ML20043B908
| ML20043B908 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1989 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Carr, Roberts, Rogers NRC COMMISSION (OCM) |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006010014 | |
| Download: ML20043B908 (28) | |
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'O'A UNITED STATES E 8.
NUCLEAR REGULATORY COMMISSION 4
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lOf0 Sl f; MEM0R'ANDUM FOR: Chairman Carr l
Comissioner Roberts 4
Commissioner Rogers Comissioner Curtiss Comissioner Remick FROM:
James M. Taylor, Executive Director for Operations
SUBJECT:
COM' MISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL In SECY-89-360, the staff noted that in recent comunications with both the Commission and the ACRS the issue of coherencelin the regulatory process
.has been raised.
In light of the' increased emphasis upon a consistent regulatory approach, the staff has prepared a discussion of several perceived inconsistencies between the policy statement on Exemptions from Regulatory Control and prior actions related to the regulation of nuclear power reactors. The discussion of-these potential inconsistencies is enclosed.
c
~
L James M. Taylor Executive Director for Operations
Enclosure:
As stated-cc: SECY OGC GPA l
l 9006010014 891130 h1 FR49886 PDC
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i
..e POTENTIAL AREAS OF INCONSISTENCY During the preparation of the final policy statement on Exemptions from Regulatory Control, SECY-89-360, the staff noted that in recent communications
- with both the Commission and the ACRS the issue of coherence in the regulatory process has been raised.
In that regard, the staff has identified several areas of potential inconsistency between the final policy statement and other regulated activities, particularly with prior actions related to reactors.
These areas include: 1) the collective dose criterion; 2) the 0.1 rem cutoff
- for collective dose calculations; and 3) the potential lack of finality for decommissioning actions. Other areas of potential inconsistency, such as with national and international recommendations, have been discussed previously with the Commission.
I.
The Collective Dose Criterion The Staff Requirements Memorandum of October 13, 1989, directed the staff to include a collective dose criterion of 1,000 person-rem per year for exemptions. Under the final policy statement (SECY-89-360), this criterion would define a level of collective dose below which further efforts to reduce the collective dose would not be necessary. Thus, in the policy statement the Commission would establish in essence, a lower bound for ALARA efforts at 1,000 person-rem. This collective dose is larger than the collective dose that has resulted from other situations where.the NRC or licensees have expended resources to analyze and further reduce the dose.
For example, the collective dose from effluents from all operating nuclear power reactors in the United States in 1986 was 110 person-rem (NUREG/CR-2850, Vol. 8). The exemption policy collective dose criterion could allow these effluent releases to be increased by about a factor of 5, if no margin for variability was taken into account, and provided that the release of effluents is defined as a separate practice. However, it should be noted that if ef fluent releases were allowed at the 10 CFR Part 50 Appendix I design objective values, the collective dose for all operating nuclear l
I power reactors could increase to several thousand person-rem per year.
The use of a larger collective dose criterion in circunstances where further regulatory control will not be exercised than when continued regulation is required could appear to be inconsistent both in terms of the relative magnitudes of concern, and the philosophy of control of The use of a 1,000 person-rem value could, for example, be sources.
construed as implying that the controls of effluents for nuclear power reactors have been too stringent. Another potential dichotory becomes apparent when the number of decisions that may be made under the exemption policy is taken into account. Although most practices are expected to be broadly defined, the combined total of all consumer products, decom-missioning activities, waste disposals, etc., could result in a large
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(7 number of exemptions, each with a-collective viose of 1,000 person-rem.
In each of these decisions, the collective dose could, under the final policy statement, be considerably greater than that allowed for situations where we maintain regulatory control.
it could, therefore, be argued that the collective dose criterion for exemptions should.be less than or equal to It should the level expected when the NRC continues to exercise control.
be noted that-if the appropriate comparison of the collective dose criterion
-is with the 10 CFR Part 50 Appendix 1 design objective values, rather than the actual ALARA operating experience, the collective dose from operating nuclear power reactors would be greater than the 1,000 person-rem criterion, and there would be no inconsistency in approach.
'It should also be ncted that there-is a potential inconsistency in approach between the policy statement on exemptions from regulatory control and the safety goal policy statement. When the safety goal policy statement was prepared, the use of a collective dose criterion was debated and rejected.
In the case of the' exemption policy, the collective dose criterion was included.
- 11. The 0.1 mrem Collective Dose Cutoff-The concept:of collective dose was estab11shed a number of years ago as a nachanism for quantifying the societal impact of radiation sources or In its pure, theoretical form, the collective dose is a practices.
representation of the societal impact only when all of the contributions to the dose are included.
However, as a practical matter, the collective dose.has almost always been truncated in some manner.
In various analyses, a cutoff in time (e.g.,10,000 years), distance (e.g., 50 miles), or dose has been used.
Each of the approaches to collective dose cutoff has advantages and disadvantages. However, in'ench case the cutoff was applied so that the truncated portion was considered to be insignificant in the decision In general, the collective dose assessment has been carried out process.
in time or space to the point'necessary to distinguish among viable alternatives when applying the ALARA principle.
The distribution of doses from any practice is often characterized by a normal or log-normal distribution.
In many casec, the average dose is an order of magnitude lower than the limit. The staff believes that-for most exemption decisions this will be the case. However, because of the narrow interval between the individual dose criterion and collective dose cutoff (1 mrem and 0.1 mrem), there may be numerous circumstances where a majority of the collective dose will not be included in determining if a practice meets the collective dose criterion. Thus, there may be situations where some of the collective dose information that would be useful to distinguish between exemption alternatives will not be available.
It should be noted, in comparison with the 1,000 person-rem criteria, that a dose of up to 10,000 person-rem might not be subject to consideration, provided that each individual received less than 0.1 mrem.
In addition, the use of a cutoff, such as the 0.1 mrem value, may not be appropriate for assessments under NEPA.
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nL 11lI.-Lack of Finality in Decommissioning Actions During-the August 3,~ 1989, hearing before' Congressman Synar, Chairman Carr discussed the problems of decommissioning nuclear facilities. One of these' problems related. to the. lack of: definitive criteria upon which final
' decommissioning actions could be based..The exemption policy individual dose criterion of 10 mrem is contemplated as.the basis for waste disposal and decommissioning decisions, and.in the latter case, the staff is preparing-guidance on soils and structures to. implement the dose criterion.
However, the'10 mrom dose level is potentially inconsistent with recommen-dations.or regulations of EPA, and the NRC may'be faced with reexamination l'
and reopening of decisions at some future date. at a significant expense to both the government and licensees, unless EPA included some type of "grandf ather" clause. The problems of a lack of finality in the decom-missioning area will be discussed in greater detail in staff paper on decommissioning.
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- 3. tcp T MEMORANDUM FOR:; Chairman Carr.
Comissioner Roberts
, *~.t Comissioner Rogers-Comissioner Curtiss Commissioner Remick James M. Taylor. Executive Director for Operations
-FROM:
COMMISSION POLICY STATEMENT ON EXEMPTION
SUBJECT:
CONTROL
[
in SECY-89 360, the staff noted that' in-recent consnunications wi in the regulatory process-
.the Comission and the ACRS the. issue of coherenceIn light f several perceived
.has been rats'ed.
-regulatory approach, the staff has' prepared a _ discussion o inconsistencies between the policy statement on Exemptions from Reg Contrcl and prior actions related to the regulation of nuclear power d
reactors. - The discussion of these potential inconsistencies is enclose James M. Taylor L
Executive Director for Operations
Enclosure:
As stated-9
(
cc: SECY OGC GPA-L
' DISTRIBUTION: [ COMMISSIONERS]
RECORD NOTE: This paper was reviewed i
RWlEB R/F - DCool Circ./Chron.
by the staff of NRSS.
L JMTaylor
'E00 R/F NRR, and OGC, and reflects L
EBeckjord-Dross their input.
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i V
i POTENTIAL AREAS OF INCONSISTENCY During the preparation of the final policy statement on Exemptions from Regulatory Control, SECY-89-360, the staff noted that in recent communications with both the Comission and the ACRS the issue of coherence in the regulatory In that regard, the staff has identified several L
process has been raised. areas of potential inconsistency between the final policy s regulated activities, particularly with prior actions related to reactors.1) th These areas include:
for collective dose calculations; and 3) the potential lack of finality for
-" " : " +h decommissioning actions. O t'-- : n ' ^ ' a t a t h ' ' - - -- '- '---
l nati --? : d '-teaa-tien 1 :::-nostions, nu. L.;a die:se;;; p-" ices!y wi+h_
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The Collective Dose Criterion 13, 1989, directed the staff The Staff Rekuirements Memorandum of October to include a collective dose criterion of 1,000 person-rem per year for Und;r in.t. :1 aalkv sit +a--t (!!CMM50), this rei+= Mon ~
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exemptions.
= 1aval d ra' h eti e L a 'v. 6 a ku igrth:r ;ffert; to d d de'4a=en11ae+4ut d;;;,,;;]j ;;; L;,,,,4;;;7y, O,g;, jg ;;,, py; ; q-rednea +ha "wr stet:=.; d "--1::f:r ::ald ::t:bli:5 'n eee;;;;,. k.;;r 5::::This collective dose is large
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collective dose that has resulted from other situations where th
- fyse For example, the collective dose from effluents from all operating nuclear licensees power reactors in the United States in 1986 was 110 person-rem (NUREG/CR-2 He exemption policy collectJve dofe criterionSetrWmow4these Vol.8).t releases to be increased by 'sios,t +fector-efff, if no margin for.
4.weG effriabilitymas 4aken into. account, and provided-that-the releasedE -":r, it :5: !d bit s4W effluents *tfefined-as-a -separate practice.
, A.
- 1w.r that if effluent releases were allowed at the 10 CFR Part 50 Appendix !
.Y design objective values, the collective dose for all operating nuclear L J power reactors could increase to several thousand person-rem per year.
F The use of a larger collecti dose criterion in circumstances where further regu atory control wi 1 not be e reised than hen continued e nconsistent oth in terms of j
regulation is required could a pear to the relative gnitudes of conc rn, and the philosophycould, for example, control of sources. The e of a 1,000 pe en-rem vdlu construed as i lying that the c trols of e luents for uclear powpe>
Another oo ntial dich toiny becomes reactors have be n too stringent.
apparent when the number of decis )ns that may be made und r the exemption policy is taken i to account. Although most pr etices are :xpected to be broadly defined, t e combined tota of all cons r product, decom-d result in a large missioning betiviti s, waste dispos 1s, etc., co v*[prM 7 V)s.
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dose of 1,000 ers,on7 rem.,fn g/ gt j
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collective dose cri rion f r a empt ss 1
less than e al to the evel pected w n.the RC onti Ues to exe se c trol.
t hould be d th t if the repr te a ison o th 11e ive iterion is wi the O CFR Par 80 Ap ndi I sign ob c ive va es, at than
- the ac al AL RA operat g exp ien e colloc e dose fmm r t ng.
nuclear power eactors w uld be rea r n the 1, 0 pers n-res rite ion, and there woul be no inc nsiste
..in a roach.
It should also be noted that there is a potential inconsistency it approach between the policy statement on exemptions from regulatory control an the safety goal' policy statement.
was prepared, the use of a collective dose criterion was debated and L
In the case of the exemption policy, the collective dose i
rejected.
criterion was included, I
The 0.1 mrem Collective Dose Cutoff L
II.
The concept of. collective dose was established a number of years ago as a L
mechanism for quantifying the societal impact of radiation sources or In its pure, theoretical form, the collective dose is a representation of.the societal impact only when all of the contribu practices.
to the dose are included.
In various analyses, dose has almost always been truncated in some manner.
a cutoff in time (e.g.,10,000 years), distance (e.g., 50 miles), or dose has been used.
Each of the approaches to collective dose cutoff has advanta truncated portion was considered to be insignificant in th disadvantages.
L in time or space to the point necessary to distinguish among viable' process.
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alternatives when applying the ALARA principle.
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//-
The distribution of doses from any practice is often characterized by a normal or log-normal distribution.
The staff believes that for most order of magnitude lower than the limit.
However, because of the narrow exemption decisions this will be the case.
interval between the individual dose criterion and c of the collective dose will not be included in determining if a practic
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meets the collective dose criterion.some of the collective dose informa 6'
It should be noted, j
between exemption alternatives will not be available.
e in comparison with the 1,000 person-rem criteria, that
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In addition, the use of a cutoff, I
individual received less than 0.1 mrem.such as the 0.1 mrem value, ma W )p\\
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NEPA.
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.111. Lack of Finality in Decomissioning Actions During the August 3,1989, hearing before-Congressman Synar. Chairman Carr One of discussed the problems of decoenissioning nucosar facilities.
l
.these problems related to the lack of definitive criteria upon which fina
.eecommissioning actions could be based. The axesotion policy individual l
. dose criterion of 10 arem is contemplated as the 3 asis for weste disposal and decommissioning decisions, and. in the latter case, the staff is-preparing guidance on' soils and structures to isplement the dose criterion.
iowever. the 10 arem dose level is potentially inconsistent with recomen-o dations or regulations of EPA..and the NRC may be faced with reexamination and reopening of decisions at some future date, at a significant expense L
to both the government and licensees, unless EPA included so
- grandfather clause.
missioning area will be discussed in greater detail in staff paper on decosnissioning.
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' MEMDRANDUM FOR: Chairman Carr Connissioner Roberts Commissioner Rcgers Comissioner Curtiss Connissioner Renick
}
)
James M. Taylor, Executive Director for Operations oL
,FROM:-
COMMISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORYl
SUBJECT:
CONTROL g
i:
In. SECY-89-360, the staff. noted that' in recent communications with both
'the Comission and the ACRS the issue of coherence in the regulatory process 7
In light of the increased emphasis upon a consistent has'been raised.
regulatory approach, the staff has prepared a discussion of M perceived
- inconsistencies between the policy statement on Exemptions from Regulatory Control and prior actions related to the regulation of nuclear power y
The discussion of these potential inconsistencies is enclosed.
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Executive Director for Operations 1
Enclosure:
'As. stated cc:' SECY-OGC l
GPA DISTRIBUTION: [ COMMISSIONERS)
RPHEB R/F - DCool Circ./Chron.
RECORD NOTE: This paper was reviewed by the staff of NRSS, JMTaylor-EDO R/F NRR, and OGC, and reflects EBeckford Dross their input.
WHouston.
TSpeis 8 Morris ZRosztoczy
.0C001 F__ b:
- D G, ES :0:RES
- EDO 0FFC:
NAME:DCool:dm
- 2 toczy:BMo s
- T s
- EBeckjord :JMTaylor DATE: n/7/89
- 12/3/89
- k/ 8 /89 :
/89 :
/ /89 :
/ 89 0 F CIAL RECORD COPY
i,.
POTENTIAL AREAS OF INCONSISTENCY During the preparation of the final policy statement on Exemptions from Regulatory Control, SECY-89-360, the staff noted that in recent communications with both the Comission and the ACRS the issue of coherence in the regulatory In that regard, the staff has identified several process has been raised.
areas of potential inconsistency between the final policy statement and other regulated activities, particularly with prior actions related to reactors.1) the co These areas include:
for collective dose calculations; and 3) the potential lack of finality for c f -A M : ' " - - - - ' " -" -" " M " d + h decommissioning actions.
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I.
The Collective Dose Criterion The Staff Requirements Memorandum of October 13, 1989, directed the staff
/
to include a collective dose criterion of 1,000 person-rem per year for Und;. in.R:1-pa14cv stata---t (SECY *^ 350), this ce4+=rion d#.
re'd de'daa = laval af ce' h ;;ive & L.I
- ,h.n Tgrth;r ;ffect; to T'
exemptions.
enllaetdue d;;e sculd n;t L; e.;essary. itse, te ih ni;cy /
rednea +ha stet:nat a C -M:f er.:;;ld ::t:51M5 h e;;;n;;. e k=r b:::: Tw This collective dose is larger'than the f
AkA"A. Tim te et 1,000 ;:r;:
r;;.
collective dose that has resulted from other situations wheredhe NRC or#J,J ^M have evpended resources to analyze and further' reduce the dose, #
me icensees or example, the collective dose from effluents fron-el'1 operating nuclear 6 person-rem (NUREG/CR-2850,"
i power reactors in the United States in 1986 was iterion'Aowhnolow4these i Vol. 8). %e exemption policy collective do
- 7. if -no=margh4cr eff t releases to be increased by ht a, ctor the release of Me?
tabi44t g-tekenintracsounWnd Paudi
.j efined as a separate practice.
H~~":r, it cheeld L -noted We s,GW effluents that if effluent releases were allowed at the 10 CFR Part 50 Appendix I oby 7
design objective values, the collective dose for all operating nuclear b power reactors could increase to several thousand person-rem per year.
The use of a larger collecti dose criterion in circumstances where further regu tory control wi 1 not be e reised than hen continued regulation is equired could a pear to e nconsistent oth in terms of f
[/
the relati nitudes of conc rn, and the philosophy control o sources.j he pe of a 1,(iOO pe on-reliiya'Tu ~ coula,YoF e~x'aiip e, be trols of e luents for ucleatpow (doRstYiTed as implying that the c Another'po ntT&1 dTch toiqy becorsis s
(reactorshaye_.bekntoostringent[s ns that may be made und r the exemption sp)aTent when the' number ~of d~ec policy is taken i to account. Alt ough most pr ctices are xpected to be broadly defined, t e combined tota of all cons r product, decom-missioning activiti s, waste dispos 1s, etc., co ld result in a large h)
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nunt>er of exemp ions, each with a collecti dose of 1,000 rson-rem. in ese ;f p..;; dyk;:.
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It could, t refore, ea e that the collective dose cri rion f r e empt ss 1
e less than e al to the evel pected w n the RC onti ues to exe s.e c trol.
- t. hould be d th t if the a repr te pa ison o th 11e ive iterion-is wi the O CFR Par 30 Ap ndi I sign ob c ive va es,_ at than
'the ac al AL RA operat g exp ien e collac e dose from r t ng
- nuclear power eactors w uld be twa r n the 1, 0 pers n-rom rite ion, H
'and there woul be no inc nsiste y in a roach.
It should also be noted that there is a potential inconsistency in approach between the policy statement on exemptionJ from regulatory control andWhenT L
r was prepared, es4se4f 44o14ective dose =ortterionaves4ebated-and VM *g,
the safety goal policy statement.
~ redected.b 'he case of the exemption policy, the collective dose
^M gg I t criterion ncluded.
i,JM M A'4A
- 11. The 0.1 mrem Collective Dose Cutoff
%W
"'"4 The concept of collective dose was established a number of years ago as a mechanism for quantifying the societal impact of radiation sources or In its pure, theoretical form, the collective dose is a practices.
representation of the societal impact only when all-of the contributions L
to the dose are included. However, as a practical matter, the collective l
In various analyses, dose has almost always been truncated in some manner.
L l
a-cutoff in time (e.g.,10,000 years), distance (e.g., 50 miles), or dose has been used.
Each of the approaches to collective dose cutoff has advantages and However, in each case the cutoff was applied so that the disadvantages.
truncated portion was considered to be insignificant in-the decision In general. the collective dose assessment has been carried out process.
in time or space to the point necessary to distinguish among viable j
. alternatives when applying the ALARA principle.
)i The distribution of doses from any practice is often characterized by a normal or log-normal distribution. In many cases, the average dose is an order of magnitude lower than the limit. The staff believes that for most However, because of the narrow exemption decisions this will be the case. interval between the individual dos (1 mrem and 0.1 mram), there may be numerous circumstances where a majority
~
of the collective dose will not be included in determining if a practice Thus, there may be situations where
/
some of the collective dose information that would be useful to distinguish
/ j, ;
meets the collective dose criterion.
between exemption alternatives will not be'available.
It should be noted, i
e in comparison with the 1,000 person-rem criteria, that a dose of up to 10,000 person-rem might not be subject to consideration, provided that each
/
In addition, the use of a cutoff, k
individual received less than 0.1 mrem.
such as the 0.1 mrem value, may not be appropriate for assessments under
[yfh NEPA.
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III. Lack of Finality in Decommissioning Actions f
During' the August 3,1989, hearing before Congressman Synar. Chairman Carr.
One of discussed the problems of decommissioning nuclear facilities.
'these problems related to the lack of definitive criteria upon which final decommissioning actions could be based. The exemption poli g individual dose criterion of 10 mrom is contemplated as the basis for waste disposal and decommissioning decisions, and, in the latter case, the staff is
- preparing guidance on soils and structures to implement the dose criterion.
i However, the 10 arem dose 1cvel is potentially inconsistent with recossnen-dations or regulations of EPA, and the NRC may be faced with reexamination
.and reopening of decisions at some future date, at a significant expense to both the government and licensees, unless EPA included some type of "grandf ather" clause. The problems of a lack of finality in the decom-missioning area will be discussed in greater detail in staff paper on L
decommissioning.
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s MEMORANDUM FOR: Chairman Carr Comissioner Roberts Comissioner Rogers Comissioner Curtiss Commissioner Remick
'FROM:
James M. Taylor, Executive Director for Operations
SUBJECT:
COMMISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL In SECY-89-360, the staff noted that in recent communications with both the Comission and the ACRS the issue of coherence in the regulatory process has been raised.
In light of the increased emphasis upon a consistent
. regulatory: approach, the staff _has prepared a discussion of several perceived h
inconsistencies _ between the policy statement on Exemptions from Regulatory t-Control and prior actions related to the regulation of nuclear power reactors.' The discussion of these potential inconsistencies is enclosed.
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- James M. Taylor Executive Director l
for Operations l
l
Enclosure:
.As stated cc: SECY l
OGC GPA DISTRIBUTION:
[ COMMISSIONERS]
RPHEB R/F - DCool Circ./Chron.
RECORD NOTE: This paper was reviewed JMTaylor EDO R/F by the staff of NRSS, EBeckjord Dross NRR, and OGC, and reflects
'WHouston-TSpeis their input.
.BMorris-ZRosztoczy DCool' 0FFC:RI R._ b;
- EDO l
NAME:DCool:dm
- Z toczy:BMo s
- TS s
- EBeckjord :JMTaylor DATE: /?/7/89
- rs/J/89
- k:/ 8 /89
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/89 :
/ /89
/ 89 0 F CIAL RECORD COPY
6 POTENTIAL AREAS OF INCONSISTENCY During-the preparation of the final policy statement on Exemptions from j
Regulatory Control, SECY-89-360, the staff noted that,in recent communications with both the Comission and the ACRS the issue of coherence in the regulatory In that regard, the staff has identified several process has been raised.
areas of potential inconsistency between the final policy statement and other regulated activities, particularly with prior actions related to reactors.
These areas include:
- 1) the collective dose criterion; 2) the 0.1 rem cutoff for collective dose calculations; and 3) the potential lack of finality for decommissioning actions. -Oth:r cre:: cf p; tent 4e-1 in;;n;4 sten;y, :::5 :: e4th, national-and-4nternational-recommendationsrtnive-b
"--"--" pmieteely wi+h
- h* C: =ission.
I.
The Collective Dose Criterion l
The Staff Requirements Memorandum of October 13, 1989, directed the staff exemptions. Urder ihdina1-policy-stetement-fGEGV-89 360-)per y to include a collective dose criterion of 1,000 person-rem l
r-4his-cr4terf on l
':::1 of ;;11ecth; de;; bele..hid Nrther effort: to j
eeeld &#%: :
-e & er th: 0011:0tiv; dese seuld net be n;;c;;;ry. Thus, ir the policy 1
et t: at the Cc-bs4en-wow 14 ::t:51fsh-4e-essence, e le.er b;;nd for-
"L*"" effort; :t 1,000 per;;n r;. This collective dose is larger than the collective dose that has resulted from other situa'tions where the NRC or have expended resources to analyze and further reduce the dose da **
s For example, the collective dose from effluents from all operating nuclea,r #'
licensees
?.
power reactors in the United States in 1986 was 110 person-rem (NUREG/CR-2850, Vol. Bh> lem. exemption policy collective dose criterion ei4&d alloOthese
', "5 y effluent releases to be increased by about a fni :'Df no margin for
.]p variability was taken into account, and pre ided thet the rele;;; cf is def%ed-:: : ::perete practice. However, it :hr'd 5: eo6ed (J d%p
-e## ? rem ?
that if effluent releases were allowed at the 10 CFR Part 50 Appendix I design objective values, the collective dose for all operating nuclear e
l power reactors could increase to several thousand person-rem per year.
Th u of/a 1 'ger ollettiv dos crit rio in rcumsta ces ere rt er gul ory onty61 w 1n be xer sed ha 'whe co inued re la on i re ired cou app ar t be co is nt th ~
terms /of
/
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e ph lo p
a 1/ 00, rsor) rem 'alue'co d,
or, ample,A e N D
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. ou he se N'/c struf8 as mpi ng that tt e control of eff1 ent foty' nuclear / power,d' 3
eactpf' h e been too'strinsent
'n' he'r" pot nti d)thotonty,,4ecomes' -
s on tha be mad ('under he ex ption "Mf dec ppe.ent u
accp Alth gh..os /pr ti are pect to
'e e coc,6nt.
po 'cy take/ int
/
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ning, tiv) ies, Maste'dispdsals, e,., coul, iss
w
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,=
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' exemptions, chwitpacollectivedos of 1,00.0/ person-rem.
In h
the g decis ns,thefco11ectJvedosec d, unddr the final policy t
nt A e co derablyAireaterAhan that lowedforsituationswhere "y
u main atory gAtrol. Mit could therefore, be argued that the olle,t41n r e criter# n for ekemptions hould be'1ess than or equal'to j
ive d the eyel <
pected n-the WRC continyes to exercise control. At should '.
b noted sat if appropriate com rison of the collective 4ose criterion j
4's wit the 10 C Part 50 Appendi I design objective'value),, rather than the ual ALA operat)tig experi nee, ths/collectiyf dosefrom o rating' i
nu ar power eactors Nould be rester than the It000 ptrson-critprion, j
an there m Id be no'inconsi ency in a'proach.
p f
-It should also be noted that there is a potential inconsistency in approach p
between the policy statement on exemptions from regulatory control and the safety goal policy statement. When the safety goal policy statement c
was prepared, the use of a collective dose criterion was debated and rejected.
In the case of the exemption policy, the collective dose i
i l
criterion was included.
II. The 0.1 mrem Collective Dose Cutoff The concept of collective dose was established a number of years ago as a mechanism for-quantifying the societal impact of radiation sources or In its pure, theoretical form, the collective dose is a practices.
representation'of the societal impact only when all of the contributions.
to the dose are included. However, as a practical matter, the collective dose has almost always been truncated in some manner. -In various analyses, a cutoff in time'(e.g.,10,000 years), distance (e'.g., 50 miles), or dose 3
has been used.
Each of the approaches to collective dose cutoff has advantages and disadvantages.
However, in each case the cutoff was applied so that the truncated portion was considered to be insignificant in the decision In general, the collective. dose assessment has been carried out process.
in time or space to the point necessary to distinguish among. viable alternatives when applying the ALARA principle.
- hr;;trird i; -
Jh: di: trit:t',. ;' d;;;: 'r: 2ny prz tin i:7:...
^
n z, th:..........;...
.In =n;M :. a g y;,;; n;, 3, ;,;;;
- r ;? ;r b;
- :3 M :' 'h tir,
- m. es -.;- u,: 7 y-- y u-;;,
r_;.4t'r d:: h h:: thi: ;;f' h th se. (However, because of the narrow interval between the individual dose criterion and collective dose cutoff cr-o circumsten;;;.;hr: ; =dee,+y
'(1 mrem and 0.1 mrem)/ thre =y ::
- ' *edncik=there may be situations where
'- d:ter.r. int; "f ae pr;;the os m y,u,.o..
Muer th ;;";;th: d;n ritrf r.
n: :
some of the collective dose information that would be useful to distinguish between exemption alternatives will not be available.
't dr?d h n:::f,
'r r 7ere r.;ith th: 1,000 pr:en e c-4t M, tMt M e:. ;'.; te 5
10,000 pren rr ';ht_= tie -;4j::t to enf dr: tier, ;rnf f:f th;t x:
"'b' t:'
- = S:t i n:-then 0.1 n
dditka, 'M.x :f : =t:f',
-"ch ?: th0,1== n1=,-?; ret +e-e;;r ;r hte fr n = n a nts.nd r MGW 2
~..
III. Lack'of Fina'11ty in Decommissioning Actions During the August 3,1989, hearing before Congressman Synar, Chairman Carr
+
discussed the problems of decommissioning nuclear facilities. One of these problems related to the lack of definitive criteria upon which final decommissioning actions could be based. The exemption policy individual dose criterion of 10 mrem is contemplated as the basis for waste disposal and decommissioning decisions, and, in the.latter case, the staff is preparing guidance on soils and structures to implement the dose criterion.
However, the.10 mrem dose level is potentially inconsistent with recommen-dations or regulations of EPA, and the NRC rey be faced with reexamination 4
and reopening of decisions at some future date, at a significant expense to both the government and licensees, unless EPA included some type of
" grandfather" clause. The problems of a lack of finality in the decom-missioning area will be discussed in greater detail in staff paper on decommissioning.
3 I
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. i Document Name:
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. COMMISSIONERS--
,:.c Reques tor's-ID:;
MENDIOLA-
' Author's.Name:
dcool-Document Comments:
COMMIS$10N POLICY STATEMENT ON EXEMPTION FROM REG. r0NTROL
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\\j UNITED STATES '
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8 NUCLEAR REGULATORY COMMISSION
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- 3 W ASHINGTON, D. C,20666 l
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-t MEMORANDUM FOR:- Chairman Carr Comissioner' Roberts Comissioner Rogers e
Comissioner Curtiss
(
Comissioner. Remick FROM:
James M. Taylor, Executive Director for Operations -
SUBJECT:
COMMISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL 1
In SECY-89-360,.the staff noted that in recent comunications with both the Comission and the ACRS the issue of coherence in the regulatory process L
has been raised.
In light of'the-increased emphasis upon a consistent regulatory approach, the staff has prepared a discussion of several perceived inconsistencies between the policy statement on Exemptions from Regulatory
' Control and prior actions related to the regulation of nuclear power reactors. The discussion of these potential inconsistencies is enclosed.
The. staff is prepared to work with the Comission to make changes or additions
[
to'the policy statement as may be' appropriate.
L I
James M. Taylor
?
Executive Director for Operations
Enclosure:
[
As stated cc: -SECY OGC l-GPA y
i y
+
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I
- MEMORANDUM FOR: Chairmen Carr Commissioner Roberts Commissioner Rogers Commissioner Curtiss Commissioner Remick FROM:
James M. Taylor, Executive Director for Operations
SUBJECT:
COMMISSION' POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL k.'
_In SECY-89-360, the staff noted that in recent communications with both y:-
the Commission and the ACRS-the issue of coherence in the regulatory process has been raised.
In light of the increased _ emphasis upon a consistent
. regulatory approach, the staff has prepared a discussion of several perceived inconsistencies between the. policy statement on Exemptions from Regulatory Control and prior actions related to'the regulation of nuclear power
' reactors. The discussion of these potential inconsistencies'is enclosed.-
'The staff is prepared to work with the Commission to make changes or additions to the policy statement as may-be appropriatej aps u! y n t 4n d g 4 James M. Taylor Executive Director for Operations t
Enclosure:
As stated cc: SECY
'0GC GPA DISTRIBUTION:
[ COMMISSIONERS]
>RPHEB R/F - DCool Circ./Chron.
RECORD NOTE: This paper was reviewed
'JMTaylor E00 R/F by the staff of NRSS, EBeckjord Dross NRR, and OGC, and reflects WHouston~
'TSpeis their input.
BMorris 2Rosztoczy DCool.
- See previous concurrences 0FFC:RPHEB:DRA* :DD:DRA*
- D:DRA*
- DD/Gl:RES*:D:RES*
- EDO cNAME:DCool:dm
- ZRosztoczy:BMorris
- TSpeis
- EBeckjord :JMTaylor DATE:12/07/89
- 12/08/89 :12/08/89
- 12/08/89 :12/08/89
/ 89 0FFICIAL RECORD COPY
4: -
4
- i
. [.
Document Name:
POTENTIAL AREAS Requestor's;ID:
MENDIOLA j
Author's-Name:
- dcool 3
Document' Comments:.
, Potential areas of inconsistency
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f POTENTIAL AREAS OF INCONSISTENCY During the preparation of the final policy statement on Exemptions from Regulatory Control, SECY-89-360, the staff noted that in recent communications with both the Commission and the ACRS the issue of coherence in the regulatory In that regard, the staff has identified several process has been raised.
areas of potential inconsistency between the final policy statement and other i
regulated activities, particularly with prior actions related to reactors,
- 1) the collective dose criterion; 2) the 0.1 rem cutoff These areas include:
for collective dose calculations;.and 3) the potential lack of finality for decommissioning actions.
- 4. ' #
I.
The Collective Dose Criterion yd The Staff Requirements Memorandum of October 13, 1989, directed t sta r for to include a collective dose criterion of 1,000 person-rem per y This collective dose is larger than the collectiv9 dose that exemptions.
has resulted from other situations where the NRC or licensees,'have expended The resources to analyze and further reduce the dose #such as at reactors.
use of a 1,000 person-rem value could, for examp1e, be construed as implying Ecr d ::p', g nts for nuclear power reactors have been tooche effl that the contro1s o#
,b.g / W ringent.
- r the United States in 1986 was 110 person-rem nuclear power reactors i l
(NUREG/CR-2850, Vol. 8). gome could read the exemption policy collective el, cr,egepQ,,,,,
w g these g lje gnif -
..~,v.,,v.pasgoge _ _ _.......
4
_N ' M N Y A a
mm,
m.
.s However, the staff notes that if effluent releases were 4Mesed ecceunt.
at the 10 CFR part 50 Appendix I design objective values, the collective dose for all operating nuclear power reactors could increase to several l
thousand person-rem per year.
It should also be noted that there is a potential inconsistency in approach l
between the policy statement on exemptions from regulatory control and Thesafetygoalpg.lfcystatementincludes the safety goal policy stateynt.
the risks of normal operatiEs as well as accidents,, Mat does not include a collective dose objective.
In the case of the exemption policy, the collective dose criterion has been included. /. MrA.x c,., rA a cdyMJ s
J' - ' p n Y M s, @,s & ? L L.no*M.2 4 4'nm&>*
II. The 0.1 mrem Collective Dose Cutoff "4A.a*Med "WM-A -AJ
- m. Ena m... J p i r. 4 ~,
a number nf year! e;0 ;; ;
Th; reacapt Of 00ll;;tiv; dc;c w;; ::teb11shed
= ache-is= far nuan+4f;4ng the :::ietal i,T.pect cf radiction : ere:: er l'
practices.
!a its pure, th;s.ei koi fum, i.hc uvlied. h c dese i; ;
epre:ertatica ef the societ=1 4 p::t en1;- when all of th: ;;ntrihtfon:
l
.tcthejeteer
'n 1uded. ";w:ver, :: :-practi:4 -etter,The collective dose hoe almost always been truncated in some manner.
In various analyses, a cutoff in time (e.g.,10,000 years), distance (e.g., 50 miles), or dose has been used.-
i i
O e
p Each of t e approaches to collective dose cutoff has advanta s and disadvant ges. However, M n ' nt: the cutoff was appli so that the
~
a e decision truncated(portion was considered to be insignificant in Ir ;;n.;',, the collective dose assessment has been carried out d
process.
g in time or space to the point necessary to distinguish among viableaM <b A 4
alternatives when applying &M esA orn Wthe ALARA principle.
TG m a L
.itu.c4 utu % n a y e.
t M,7 C
- r:r :ny pr;; tic; h eft:r :hcr;;d:i d by :
The di trit;ti:n Of d::::
Ir = ry c ses, the g :
d::: h er 4
.^rn!-cr le; er=1 dhtributi;n.
erder Of = ;rit;d; hu;r th;n th; it;ii. The ;t:ff "M v:: that f - ett e m t tr d:: h hn; this wi b; th: ;;n.
because of the narrow interval between the individual dose criterion [r:d cf liective dose cutoff (1 mrem and 0.1 mrem), there ny t; n;;;res; A,
- r :: ch:re ; ;;j;rity
- f the ;1k;tivs d;;; hill n
- t 50 intbd:d dr 4 t:r pr;;ti;;
- t th: ;1kethe de e criterier.
'ht;, there may e situations where some of the collective dose information that would be u eful to distinguish between exemption alternatives will not be available M theeld be reted, 4 ;;;p;ri;;n with th; 1,000 p;;;;n-re; criterie, t mt e d;;e of up t:
}
s 10,000 p:r;;n r;; might not b; esbject te censiderstien, pr vided thet e=ch 4ndi" k;;l re;eived i m ih6n C.1 ; rem.
In ;ddition, the 0;; cf : tute %
the 0.1 r;r ;;lue, r.;y net be epp, vpi iete f;r O';;;;;:nt; ender auch et I i AA M
p,i, & it % wr 4% J fe m=-
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6 4
Ill. Lack of Finality in Decommissionino Actions During the August 3,1989, hearing before Congressman Synar, Chairman Carr discussed the problems of decommissioning nuclear facilities.
One of y
these problems related to the lack of definitive criteria upon which final decommissioning actions could be based. The exem'ption policy individual dose criterion of 10 mrem is contemplated as the basis for waste disposal and decommissioning decisions, and, in the latter case, the staff is preparing guidance on soils and structures to implement the dose criterion.
However, the 10 mrem dose level is potentially inconsistent with recommen-dations or regulations of EPA, and the NRC may be faced with reexamination and reopening of decisions at some future date, at a significant expense to both the government and licensees, unless EPA included some type of "grandf ather" clause. The problems of a lack of finality in the decom-missioning area will be discussed in greater detail in a staff paper on decommissioning.
2
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POTENTIAL AREAS OF INCONSISTENCY During the preparation of the final policy statement on Exemptions from Regulatory Control, SECY-89-360, the staff noted that in recent communications with both the Comission and the ACRS the issue of coherence in the regulatory process has been raised, in that regard, the staff has identified several areas of potential inconsistency between the final policy statement and other regulated activities, particularly with prior actions related to reactors.
These areas include: 1) the collective dose criterion; 2) the 0.1 rem cutoff forcollectivedosecalculations;and3)thepotentiallackoffinalityfor decomissioning actions.
I.
The Collective Dose Criterion
.M The Staff Requirements Memorandum of October 13, 1989, directed the staff to include a collecti.ve dose criterion of 1,000 person-rem per year for exemptions.
This Sc11ective dose is larger than the collective dose that has resulted from/other situations where the NRC or licensees have expended resources to analyze and further reduce the dose, such as at reactors.
The use of a 1,000 person rem value could, for example, be construed as i
implying that the controls of effluents for nuclear power reactors have been too stringent. The collective dose from effluents from all operating nuclear power reactors in the United States in 1986 was 110 person-rem i
(NUREG/CR-2850, Vol. 8). Thus, some could read the exemption policy collective dose criterion as allowing these effluent releases to be l
l increased by a significant factor, if the release of effluents were to be i
defined as a separate practice.
However, the staff notes that if effluent releases were at the 10 CFR Part 50 Appendix 1 design objective values, I
i the collective dose for all operating nuclear power reactors could increase to several thousand person-rem per year, it should also be noted that there is a potential inconsistency in approach between the policy statement on exemptions from regulatory control and 2
the safety 9061 policy statement. The safety goal policy statement des the risks of normal operations as well as accidents, but does not A clude a I
collective dose objective.
In the case of the exemption policy,j llective co dose criterion has been included.
In addition, the exemption policy cr (e eria The potential risksedu a/
de N,,,/j,// re -et %t=d:dee apply to accident situations.
7 4
te accidentt, 7: t: 5: -edd-***d :== ^ 2,, in the information supporting
<-ret C.
o dt..
a request fo exempt i on,.,/ 4,.m A. 7/
m e,,, /p, f, /.,, y
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- 11. The 0.1 mrom Collective Dose Cutoff j
The collective dose is almost always been truncated in some manner.
In various analyses, a cutoff in time (e.g.,10,000 years), distance (e.g.,
50 miles), or dose has been used. D eh of the approaches to collective cose cutoff has advantages and disadvantages.
However, the cutoff was j
usually applied so that the truncated portion was considered to be insignificant in the decision process. Thus, the collective dose assessment has generally been carried out in time or space to the point necessary to l
distinguish among viable alternatives when apply ng the ALARA principle.
I This poses a potential inconsistency with the se ection of a generic cutoff l
based upon dose.
In particular, there may be situations where some of the collective dose information that would be useful to distinguish between exemption alternatives will not be available, because of the narrow interval J
between the individual dose criterion and collective dose cutoff (1 mrom i
and 0.1 mrem). This inconsistency would exist for any values of limit and.
1 cutoff, so long as the narrow interval was maintained.
i 111. Lack of Finality in Deco missionino Actions l
l l
During the August 3, 1989, hearing before Congressman Synar, Chairman Carr discussed the problems of decomissioning nuclear facilities. One of these problems related to the lack of definitive criteria upon which final decomissioning actions could be based. The exemption policy individual i
l dose criterion of 10 mrem is contemplated as the basis for waste disposal j
and decomissioning decisions, and, in the latter case, the staff is preparing guidance on soils and structures to imp.lement the dose criterion, j
I i
However, the 10 mrem dose level is potentially inconsistent with recomen-dations or regulations of EPA, and the NRC may be faced with reexamination
)
and reopening of decisions at some future date, at a significant expense to both the p'overnment and licensees, unless EPA includec some type of
' grandfather clause.
The problems of a lack of finality in the decom-missiening area will be discussed in greater detail in a staff paper on
]
decomissioning.
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MEMORANDUH FOR: Chainnan Carr Comissioner Roberts Comissioner Rogers Comissioner Curtiss Comissioner Remick FROM:
James M. Taylor, Executive Director for Operations
SUBJECT:
COMMIS$10N p0LICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL In SECY-89-360, the staff noted that in recent comunications with both the Comission and the ACRS the issue of coherence in the regulatory process has been raised.
In light of the increased emphasis upon a consistent regulatory approach, the staff has prepared a discussion of several perceived inconsistencies between the policy statement on Exemptions from Regulatory Control and prior actions related to the regulation of nuclear power reactors. The discussion of these potential inconsistencies is enclosed.
The staff is prepared to work with the Comission to make changes or additions to the policy statement as may be appropriate after reviewing the enclosed information.
James M. Taylor Executive Director for Operations j
)
j
Enclosure:
As stated cc: SECY OGC GPA DISTRIBUTION:
[ COMMISSIONERS)
RPHEB R/F - 0C001 Circ./Chron.
RECORD NOTE: This paper was reviewed JMTaylor EDO R/F by the staff of NMSS, EBeckjord Dross NRR, and OGC, and reflects WHouston TSpeis their input.
un r :
f #* M BMorris 2Ros2tocry Red d W
- E" DCool y,p p p m,
- See previous concurrences No A*M**
f y
0FFC:RPHEB:DRA* :DD:DRA*
- D:DRA*
- DD/Gl:RES*:D:RES*
- EDO NAME:DCool:dm ' :ZRosztocry:BMorris
- TSpeis
- EBeckjord :JMTaylor DATE:12/07/89
- 12/08/89
- 12/08/89
- 12/08/89
- 12/08/89 :
/ 89 0FFICIAL RECORD COPY
)
,r
- a w.
's POTENTIAL APEAS OF INCONSISTENCY i
During the preparation of the final policy statement on Exemptions from Regulatory Control SECY-89-360, the staff noted that in recent communications I
l
-cith both the Com ssion and the ACRS the issue of coherence in the regu atory i
process has been raised.
In that regard, the staff has identified several
)
areas of potential inconsistency between the final policy statement and other regulated activities, particularly with prior actions related to reactors.
These areas include:
- 1) the collective dose criterion; 2) the 0.1 rem cutoff for collective dose calculations; and 3) the potential lack of finality for deconsnissioning actions.
I.
The Collective Dose Criterion The Staff Requirements Memorandum of October 13, 1989, directed the staff to include a collective dose criterion of 1,000 person-rem per year for l
exemptions. This criterion defines a level of collective dose below which further efforts to reduce the collective dose would not be necessary and, t
in essence, establishes a lower bound for ALARA efforts. This level of collective dose is larger than the collective dor,e that has resulted from L
some other situations where the NRC or licensees have expended resources to analyze and further reduce the dose, such as at reactors. The use of a 1,000 person-rem value could, for example, be construed as implying that the controls of effluents-for nuclear power reactors have been too stringent.
The collective dose from effluents from all operating nuclear power reactors in the L'nited States in 1986 was 110 person rem (NilREG/CR-2850, Vol. 8).
It may be reasonable to conclude that the exemption policy collective dose criterion could influence the control of effluent releases below the
{
limits established in 10 CFR Part 20.
In the case of operating power reactors, this could lead to an increase in effluents by a significant factor.-if the release of effluents were to be defined as a practice j
separate from other activities causing public exposure (e.g., waste disposal).
j I
The staff notes that if the effluent releases were at the 10 CfR Part 50, Appendix 1, design objective values, the collective dose from all operating nuclear power reactors would be on the order of several thousand person-rem
)
per year. Thus, if the appropriate comparison of the exemption policy collective dose criterion is with the design objective values, rather than the actual ALARA operation experience, there would be no inconsistency in approach.
It should also be noted that there is a potential inconsistency in approach i
between the policy statement on exemptions from regulatory control and the safety goal policy statement. The safety goal policy statement includes l
the risks of normal operations as well as accidents, but does not include a collective dose objective.
In the case of the exemption policy, a collective dose criterion has been included, In addition, the exemption policy criteria do not specifically apply to accident situations. The potential risks and impacts resulting from potential misuse or accident scenarios must also be evaluated in the information supporting a request for exemption, and demonstrated not be be significant.
t
- 11. The 0.1 mrem Collective Dose Cutoff The collective dose is almost always been truncated in some manner.
In various analyses, a cutoff in time (e.g.,10,000 years), distance (e.g.,
or dose has been used. Each of the approaches to collective 50 miles)ff has advantages and disadvantages. However, the cutoff has dose cuto usually applied such that the truncated portion was considered to be insignificant in the decision process. Thus, the collective dose assessment has generally been carried out in time or space to the point necessary to distinguish among viable alternatives when applying the ALARA principle.
I This poses a potential inconsistency with the selection of a generic cutoff based upon dose.
In particular, there may be situations where some or all of the collective dose information that would be useful to distinguish between exemption alternatives will not be available, because of the narrow interval between the individual dose criterion and collective dose cutoff (1 mrem and 0.1 mrem). This inconsistency would exist for any values of limit and cutoff, so long as the narrow interval was maintained.
III. Lack of Finality in Decommissioning Actions During the August 3,1989, hearing before Congressman Synar, Chairman Carr discussed the problems of decommissioning nuclear facilities. One of these problems related to the lack of d2finitive criteria upon which final decommissioning ictions could be based. The exemption policy individual dose criterion of 10 mrem is contemplated as the basis for waste disposal and decommissioning decisions, and, in the latter case, the staff is preparing guidance on soils and structures to implement the dose criterion.
However, the 10 mrem dose level is potentially inconsistent with recompen-dations or regulations of EPA, and the NRC may be faced with reexamination t
and reopening of decisions at some future date, at a significant expense r
to both the government and licensees, unless EPA included some type of
" grandfather" clause. The problems of a lack of finality in the decom-missioning area will be discussed in, greater detail in a staff paper on decommissioning.
t L
1 i
2
.