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/"'%g UNITED STATES 3
NUCLEAR REGULATORY COMMISSION i
Offloe of Govemmental and Public Affairs
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Washington, D.C. 20505 No.88-174 FOR IlmEDIATE RELEASE Tel. 301/492-0240 (Monday, December 12,1988)
NRC TO HOLD PUBLIC MEETING ON EXEMPTING CERTAIN PRACTICES FROM REGULATORY CONTROL The Nuclear Regulatory Commission's Office of Nuclear Regulatory Research will hold a public meeting on January 12, 1989, to discuss and receive public comments on the development of a policy statement for exempting certain practices involving the potential for low-level radiation exposures from regu-latory control because of their low public health and safety significance.
The meeting will be held at the Holiday Inn, 8120 Wisconsin Avenue, Bethesda, MD 20814 (four blocks north of the Bethesda Metro Station) from 9:00 a.m. to 5:00 p.m.
l As explained in an advance notice of proposed policy statement and i
meeting notice published in the Federal Register on December 12 1988, the l
Commission is developing a broad policy on exemptions from regulatory control for practices whose health and safety impacts could be considered below regulatory concern.
The purpose of the policy statement will be to establish the basis on 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 certain radioactive material.
The exemption policy would not assert an absence or threshold of risk from exposure to low levels of radiation but rather would establish a basis that would define when government regulation to further reduce risks is unwarranted.
The concept of regulatory exemptions is not new.
For example, in 1960 and 1970, the Comission issued tables of exempt quantities and concentrations for radioactive material that a person could receive, possess, use, transfer, own, or acquire under certain circumstances, without a requirement for a license.
The Comission believes that these " practice-specific" exemptions should be encomp'assed within a broader NRC policy.
For exempted practices, the Comission's regulatory involvement could be essentially limited to licensing, inspection, and compliance activities associated with the transfer of the radioactive material from a controlled to an exempt status.
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Although several advisory and scientific bodies support the need for an exemption policy, they have offered diverse views to the Comission regarding policy provisions.
For example, there is no clear consensus based on existing scientific evidence or research regarding the selection of the specific numer-ical values that could be used in the policy statement. The Commission is, in fact, aware that there are differing views even within the NRC staff on the selection of numerical criteria that are below regulatory concern.
In the absence of a scientific consensus, it is the Comission's task to assess the diversity of views in establishing a responsible below-regulatory-concern policy.
The Commission is interested in assessing how the fundamental principles of radiation protection should be applied in establishing criteria for the release of radioactive materials froth regulatory control. These principles use of radiation or radioactive materials; (2) quires a net benefit from the are:
(1) justification of a practice, which recose limits, which establish the upper boundary)of adequate protection of the public from nuclearthe principle of k activities;and(3 reasonably achievable (ALARA), economic and social factors being taken into account.
In considering the principle of justification of practice, the Comission questiohs whether certain practices should be excluded from consideration for exemption if they appear to have no reasonable justification, whether the social acceptability of a practice should be considered, and whether the existence of an economical nonradioactive alternative would make a practice unjustified.
The Commission is proposing to include in its policy an individual dose criterion that would essentially define the achievement of ALARA; that is, if the doses from a practice proposed for exemption are projected to be below this individual dose criterion, no cost-benefit analysis would be required to demonstrate achievement of ALARA and a decision on exemption could be made on the basis of simple antlysis and judgments. The Comission presently believes 10 millirem per year to be an appropriate individual cose criterion.
The Commission is also seeking input on whether a collective dose criterion should also be used for judging the achievement of ALARA. The collective dcse is the sum of individual doses.
In addition, the Commission is seeking input on what approaches should be used to ensure that individuals will not be exposed to doses exceeding the overall dose limits from the combination of exposures from various practices.
Persons who wish to s eak at the January 12 meeting should call Catherine R. Mattsen, telephone (301 492-3638, or William R. Lahs, telephone (301)492-3774, so that they can be scheduled on the agenda. The meeting will be broken into times to discuss the four major issues:
(1)justificationof practice,(2)individualdosecriterion,(3)collectivedosecriterion,and(4) multiple exposures, as well as a general question and coment period.
Written comments on the planned policy statement should be submitted by January 30, 1989, and should be addressed to:
Secretary, U.S. Nuclear Regulatory Comission, Washington, DC 20555, Attention: Docketing and Service l*
Branch.
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S hgget Federal Resister / Vol. 53. No. 238 / Monday December 12. 1968 / Proposed Rules Adrninistration (13 CFR 121.2) has loading and unloading pauetised Aveben r: Soes. t.ts. as list. M u amended.'P U.S C en.e74 l
defined small agneultural producers as enerchandise by fork lifts and pallet those having annual gross revenue for jacks. Authontmg a contamer of the
- 1. Section 371.3221s amended by a
the last three years of less than $500.000, correct tire to be pelletired should revising the introductory text.
t and small egneultural service firms are facihtete the efficient movement of redesngnating paragraphs (a)(4) and t
defined as those whose gross armual lettuce from the packinghouse to the (s)(5) as (6)l6) and (t)(6), respecta ely, a
receipts are less than $3.600.000. The
- consumer, and addmg new paragraphs (a)(4) and I
melonty of handlers and producers of The use of this container would (b)(3) to read as follows:
I South Texas lettuce may be classified as enable lettuce shippers to take t
small entities.
advantage of the benefits denved by the 9 8M 888 N'"8'"8 88888883-(
As of October 14.1968, estimated use of pallets. Texas lettuce shippers During the period beginning South Texas lettuce acreage planted would also be able to fill orders for Novemberis and endina March 31 each
)
3 was 1. Des acres compared to 476 acres pellettred loads and compete with aesson no person shall handle any lot at the same time in 1987. Total plantings California and Arisons shippers for this of lettuce grown in the production area
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f:t the 1966 40 season are expected to market.The proposed container is unless such lettuce meets the t
approximate 1.600 acres, which is up designsted as carnet container No.79-requirements of paragraphs (a). (b). and t
considerably from last year's total of 47, which is consistent with the (c) of this section, or unless such lettuce p
t 1.629 acres. Total shipments of South manufacturers identification number. in is handled in accordance with Texas lettuce for the 1987-48 crop wen addition. the proposed regulation would paragraph (d)or(e)of this section.
approx.imately 734.000 cartons. Total require that only 18,24. or 30 heads of Further no person may package lettuce J
l ahnpments for the 1980-80 crop are wrapped and unwrapped lettuce may be during the above period on any Sunday, g
protected by the committee at 750.000 packed in this container. Pecking 24 or or on Christmas Day unless approved in t
cartone.The mejority c the crop is 30 heads oflettuce in the propoud accordance with paragraph (f) of this
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shipped to the tinh r He ets, with only a container is the industry norm.
- ction.
g small volume utile ;" stocenors.
However, the committee believes it is (a) * ' '
f necena to include the 16. count limit (4) Cartone with inside dimensions of 1
The handlingr.e e ants for South 1
Texas lettuce sty.n / 4ed in i 971.312 to allow or packing larger heads of 10% inches x 15% inchu x 13%
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(81 FR 2. lanuary m. u6). The cunent lettuee.
inches (designated as camer container requirements for South Texas lettuce in acent yeam, the shipping staton No M7) t'f I
spectfy the inside dimensions of the four for South Tsxas lettuce has begun in late (b),,,'
j containere that may be used to pack November rather than early December.
g lettuce and the number of beads that This snift has been caused by changes (3) 14ttuce heada in carrier container may be packed per container.
in cultural practices, such as the use of No.79-47 may be packed only 18,24. or Additionally, inspection is required and black plastic and the transplanting of 30 heads per container.
packagmg lettuce on any Sunday or on Christmas Day is prohibited.
wed! mas. The committee has Dated. Decesiber 7, tees.
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This proposed rule would authonse a recommended that the beginning of the, Robert C. Kessey, new container for shipping South Texas effective pened for the handling pp,y p g g.,,g, lettuce and change the begmning of the regulat on be changed from December 1 py.,,,, wwg,%.,,,,
l to November 18 wo that it will coincide (FR Doc. 06-2asto Filed 11-6.ea, eLas am)
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effective pened for the handling regulation foe December 1 to November with the shipping season.nis action g
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16.These changes were unanimously will ensure the uniform application of 8
l recommended by the South Texas marketing order requirements to all lattuce Committee shipments of South Texas lettuce, NUCLEAR RESULATORY o
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The four containers currently Besed on the above, the Administrator 000"O cuthonud under the handlms regulation of AMS has determined that this action l
do not have the conect dimensions would not have a significant economic 10 CFR CM necessary to be properly stacked on impset on a substantial number of small f
pallete.The recommended new entities.
Pelley Statement en Esemptons From g
container, with inside dimensions of A 30. day comment period is provided Regulatery Centrol 23% inches (length) x 15% inches to allow interested persons sufficient g
(width) x 10% inches (depth). is of tirne to respond to this reposal. All Aassect. Nuclear Regulatory 3
proper site to be palletised.The wntten comments time received will Commission.
t dimensions of a standard pallet are 48 be considered before a nel Acnoses: Advance notice of proposed h
inches (length) x 40 inches (width). The determination is made on this matter.
statement and meeting.
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,a recommended container would be etacked in layers of five on the pallet ust of Sub}ects in 7 CFR Part 971 spesesAar.The NRC is in the process of g
and 100 percent pallet utiliution would Marketing agreements and ordera, developing a broad policy on k
exemptions from regulatory control for be possible when using such container.
lettuce, South Texas.
Practices whose health and safety
,8 The malonty oflettuce shipped from For Ge nasons ut forth in de impacts could be considered below
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California and Arizona, the top two preamble,it is proposed that 7 CFR Part regulatory concern.This policy lettuce producing States. is shipped on 971 be amended as follows:
statement would provide for more pellets.ne use of pallets reduces the efficient and consistent regulatory handling of tr.dh'idual containers, which PART 971-LETTUCE GROWN IN actions in connection with exemptions 3
in turn reduces damage caused by LOWER RIO ORANDE VALLEY IN from various specific Commission exceulve handling and reduces SOUTH TEKAS handling costs. Palletized loads are requirements.The Commissien in l
preferred by produce warehouses and
- 1. The authority citation for 7 CFR formulating this Advance Nct e is retail outlets because of the ease of Part 971 continues to read as follows:
seeking public input on some ideofic A
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' Federpl Regletee / Vol. 63. No. 238 / Monday. December 12. 1988 / Proposed Rules does7 Id omtions. hich are key considmuone country's border. lt le hoped that Commission may initiate the
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in develope g ovch a policy.De NRC exchanges ofideas and information development of appropnote regulations staff wiU sonduct a meeting to inform such as occurred at theintomational or make boensmg d cisions to exempt the public of its intentions, spectfloaUy. workshop wi!L besides providing one from regulatory control persons who to clanty and onewer questions avenue ofinput to the Conanussion's receive, possess, use, transfer. own. or l
concerning the advance motice, and to actions. lead toward a greater degree of acquire certain ratioactive material l
i hear prehminary views concoming a consistancy in such exemptions world.
This policyle dimeted pnncipany policy for exemptions with emphasis on wide. At the intemational workshop, the toward rulemaking actmtin, but may l
the specific queouone taleed by the
- Advance Nouce of the Development of be applied to boense amendments or l
C mmisolon.
a Commiselon Policy on hemptions license applications involving the paret: Meeting to be held on lanuary from Regulatorf Control for Precuces please of beensed radioactive material 22.1940. Written commente should be Whose Public Health and Safety eithu a the envhnment w to pmm submitted by January 30.1ges.
Impacts are Below Regulatory Concern",
Commente received after this date will presented k this nouce, was made who would be nempt from Commiselon regulauone. it is important to emphaeite be considered if it is practical to do so.
available for discupion.The transcript that this polely does not asset an but assurance of consideration can only of the internauonal workshop which be given es to commente received on or includes all the papero presented et the absence or thrvehold of risk but rather before this date, meeting may be examined and copied establishes a baseline where further Assantsas: Meeting will be held at the for a fee at the NRC Public Document govemment regulations to reduce risks i
Hilida Inn staoWisconsin Annue Room at 2120 L Street. NW.,
is unwarranted.
Bethesda, MD 30014 (4 blocks north o't Washington. DC.
The concept of regulatory exempuone le now new. For example,in teso and the Bethesda Metro Station). Telephone: Advance Notice of the Development of a 1970, the Commission promulg (301) Gla-3000,1-00H6H329. Mail r a==laalan Poucy tables of eneropt quanuties and N clearReg[a$o ommi i latroduction ond Aupwe concentretions for todioactin material Washington, DC,30666 Attendon:
Over the last several years, the which a person, under certain c
tanm, mld scim, pwpu, Docketing and Service Branch.
Commluton hu become incmasingly ockvi$le
.Ro e,
be een heothsa to na7e n
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tens or 7:30 a.m. and 4:18 p.m. weekdays.
release of re&oacuve matwiele from
- 26. P Copies of the commente received may repletory control. To address thle need.
0). Othw mapum a11 ming be examined and copied for a fee at the the Commission le expandmg uponits u n emumw pWucts w NRC Public Document Room at 2120 L exas polley for protecnon of the other deview to the general public, or Strwt. NW., Washington. DC-pubb m re&suon, curnntly "U"a"I "I'** d "d*I" I
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.,t ex,ressed a eue
,epia c oe embo&ed in ee Commink+a e Catherine R. Matteen. telephone (301) 10 Code of Federe etuletions)and I
"W'U " I"**"*'
492-3638, or William R. labs. telephone M,cudy. es law 14nt Ra' M"un licy etstements (30 FR 3462. Use of (301) 492-3774, Office of Nuclear hproduct Materialand Source dioac um Pdcy Amadents Act of t968 Regulatory Research. U.S. Nuclear Material dated Merch 16,1065: 47 m Regulatory Commission, Wuhington.
57446, Licens Requimments forland directed the Commluton to dmlop DC. 30666.
Disposalof A oscove Waste, dated standards and procedurn fu sum.sesserrAmy esponenar,ese December 27,1983: and 81 FR 30830.
expe&um handing of peuuta 2 Ceneral Statement of Policy and mmPurom meulawn se sepwalM latemationalWeekaboP Procedurn Concoming Peutions slighuy contammated radioscuve waste in addition to conducting this public Pursuant to i 1.802 for Disposal of matuial est the Commlulon s eetms, the Commiselon has sought Radioacuve Weste Streams Below determined to be below regulatory input from the interna tional regulatory Repletory Concem, dated August as, concom.The Commission responded to community through aninfomanonal 1986). The expansion includes the
$le legislaun bylasuing a policy workshop on exempbons from denlopment of an explicit policy on the statement on August 30,1986 (81 m regulatory controlwhich was held exemption from regulatory control of 30639). That statement contained critwie October 17-10.1988 in Washington. DC.
practices whose public health and which, if natisfactorily addressed in a The importance of such interaction safety impacts are below regulatory petition for rulemaking, would allow the stems from the fact that many existing concem. A practice is defined in this Commissin to act expe&uouslyin and potential exemptions involve policy as an acevity or a set or proposing appropriate regulatory relief radioactive meten'als purposefully used combinetion of a number of shallar sets on a practice-specific" basis consistent in consumer products or introduced into of coordinated and continuing activities with the merite of the petition, various products or materials through aimed at a sinn purpose which involve The Commission believes that these the scycling of contaminated scrap.
the potential for todiction exposure.
- practice-specific" exempuone should either of which may enter international Under thle policy, the defialtion of be encomposeed within a broader NRC trade. Even effluents and waste disposal caninvolve exposures to people in '
practice"le a critical feature which will policy which defines levels of radiation assure that the formulauen of risk below which specified practices countries other than those from which exemptions from regulatory control will would not require NRC repletion based the effluent or wute onginated. '!his not allow deliberste dilution of material on public health and safety intereste, aspect le a significantissue in the or frecuonaton of a practice for the For such exemption practices, the European commurJty. Due, some purpose of circumventing controls that Commlulon's regulatory involvement degrw of consisteney intemationally le would otherwise be appbcable, could therefore be euentially limited to desirable, since exemption decisions The purpose of this polley statement licenomg. inspection, and comphance enn affect populations outside each is to utablish the basis upon which the acuvides associated with the transfer of 4,
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Federal Regleter / Vol. 53. No. tag / Monday. December 12, taag / proposed Rales L
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the radioative material from o controlled international community,%e values Aherastive hypotheses beve been to an anempt status.
under eensideredein this Policy proposed and reevduouans of the data s
no Commission noegnises that,if a Statement do not asemanardy agree with base at higher doses senhaus.De i
nationalpolicy on exemphone from those selected or under consideration by Commissian betwves that use of the nguistory controlis to be efectiva, ohr countnea.no Comminion has linear mos.thmbold bypothesia nuowe Agrument States wiU pay animportant carefuuy reviewed thoes alternate the theoreucal estabbsbawal of upper implementstion role. In the past, States entaria. and does not And signi$ cant halts on the number of beetih e5ects i
have been encouresing findings that scientt$c evidence that wouid dictate that might occw at verylow dosee certain weste6 are below regulatory preferentalselectionof any of those which are the subject of the exemption concern and the Comminion believes viewe over whatis proposed in this
- policy, that States will support en expenolon of Policy Statement.
De risk of duth to anindividual,u these views to all procticoe involving Ra& ados Prokc6on Prbciph calculated using Se linear model,is I
shown in Table 1 for sarious defined exempt distribubon or release of radioactive material. no Commiselon ne Commission recognises that thne levels of individual dose. A redisuon intends that rulemakings codifying fundamental principles of rediation exposure of to arem per year (0.1 mSv regulatory control exemptions whl be protection heve historicaUy guided the per par)for a hieuse correspede made e matter of compatibility for formuleuon of a system of dose theoreticaDy to an increase oIO 1% of W - n t States. Consequently, any limitstion to protect workere and the h ia&vidud's annut rbk d cance i
ruIemakings that evolve from this policy public from the potentiaUy harmful death.De hietime risk la based upon will be coordinated with the States.
effects of radiation.ney are:(1)h h furthe amumpuon ht 6e exposure Advisory and scientiBc bodies have justification of the precuce,whic levelis the name for each year of a 70 i
offered diverse views to the Commission requires that there be some met bene 84 par hieums.
In enucipsuon of this Pohey Statement.
resulting from the use of todiaban or la eenmaung the done reks to nere la not clear==== based on todioacuve materials. (2) dose halts, inembers of the pubhc that might ario existing scienttfic evidence or rnearch which define the upper boundary of
& rough h use d vu6me procuces fw regardag the selection of numerical edequate protection for a member of the whle exempucas are king considmed, criteria for use la this Policy Statement.
pubbc whis should not be exceeded in the Commission has decided to apply Further, the Commasalon is aware that the conduct of nuclear activttles, and (3) h concept d b eSecun dm L
there are di5ering views within the NRC ALARA, which requires that redaban equivalent." Dis concept, which is
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staff on the selection of numerical dose be as low as is reasonably bmd e a tempwhen d b deland F
criterial for BRC.
echievabla, economic and social factore mortahty efece dlealmas radiate In the obsence of a scientific being taken into encount.De tens'As le ',*g,'
d "esash$ db ALARA. is an acronym for As law l
consensus, it is the Commission's task to h eMo nuess the divoratty of views in Reasonably Achievable.De wbole body does equivdut oiparhal esteblishing a responsible BRC poucy.
Commismon is interested in aseseeing DA Ppro hwas l
The authonty and responsibibty to make how these prmciples abound be applied 7,g,,g*by h the final selection of criteria rests with in establishing appropriate cettens for g,,,,,,g3,,,3rs.
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the Commiselon. Criterie selected must:
release of redsoecove materials tren Ra&dogicalProtecuon and was Amt (1) Provide masonable assurance that to story control.
expressed in its Publication as taeued in s
will be une of the absence of observed 19'r7 Since that time, the concepi bas public health and safefstent with euchhealth effects below 6 res/ year 180 been reviewed and evaluated by t
protected, and (2) cone assurance, pennit practices in the public mSv/ year), scientiac uperm lacle&ng todietion prowcum mganisatins
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domain which imedw the see of the InternationalCommission on throughout the world and has gained radioisotopes for which society Radiological Protection (ICRP) and the perceives a demand.
NationalCouncil on Radiation wide acceptance.
it is recognised that there is a delicate Protection and Measurements (NCRP)
TAna18 belance bero. Criterte een be set make the assumption that the troquency sufficiently restrictin such that there is of occurrence of health effects per unit L88*",,*8 absolute escuesnee that beslth and does at low does levels is the same as at w
safety will always be protected, no high doses (to RAD (0.1 Gy)) where som e,no ma i,
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netter what events might transpire, health e5ects have been observed and a n o esse However,in doing so, the regulator may studied in humans and animals. Die 100 m m '
axto" t:to-*
then pleos undue and -===y linear non-threshold hypothesis soeuses notrictions en procuous wtuch abould that the risk of radiation induced e5ects
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t be permitted becense of othennae (pnncipally cancer)is linearlF oE axto" 1ste*
l; masonable social, conaamic, or proportional to done, no matter how i met ensammes e amie" somtaxie"e,. I l
industiral comanderations.Dere is small h does might be.The cos!!icient
%"""@*, "d"" g '0,",',,,, no,
always the danger d over regulation used in the modalas a basis for which results an effects that am felt in estimating statistical health risk is os een amust som es sowess s eneense a ge Q jt. at M %ge,m,a,_ norme, g amas wt.are h NRC does not have the ordw of 2x10" risk of fatalcancer outhority and responsibility. Moreover, per person-rom of radiation does eme. esa a usosas erwies enemage meressen s b Atomic Energy Act does not require (2x10-8 per SV).De Commission absolute aneurances of safety in b une recognises thatitis e conservative
@,,*,,s"" tine *m" mesi e I"e*s*se U of redioactive material and ucanned modelbased upon date collected at amees
- esween enese a ve soor era en W,,,Q' "" ****** * "**'* * [,
facilities, relativaly high doses and dose rates The numericalcriteria ultimately which is then axtrepolated to the low eelected will have significant impact on does and done rate region where then De Comn$sion recognises thatitis nuclear reguladon bero in the IJnited are no statistically rehable impossible to measure nak to States and potentially in h epidemiological data evallable.
tndividuals or populations directly, and.
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' Federpt Register / Vol. 53, No. 238 / Menday December 12.1984/ Proposed Rules 49330 that in most altustions, it is impractical licensee's control (natural background 1.he application or emotinuation of to measure annual doses to individuals and medical exposures are excluded),
regulatory controle se the preetice dwo at the low levels imphed by exemption Because of the small risks involved, a 10 not result in any significant reduction in decisions.Typicany, radioisotope miem (0.1 mSv) individual dose criterion the dou received by individuals within concentretions or radiation levels from is proposed as the basis for exemption the criticalgroup and by the exposed the material to be exempted are the decisions based on etmple analysis and population or, i
actual measurements that can be made, judgements.The Cornmission 1.The costa of the regulatory controle and doses are then estimated by specifically seeks comment on the need that could be impoeed for dose expcsun pathway analysis combined for estabbshing a collective dose limit in reduction are not balanced by the with other types of assumptions related addition to en tndividual dose criterion.
commeneurste reduction in nok that to the ways in which people might if such a collective dose criterion le could be realised.
become exposed. Under such con &tions, needed, what is the basis for this need?
For purposes ofimplementing its conservative assumptions are frequently lf the Commission decides that a policy, the Commission recognizes that und in modeling so that the actual dose collective dose criterion is needed. what only under unusual circumstances is on the low side of the calculated dose, approaches allowing truncation of would practices which coup radiation The Commission believes that this is the individual dose in calculation of exposures approaching the 100 mrem per 4
appropriate approach to be taken when collective dose or weighting factore for year (1 mSv per year) tunit be determining if an exemption from components of collecuve dose would be considered as candidates for exemption.
atory controls is warranted.
appropriate? What alternatives should he Commluton will consider such Uective dose is the sum of the be considered for assessing societal circumstances on a can specific buis individual doen resulting from a impacti using the general principles outlined in practice or source of radiation exposure.
- AIARA-The A1. ARA principle this policy statement. However, as the By assigning coUective dose a monetary generally applies to determining dose doses and attendant risks to members of value,it can be used in cost benefit and levels below which exemptions may be the exposed population decrosse, the f
other quantitative analysis techniques. it granted on a cost benefit basis.
need for regulatory controle decreaus is a factor to consider in balancing However,it le the purpose of this policy and the analysis needed to support a benefits and societalimpact.
to establish criteria which would in proposal for exemption can reasonably effect delinute achimment of A1 ARA be somewhat simplified.
considerations in Cronting Exemptions i
rrun u,*ory Comra
~?gegi?i,lfs',Massonsbiy
'a ne Co=mi ion i. ~iuses e use l
T'oe following elementa are being project what the dose will be from a d '",'
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,'f" # 8 O' considered b the Commission as a practice, and then take this information [
l basis for evafusting precuces which areinto account in controlling regulated b a indi nnus d se I
proposed to be exempt from regulatory practices so that the dose limits are not reas nobly expected to be received u a l
control.These precuces.if approved.
exceeded. exemptions imply some ruuh d me prochee and N a monum would result in products containing low degree of loss of control. The
- of societalimpact to the exposed l
levels of radioactive material being Commission believes that a key l
d:stnbuted to the genetal public and consideration in establishing a policy for population.These criteria are being considered to assure that, for a given radioactive effluents and solid waste exemptions, and subsequently in exempted practice, no individual will be l
being released to areas of the publicly-specific rulemaking or hcensing expond to a significant risk and that the accessible erwironment.
decisions,is the question of whether Population as a whole does not suffer a
- Justification-The Cotarnluton individuals may exponence radiabon neks comment on the extent to which exposure approaching the limiting significant impact.
l exposures resulting from any procace values through the cumulative effects of If the individual doses from a practice t
should be justified. As lower levels of more than one practice, even though the under consideration for exemption are i
radiation exposure are projected should exposures from each procuce are only sufficiently small, the attendant risks i
lowerlevels of benefit be requimd for small fractions of the hmit.The wiu be small compared with other societal riska. The Commission believes practice justification? In estabbshing its Comminion specifically seeks comment
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exemption policy, should the on the inue By appropriate choices of that annualindividial htahry riska l
Commission exclude certain practices exemption criteria and through its below approximately 10**(one in for which there appears to be no evaluations of specific exemption 100.000) are of little concern to most reasonable justification? In considering proposals in implementing the policy, members of socie.Providing for some proposals for exemptions. should the the Commission intends to suure that it margin below this ml, the Commission Commluion evaluato the social is unlikely that any individual will proposee 10 mmm (0.1 m$v) as the level r
acceptability of practices? Should the experience exposures which exceed the of annualindividualexposum.The l
incremental annual tadwidual cancer Commission determine a practice to be 100 mrem per year (1 mSv per year) unjustified if nonradioactive economical limit.
f atality risk associated with an exposure level of to mrem per year (0.1 mSv per e
altematives exist?
- Dose 1.imits and Criterion-Ptsnciples of Exemption year)is about 3 x10**(two in one 3,
indwidual doses from practices A mejor consideration in exempting mi!! ion) as indicated in Table 1 and of 3
exempted under this policy should not any practice from regulatory control the order of 0.1 percent (one in one be aDowed to exceed 100 miem per year hinges on the general question of thousand) of the overall risk of cancer d
(1 mSv per year).This is the dose hmit whether or not application or death.
l for members of the public specified in contmusuon of regulatory controls are In evaluating the need for a collective the final reviolon of to CTR Part 20, necessary and cost effective in reducing dose criterion, the CorrJnission l
Standards for Protection Against dose. To determine if exemption is recognizes that this criterion could be kaistion.The dose tunits m the final appropriate, the Commission must the tunitmg consideration for practices
'evision of to CTR part 20 apply to all determine if one of the followmg involving very small todividual doses to l
sources of radiabon exposun under a conditions is met; very large numbers of people. it is also
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mege Federal Register / Vol. 53. No. Ess / Monday. Deosaber 12. sees / Proposed Rulu recognised that la such cases the from applicable licansing reqairemania.
that ALARA onnalderations have been I
coueettre does artierion would, in effect. Approval of a proposed consumer dealt with, nie approach ta ceanistaat l
spply the ALARA concept to individnal product dependo upon as -w of with past praches e n. censumer doseeless than the below regulatort exposures of penons to radiation as product ruleela no CfR Part aos l
cIncern level of to mrem per year to the wall as an evatuation of b usefalanes in evaluating proposals far esamption individual. Conversely, where the of the product, under this polacy the pnsected a
collecen dose cNterion would not be Cartain practicas involving rediation exposures to sh5erent eomposants of I'
limitms, it would serve no purpose. The or radioacuve malarials have been the aspeeed papelation welbe Commission requests comments on this judged by NRC to be sociaHF comendered erith regard to the potential issue, including comments on what the unacceptable agardhess of how trivial that some ledmdoels may recein dosee magnitude of the collective dose the resulting dose might be and, near the100 mrom per year (1 m6v per should be.
therefore, have been excluded from F**')16mit when doses from other I
cnterion. If any,less than the below exemption. Excluded practices include.
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If the dose is regulatory concern enteria, then the risk but are not limited to, se latentional cone 6deben. lf expmurn fmm from a practice would be considered to introduction of radioactive materialinto meldple proc 6cn een occur wWeh m be A1 ARA without further analysie. 'th toys and products intended for slaninoandy beyond the indlvidual dose Commiesion stresses that adophon of ingution, inhalation or direct enterion (10 arem per year (0.1 mSv per the erstena abound not be construed as e applicadon to the thin (suc.h as year)), the esemption will not be granted decleion that smaller doses are cosmetical, neasseary before a procbee can be in add don to socla!!y unacceptable without further analyels. As arperiance I
exempted, while doses above the uses of radioactive materials, a question is gained, this policy and its -
I entaria would preclude exemptions. On also arises regar%uses where there implementation wiD be reevaluated with I
the contrary, the critana simply are clear economicaJ alternatives, and regard to this issue to assure that the represent a roepe of risk wh6ch the no unique beneSts esist from using exposures to the public remain wall Commuasion beneves is suffic6en07 radioscuve materialWhere risks are below 100 mrem per year (1 mSv par emell compared to other in&vidual and trivial, the regulatory prohibition of such year),
sometal esaks that a cost benefit analysis uses could pose an unnecessary in addittoa to considerations of is not required in order to make a regulatory burden by interfering with the expected activities and pathways, the decision regarding the acceptability of conduct of businesa.
Commission recognises that an esemphon. Precaces not mestas ne Conunission seeks comments on consideration meet also be given to the I
these entens may be granted whehr practices should be potential fw see6dente ad misuse of the exemptions oc a case by.csos baala in categorically excluded based on the ro6cacWw mouriale levolgd in h accordance with the pnncipler Commission's judgement regarding practice. A proposal for exemphon of e t
embo&ed within this pohcy. To further social acceptabillry or the existance of dermed practice amst therefere also emphasise b Consussion's recognaban alternettves. An alternative to addrus the potentials for accidents or i
i that e ngid limitauen on collective done categorical exclusion could be a case misuse, and the consequences of theos would be inappropnals.11 notes that for specific determmation based on a safety exceptionalconditions to terms of I
some practices, such as une of smoke
- analysis, Individuals and collective dosa, detectors, appremable benehts can only be attained through extenstve utilization Proposals for Dempb.an
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and, hence, with a commensurate A proposal for axemption must The Comminalon believes that b L
collective dose.
provide a buis upon which h implementation of an axemption undet L
The t%==w6n is aware that Corrarussion can determine if the baalc
'Al'. ting regulations of the con &tions desenbod above have been this broad policy guidance must be Environmental Protection Agency satisfied. in general this means that b accompanied by a suitable program to establish cntaria more restncave than preposal should address the individual monitor and unfy that the basic exemptions which could otherwise be dose rond societal impact resulting from considerations under which an granted under this proposed policy, the expected actmues under the exemption was issued remain valid. in L
With regard to its own regulations, the esemption. inclu&ng b use of the most cases. the products or materiale Comrnission will evaluate whether there ra6osctive materiais, the pathways of comprising an exempted proctice will
{f',{x]p[g,ana exposure. the levels of activity, and the move from regulatory control to the ere n me ods and constraints for assuring exempt status under e defined set of
{n ples of this po11cy, would be that the assumptions used to define a conditions and criteria. '!he rnonitoring p
practica remairs appropriate as the and verification program must therefore p
radioactive matenals move from be capable of providag the Commission I
helusions hem Demptia,,,
re latory control to en exempt statua.
Eri*N """'*"C' th't th' I
The Comrnission's March 16,1965, a proposal for exemption results in
- Ith thEfor the exemption remain e
conditions notice on the Use of Byproduct Material a rule containing generic requirements, a valid, and that they are being observed.
4 and Source Material. Products Intended person applying to uttiisa the exemption The Commission willdeterame for use by General Pubbe (Consumer would not need to addrena lustification compliance wie the specine condtions Products) 90 FR H62) provides the or ALARA. The Coiranission decision on of an exemption through its established basis for the Commission's approval of such proposals will be based on h licensing and inspection program and the use of bee matanals in consumer beensee's meetmg the con &tions will, from tune to time, conduct stud es products wibut regulatory control on specified in the rule.The promulgation l
the consumar user.This is accomphabed of the rule would.under then as appropnate to apens the impact of l
by case-by. case exempton of the circumstances, constitute a finding that an exempted practice or combinations I
possession and use of approved iterns the exempted practice is justified, and of exempted pract ces.
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1 Fadural Roguer / WL 53. No. 2as / Monder. Decembee sa. toss / Proposed aide, a
- 4gy, TensesterAdessey M procece to a freenen of the some Counsel.FAA. Feet Wenti.Tomas 7elfe-i limtt eprmpnetet 0007 or delivered in dupiecote to Ofboe
.. L laarodmenos and SummaryM Staf 1 Althosph moet exempted soumes of the Aseistaat Chief Conneel Room IL Dmeunion of spectic Questmu Bref would be expemd to into% indrvid.
184, mRding 35. 440D Slee Mound Road, NRC Stat summary and presentakone or vel dem which are a sendt freem qveettone trorn scheduled partsmpans-of the overeu liad. eleseld fleaibilery FoM cHk. huse. Comment remet be A. Apphcotion of pnnciple el justJicauon be meistained by esameenes essene, snaM Dock h M4 including the geestions; hone on a cost bonent beans above to Commente may beinspected et the
- 1. As lower levele of radioWon esposures mremtyeert above locatiesi bettecent the hotare of 4 m pro}ected. ebould lower lente of
- 3. le the evelection of collecen does a.m. and 4 p.m. weekdays, encept bemfit De reannred for itsnficanon'of important in considering the metaple Federal hohdeye.
a proctice winch is e candidete for uposure luue?
gaemp:3ent 4 M1 the applicanon el justL6 cation of A copy of the opphesble 6ervice L la eenetashirig esemption policy.
Pfeceos help to maintain a smallee bulletin may be obtelned from 5ikorsky alwuld the Cenownion esclude ce,.
mus.ber of sonnes mekans it easier to Aircraft. 000 Main Street. Stratford, tem processe for wtush Sm appem (0*tml ovmu exporumt Connectient 00001-1381 or may be to be no mesonable bastificat> eof
& How unportant le monitones to main. emendned in the Regional Rules Docket.
- 5. la seassdenas proposals for esemp.
tainsng eseurance that todmdual en.
Office of the Assistant Chief Counsel.
fsaut?aires do not exceed to the soerell FAA. 440035me Mound Reed. Fort Woa, theuld the Caseensatoa evalueu social acceptability of the precuc,y Wonk. Tents.
- 4. Should the Commiselon determine a UL Geswrtl Discusolos/ Question period.
POR N MON C08Ma m proeuse to be anpuerified If men redio.
Commerite or questions by schedeled per.
logical economasal alternetrees sanatt tempacts. Open to the fleet as ame pw, Donald F.Thompeon. Alstreme Branch.
O ladroWed dose wpenni for detumans mne.
AhTALI.Booten Alrurtft Certification i
schievesual of the *se low as resone, Thou dre of the poblas who w6eb to Mce.Nm Wand FAA.12 atily arAieveble" (ALARA) pnacaple na PeNeo'peu tmy speakang at the sesetsig New Englard Eaecutive enaapuan decisies. making, thosid notify one of she sootace 16esed Burlington,Masaechusette 018D1 i
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med by e Cam-se.on.-e.e
.u m.,,0m L le the appropnetentes of this number Deted m Rochvilla. Maryland. than ad day in19 rested persons are levited to a
effected by the demeren regenimg of Desamhet tees
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participate in the makjeg of the Victor 88e8*. le.
Proposed rule by submitting unch id be med a,
g,
,gini ng Laecoere DuectorforOpemobrin written data, views, er argiamania as
- 3. Should the ladeessai des entonoe (TR Doc.sa Steel FUed 12-6-4k R43 am) they may danist. haanna be chosen on the basas of aeslagsle ename ssaa reen ews should identify tba tegulatory docket nok se le done intemanonelly (t.o.
number and be embaitted la duphcate to IAEA Safety Series No. as) or can a the addreas speciaod above. AU somewhat h ber be veed bandaseysh DEPARTMENT OF TMA800pORTATION communicahona mea 6veden or before ehey des
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Federal Avletion Administration the closing dets for comments willbe considered by the FAA befose taking sources is not unreenandt action on the proposed rula.The
- 4. How toponant la interwuosel can.
14 CFM Part 39 proposal cantained la this notice may be sietency m choosing an indmdual changed la light of comments received, does antenoat (Dookstha M AS M Commenta are speciAcally lavtsed on C. Une of a coUecovo does entanon for Airworthiness Directives; Saioretry the overall regulatory.cocoondc.
determintag achievement of the ALARA Aircraft Model S 79 Series HoHoopters environmental and energy espects of Pnnetple in exemption decision.sekang the proposed rule. All comments
- 1. le a collective do.e cetterion onded asasecv: Federal Aviation submitted will be eveilable, both before l
in oddauon to as tedindual dose crite. Administration (FAA). DOT.
and after the closing date for comments.
ac.PRM).noet Natce of i+
" r=lamahing in the Rules Dodet. Offloe of the L U so, what is the beelv of that needP g
Assistant Chief Coassel. FAA 4400 Blas
- 3. H On hunos deadn a cotee**
l dose creenen shoekt be med, what Mound Road. Forth Worth. Toast, for suasesaavt This notice proposes to adopt examination by interested persons. A i
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a new airworthiness directive (AD) that r, port summarising eed FAA public i
cmenos should be cos,medared is no.
would regur,s e servios hfe bort en the contact, concernad with the embetanca
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tall rotor norn on Sikorsky Model S-76 of the proposed AD.willbe fLled in the e
E. In calculauas caueetsve does, what senee helicopters.The proposed AD is Rules Dockat.
I appronshes allowing truncation of in.
needed to prevent a fatigue failure of the dmdual doses of the use of weighting tall rotor horn which could result in loss Commenters wishing the FAA to facterre her componems of coDectres of directionalcontrolof the belicapter
-acknpledge Mceipt of Mr commuts done are apprepnetet and subsequent loss of the helicopter.
submitted in response to Gns notice must submit a self eddressed, stamped D. Approaches For eseerht totel expo.
Daft Comments must be *eceived as se I
postcard on which the following 8'
- P' before January 1L18EBL statement is made: Comments to Docket t
hm yen lam,t ADORE 9eek Comments on the proposal No. a6-ASW-44.The postcard will be
- 1. b inn apseseek af powelty haemes may be mailed in duplicate to: Rules date/tirse stamped and rerereed to the insbesh.ais desse trum each seine oc Docket.Offace of the Assistant Chh!
commenter.
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(s:$tello NUCLEAR REGULATWidMihMMlGNLY Taylor 64 I
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SERNERO Thomoson FUN 0HES Jordan 7,L Degg0 88 Murray Central Files 7g 6
The Honorable Londo W. Zech, Jr.
Chairman OTHER:
l U.S. Nuclear Regulatory Comissien i
Washington, D.C.
20555 t
Dear Chairman Zech:
l
SUBJECT:
COMMENTS ON ADVANCE NOTICE OF THE DEVELOPMENT OF A COMMIS$10N POLICY CN EXEMPTIONS FROM REGULATORY CONTROL FOR PRACTICES WH0SE PUBLIC t
HEALTH AND SAFETY IMPACTS ARE BELOW REGULATORY CONCERN the fifth meeting of the Advisory Comittee on Nuclear Weste December Durin 21 1 BB, we discussed the "Advence Notice of the Development of a domission Policy on Exemptions From Regulatory Control for Practices Whose Public Feelth and Safety Impacts Are Below Regulatory Concern." This subject was also discussed with you and your fellow Comissioners during our meeting with you on October 27, 1988. We had previously submitted several written reports on this matter to you.
The purpcse of this report is to provide you with our responses to the several questions on which the proposed Policy Statement requested comments and to effer our coments on selected positions and/or premises outlined in the Policy Statement.
1.
Justification of Practices in establishing its exemption policy, should the Commission ex-clude certain practices for which there appears to be no reason-able justification?
In considering proposals for exem)tions, should the Comissioii evaluate the social acceptability of prac-tices?
Response
The ACNW believes that practices for which there appears to be no reasonable justification, particularly those that are considered to be of a " frivolous' nature, should be excluded from exemption.
We concur with the staff in the examples that they cited for this category.
At the same time, however, we would urge that the Comission recognize that what may be considered to be unjustified by one group may not be simi-larly regarded by others.
We continue to believe that the Counission should exercise considerable care in reaching judgments on this matter.
2.
Dese Limits and Criteria The Comissien specifically seeks coment on the need for estab-lishing a collective dose limit in addition to en individual dose bMY
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h' The Honorable Lando W. Zech, Jr. December 30, 1988 criterion.
If such a ecliective dose criterien is needed, what is l
the basis for this need?
If the Commission decides that a col-J 1ective dose criterion is needed, what approaches allowing trunca.
1 tien of individual dose in calculation of collective dose or weighting factors for components of collective dose would be appropriate? What alternatives should be considered for assess-l ing sccietal impact?
Response
l a.
Collective Dose Criterion We continue to believe that a collective dose exemption level (or 3
criterion) is necessary, but we also recognize that some flexibility should be allowed in setting that criterion.
It is important to recall that annual doses to individual members of the public arising from en exempted practice will be estimated by use of models and i
assumed scenarios.
These models will not be, and prcbably cannot be, validated.
As a result, dose estimates derived through the application of such models will contain potentially important uncer-teinties.
Further, exemption from controls also increases the range of possible exposure scenarios that can take place. This will add i
to the uncertain nature of the calculations. Although we are aware i
that estimates of collective population doses and determination of compliance are plagued by the same kinds of uncertainties, the additional constraints imposed by collective dose exemption levels should provide some further assurance of the continued acceptability of a practice that has been exempted.
We believe that the magnitude of the collective deso criterion should depend on the associated dose rett to individual menbers of the public. As one possible approach, the Counission might consider that, for sources, practices, and/or devices that result in a dose rate as high as 10 mrom per year to individual members of the public the collective dose criterion should be no greater than several hundred person res per year.
For activities that result in dose rates well below 1 mrem per year, a collective dose criterion of several thousand person-res per year might be considered, b.
Truncation of Collective Dose Although a number of groups (such as the National Council on Re-dietion Protection and Measurements) have proposed individual dose l
rates (for example,1 mrom per year or less) et which collective l
dose calculations should be truncated, we believe that such an approach would be strongly opposed by many groups witMn the public.
We recommend that those respcnsible for calculating the impacts associated with a given practice being considered for exemption be t
required not only to provide an estimate of the total collective dose but also to provide data on the number of people within each g
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The Fonorable Londo W. Zech, Jr. December 30, 1988 dose rate range.
Following this practice, all interested parties would be provided with detailed information on the contribution to the total collective dose by population groups in all dose rate ranges, including those in the extremely low rentes, and the Com-missien could take this information into consider & tion in deciding whether to exempt the practice.
We believe the collective dose exemption approach suggested above will be helpful in making such judgments.
c.
Alternatives for Assessing $ecietal Impacts The Comittee is not able to coment on the issues surrounding the social acceptability of a practice under consideration for exemp-tien. We urge the Comission to proceed into this area with caution owing to the extensive and potentially unproductive polemics that could easily be generated.
3.
Role of the As low As Reasonably Achievable (ALARA) Criterion l
In the Advance Notice of the Comission Policy, the NRC staff stated that, "If the dose is less than the below regulatory concern criteria, then the risk from a practice would be con-sidered to be ALARA without further analysis."
Response
We believe that this statement is confusing and that it does not repre-sent the approach that the NRC staff has indicated that it intends to follow.
L In all cases, the staff has indicated that no practice would be exempted j
without a careful review of all details of its proposed application, that all practices will have to be justified, and that the proposed licensee will have to demonstrate that the given practice incorporates good radiation protection - principles.
For those practices that are exempted, there will be 1eriodic, subsequent reviews to assure that they i
are properly implementec and that they do not result in dose rates to individual members of the public in excess of what was predicted.
j-Rather than characterize the exempted practice in tems of the ALARA criterion, we believe it would be better simply to say that the practice l
satisfies NRC radiation protection criteria, and its 1spects have been I
j found to be so small that the Comission has deemed it acceptable for l
the practice to be used or for the device or source to be released to the general public.
t 4
Designation of. Exemption Levels In discussions on this aspect of the Policy Statement questions have been raised on several occasions on the individual, dose rates l
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The Henorable Londo W. Zech, Jr.
4-December 30, 1988 that would be considered to be acceptable for exempted practices, 1
sources, and devices.
Although the Comission did not explicitly request conments on this matter, the Comittee desires to offer the following remarks.
Respense First, it is important to note that there are practices, sources, and/or devices that result in exposure to the public for which exemptions have already been granted.
These include consumer products, such as luminous dial watches exempted by the U.S. Nuclear Regulatory Comission, as well as items such as television sets that have been exempted by the U.S.
Department of Health and Human services.
In addition, exposures re-sulting from the transportation of radioactive materials have 6een.
3 L
exempted through regulatiens of the U.S. Department of Transportation.
In fact, according to studies of the National Council on Radiation L
Protection and Measurements (NCRP Report No. 95 the average dose rate to individual members of the U.$. December 1987),from public arising the use of consumer products (involving both radioactive materials and radiation generating machines) is currently at a level of 10 prem per year.
In short, this is not a new field.
second, although the Policy statemert implies that some practices that could result in dose rates nf as much as 100 mrom per year might be considered for exemption, we believe it is important to note that 100 mrem per year is the longl Council on Radiation protection and Measure-term dose limit for mee6ers of the public as recomended by the Nationa ments and the International Commission on Radiological Protection.
It is also the limit recomended for members of the public in the revision being preposed by the NRC to Title 10, part 70, of the Code of Federal Regulations, " Standards for Protection Against Radiation." A dose rate for individual members of the public approaching 100 arem per year should not-be viewed as an exemption level; rather, sources and prac-L tices that have the potential for causing dose rates in this range would have to be regulated.
We foresee no conditions under which such sour-ces, practices, or devices can be consleeres for exemption.
In terms of the exemption of practices, sourecs, and/or devices, it is our opinion that the limiting dose rate for individual meu6ers of the public as a result of exposures from all such exemptions should not exceed a value in the range of a few teWof mres per year.
Following this approach, and assuming that each person has the potentiality of being exposed to more than one such practice or source, then the exemp-tien level per practice should be in the range of, at most, 1 to 10 arem per year.
We note that, in developing an exemption policy, the Com-mission is deciding how much of the 100 mrem per year dose limit for members of the public should be allocated to exempted practices, sour-ces, and/or devices.
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o The Honorable Lando W. Zech, Jr. December 30, 1988 L
Since-other government agencies have similar responsibilities, all such efforts should be well coordinated, and the total dose rate from all empt9d practices must be well below (only a small fraction of) the don 1Mit.
5.
Exposures to Multiple Practices L
The Comission seeks coment on whether individuals may experience radiation exposure approaching the limiting values through the cumulative effects of more than one practice, even though-the exposures from cach practice are only small fractions of the l-
- limit, i
Response
The reeemended dose rate. exemption level of a few mrem per year for i
individual members of the public (arising from a single source, prac.
tice,5 and/or device) should provide reasonable protection against the inadvertent accumulation of annual doses cin-excess of the exemption level for individuals due to exposures to several exempted practices.
p Nevertheless, the Comission will need, in the long run, to guard against. concentrations of exempted practices in localities and 'should include in its rules provisions that allow it to use judgment in this matter.
6.
General Coments In addition to the coments above, the ACNW offers the foilowing general comments.
One requirement that the Comissien should consider for inclusion in the exemption reculations is that for a source.: practice, and/or device to be eli ible for consideration, it must be " inherently" safe. That is to D
say, no accident scenario can be reasonably postulated that would result in doses to individual members of the public greater than a few prem.
l The Comission should also emphasize that, even after the application-of a practice has been justified and approval has been -granted for its the-situation will be reviewed periodically to application and/or use, l conditions are being met and that the given r
ensure that the origina practice, source, and/or device is still acceptable for exemption.2 This is currently a part of the Policy Statement.
It should be emphasized.
. Equally important to the development of an ' exemption policy is the establishment of accepted exposure pathway scenarios, both for routine and/or devices use of and accidents involving the practices, sources, f environmental under consideration. This will require the development o transport models and the derivation of secondary or derived guides (for example, concentration limits for specific radionuclides in low-level m
radioactivewastesthatshouldbeconsideredeligibleforexemption),as
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4 The Honorable Lando W. Zech, Jr. Deces6er 30,1988 well as the development of laboratory.and/or field procedures for making the measurements necessary to confirm that the given practice, source, and/or device complies with the exemption levels.
Finally, we believe that at this stage in the process one of the most important goals should be to develop a policy primarily designed for application on a case-by-case basis.
It is also clear that procedural-flexibility should be explicitly maintained.
A Policy Statement in-corporating both of these attributes can then guide the practices and, as experience is geired, both can be modified, if necessary, to lead to a more workable approach.
We hope these coments will be helpful.
Sincerely, Dade W. Moeller Chairman
Reference:
l
" Mvance Notice of the Development of a Commission Policy on Exemptions From Regulatory Control For Practices Whose Publicl Health and Safety 1mpacts are Below Regulatory Concern," presented at the NRC/NEA Workshop on Rules for Exemption from Regulatory Control on October 17-19,.1988.
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1 AGENDA NBt4 M7!HiG ON POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL Holiday Im, 8120 Wisconsin Avenue, Bethesda, MD Jar w y 12, 1989; 9 a.m. - 5 p.m.
o 09:00 Introduction - William R. Lahs, U.S. Nuclear Regulatory Comission, Chairman 1
PRESENTATION OF GENERAL / BROAD COMMENTS-A 9:15 Dr. Lauriston Taylor, Health Physics Society
/09:35 Ms. Diane D'Arrigo, Nuclear Information and Resource Service M:55 Dr. Allen Brodsky
/ 10:15 Break
/10:30 Dr. Judith Johnsrud, Environmental Coalition on Nuclear Power / Food and water L
/0:50 Fuel Processors Group f1:10 Mr. Jack Ransohoff, Neutron Products 11:30 DISCUSSION OF ISSUES - ISSUE 1 l
Justification of Practice L
11:50 DISCUSSION OF ISSUES - ISSUE 2 Individual Dose Criterion LUNCH l01:30 PP,ESENTATION OF GENERAL / BROAD COMMENTS Mr. Richard Guimond, EPA l
02:00 DISCUSSION OF ISSUES - ISSUE 3 Collective Dose 02:05 Dr. Victor Bond Health Physics Society 02:25 DISCUSSION OF ISSUES - ISSUE 4 Multiple Exposure s
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,~i EXEMPTIONS lFROM REGULATORY CONTROL il SPEAKER SIGN-UP SHEET NAME/ ORGANIZATION :
PHONE :
ISSUE (S) ON WHICH YOU WANT TO SPEAK :
(Please checic) j l
A. GENERAL / BROAD COMMENTS ON SEVERAL ISSUES B. APPLICATION OF THE JUSTIFICATION OF l
PRACTICE : PRINCIPLE i
C. INDIVIDUAL DOSE CRITERION BELOW WHICH "AS LOW t
AS REASONABLY ACHIEVABLE" (ALARA) CONSIDERATIONS ARE NO LONGER REQUIRED D. USE OF COLLECTIVE. DOSE CRITERION BELOW WHICH l
ALARA CONSIDERATIONS ARE NO LONGER REQUIRED
[
E. APPROACHES FOR ASSURING TOTAL EXPOSURES TO l
INDIVIDUALS FROM MULTIPLE PRACTICES WILL l
NOT EXCEED THE APPLICABLE LIMITS i
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