 (all waste) small Waste BRC.
NCRP 1/ practice General De minimis--
10 (all sources)
CRCPD 4 to 5/ practice
-General De minimis-HPS.
10 to 20/ practice --
-General BRC IAEA 1 to.10/ practice 100' General De minimis ICRP 1/ practice-100 General BRC.
U.K.
0.5/ practice 100 General De,minimis.
5 (all sources)
. Canada 5 (2 wastes) small Waste.
De minimis Japan' 1/ waste type Waste
-De minimis West Germany' 1 to 10/ practice Waste'and
-De minimis Recycling.
J Sweden
< 1/ practice small General-(De minimis)1 Finland
< 1/ waste Waste
.De minimis i
Italy 1/ practice 100.
General De minimis 1 to 10/ waste Waste' 1
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' Basis'for selecting and implementing' numerical criteria.for exemptions; BRC = risk threshold below which societal resources i
are better spent on reducing more significant risks; De:minimis.='
risk to any. individual at such low doses is trivial-or' negligible.
2NCRP = National Council on Radiation Protection and Measurements, CRCPD = Conference of Radiation. Control Program Directors, HPS = Health Physics Society, ICRP = International j
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Commission on Radiological. Protection, IAEA = International ~
Atomic Energy Agency.
3Units in Person-Rem / Year
'Also uses variable activity levels for consumer: products L
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