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UNITa0aTATla NUCLE AM Mt0VLATORY COMMIT $10N f
'i ADvis0RY COMITTEE ON AEACTOR SAPE0VARDa N I I E.
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D. W. Moeller. Chairman
}QEMCRANDJMFOR:
ACR$ Subcomittee on Weste Managemer.t F. J. Remick, Member M. J. Steindler, Member h
M. Carter, Censultant Y
F. Parker, Consultant R. Foster, invited Expert
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0, 5. Merrill, Senior Staff Engineer SUNECT:
STA105 REPORT FOR PEETING OF THE ACPS $UBCOMMITTEE Oh WASTE MANAGEMENT ON WEONESDAY, MAY 4, 1988 l
Neetins Netice:
l The ACRS Subcom.ittec er Waste Management will meet in Room H 1167,1717 H S t. N a'.. Washington, D.C. on Wecnescey. May 4, 1988. The meeting will start a; 8:30 a.m. and continue until 5:30 p.m.
t PurDese:
The purp:se of the treeting is to review and ciscuss tha current and potertial applicability of _"dt @imis* and "Selow Regulatory Concern
I concepts to Corrr.ission poliTc es.
Irelement_a tion:
The aben narsed topic will be reviewed and discussed in accordance with an agensi currently being prepared by the NRC Sta'f, which is not yet availabla.
P.r. Robert Bernero of NM55 is organizing the presentations for this meeting, Dr. Moeller requested that the relationship of the issue to Safety Goals Appendix ! of Part 50, and institutional issues also be addressed. The meetir.g will corrnence and end at the times I
indicated above. As explained below. Mr. V. Stello. EDO, has recuested f
ACR$ cer.ents en this sub,iect as soon as is ressor. ably feasible.
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'9006010138 891130 PDR PR CHP1 03FR4986:6 PDC
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Arranceeents:
Hotel reservations have been made for members and consultants as fo lows:
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$Ligl Nishts ef D. voeller Lombardy May 3, 4. 5. and 6 F. temick Makes Own M. Steineler Lombardy May 3 M. Carter Anthony (Tentative)
May 3 R. Foster Crowne Plaza Holiday Inn May 3.4. & 5 i
F. Parker Anthony May 3 i
i tech corluitant and invited expert should provide his hotel with a Mjor credit care number at the time the reservation is page to guarantee late arrival sfter 4:00 p.m.
The Lombardy hotel number is (202) 822 2500tAnthony (202) 223 4320 Rockville. Mc. (301) aff-1100.
and the Crowne Plaza Holiday Inn.
Also, es:h consultant and invited expert should contact Dimensions j
Travel in Bethesda, Md. (301) 986 8949, to make his own travel arrange.
- rents, elease 1centify yourself as an ACR$ consultant er invited If you reed assistance in making these arrangements, centact emptet.
BarbaraJoWhiteat(202)6341406.
Backneound:
During a meeting of Drs. D. W. Moeller and M. J. Steindler with V.
f Stello, the NRC Executive D%ctor of Operations (EDO) to discuss the role of the proposed Advisory Comittee on Nuclear Kaste-(ACWW) ano its relationship to the NRC 5taff Mr. Stello requested that the ACR$
SubcoW ttee on Weste Manageme,nt (or its successor, the ACWW) review and provide corrnents to the Comission on two current issues.
1.
The NRC draf t coments on the DCE Consultation Draft $ite Characterization Plan (CD$CP) cn the proposed Yucca Mountain Nevada geologic repository site.
2.
The NRC Staff Position Paper on the issues of radiation below i
regulatoryconcern(BRC)andjgmihimisradiation.
This Status Report addresses only the second topic; the first one was addrested on April 20, 1988 Status Report. Enc 1cled are documents pertinent to the sutject of this meeting.
They were provided by William R. Labs of RIS who is working closely with R. Cunningham of NMS$ in setting up an International Symposium on the d,e minimis issue discussed
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On August 29, 1960, Appendix 8 to Part 2.. " General $tatement of Policy and Procedures Concerning Petitions Pursuant to Paragraph 2.802 for Disposal of Radioactive Waste $treams Below Regulatory concern," was publishedintheFederalRegister(51FR30839).
It was followed in the 1C
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same notice by "huclear Regulatory Comission Staff Implementation of i
Nuclear Regulater Comission Policy on Radioactive Waste Below Regy.
lateer encerni ( et Attachment 1). xitty eregnnette of the then c
L Divistor of kasta Managerent in NMS$ was the principal author of this l
notice. Thirtete public coments were received in response to this notice, but no NRC response was prepared.
Instead, the event following occurrec.
AnAdvsnceNoticeofPreposedRulemakinf,waspublishedintheFederal Register on Decenter 24 1966($1FR43367 entitled 10 CFR Parts 2 and
- 20. "Radicactive Weste felow Regulatory Concern; Generic Rulemaking,'
(See Attachment 2). Ninety three public coments were received on this t
notice, but no response has as yet been prepared by the NRC $taff, the i
principt1 reason being that the responsibility for this issue was trarsferred from NM55 to the Division of Regulatory Applications in RE5, i
viz., 8'11 Morris, Director and Robert Alexander, Chief of the Radiatien and Hesith Physics tranch.
Within that trancb, William Lahs and $tani y Neuder were assigned the t
resronsibility for pursuing this subject, principally as it related to waste strears below regulatory concern. However, other related tcpics came into the picture in 1987, viz., radicactive waste oil disposti, residua
- radioactivity from decomissicting, and irradiated gemstones, all of thich raise questiens regercing the below regulatory concern and de minir s issues. SECY.86 69 was issued on March 8, 1988 as a Policy Tisue, r"uTject: Current and Pctential Applicability of "dt minimi " and "Italow Fegulatory Concern" Concepts to Comiscien Policies, witn Lanley hevder et, its principal author and peint of contact ($ee Attachment 3).
The abow document fomed the basis for the March 14,1988 Comission Briefint by M111am Labs (See Attacheent 4). A cepy of the tran-scriptienofthatbriefingisalsoprovided(SeeAttachment$).
I would highly recemr'end that you read the entire transcript to get the full fiever o' the meeting, especially the last 27 pages, starting on line 16 on page 33, where Comissioner Bernths) asked, "What would be wrenc with this agency (the NRC) consulting with the ACRS, etc.." and the following exchangc between the Comissioners (principally lech, Bernthal and Carr; and the NRC 5taff (principally Stello, Morris and Alexander). This should bring you up to date on why Mr. Ste110 hes this issue high in his priority list.
As a result of the Comission trie'ing, a 5taff Requirements Memorandum
($RM)wasissuedonthistopiconMarch 30, 1968.
(See Attachment 6).
l This SRM accressed two requests, the rejer issue being delineated in the second paragraph requesting (ions for a Corrrission policy whichthe staff Comiss'en coesideration opt establishes a generic nueber for exposures that are below regulatory I
concern.'etc.
(See paragraph cited). This is the principal reason for the ACR5 review of the Staff's program, which is also to ensure that what the Staff is doing, and proposing to do, is a sound, rational Mr. Lahs has drafted documentation in response to this approaci.
request, but it is preliminary and undergoing internal RES review and is therefore not available to us at this tine. He will discuss its concepts and proposels with the Subcoarnittee during its May 4,1986
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Petting. The second reevest by Comissioner Bernthal, although minor in nature, is nevertheless impcrtant. Mr. Lahs is approaching completion of the Fil response to this request.
The balarce of the SRM, pages ! and 3 should be carefully reviewed, sinceitdelineateswhatthestaff'soptionspaper(thematerissue discussac above) should explicitly identify and specifically include, j
the International Conference on the dg i
Curing the Comission triefing1 March 29.1988 memorandum from R.
minimi issue was discussed.
tem to H. Thompson reported on the fomer's attendance at a joint i
lAEA/N A meeting during March 21 25, 198P. in Vienna, Austria to prepare aguitartedocumentonthegminimisissue. The draft of that document i
enclosed with Mr. Cunningham t memorandum represents the final markup of the craft on the last day of the meeting. Mr. Cunningham states that he believet this " international guidance will now provide a solid tiesis for' preparing broad NRC policy on 'below regulatory concerni and trivial dose.
Mr. Cunningham,is shown in the list of attendees as an observer, and Mr. K. Richarcsen of the Office of Radiation Prngrams of the U.$.
Environrental Protection Agency is shown as the official U.S.A. rep-resentative at the meeting.
Although it is not mentioned in the above memorandum, it is my under-standing fron both Mr. Labs and Diane Flack of the Council on Interagen.
l cyRadiationResearchandPolicyCoordination(C!RRPC),thatMr.
Cunnirghm, with the assistance of Mr. Labs, is setting up an Interna.
l tional Symposium on this subject to be held.at the Pan American Building.
5 here in Washington, D.C. on October 17 18, 1988 and that they are j
inviting representatives from 20 foreign countries to attend. Mrs, i
Flack werks closely with Billy Mills on this n.stter at ClRRPC and is the designa*.ed peint of contact for inferr.ation about the meeting.
(
i Action Seoviredt The enclosed documents should be carefully reviewed in preparation for the meeting. Although much of the meeting will be infomational, you
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will unecuttedly have many questions and coments that need answers and discussion. -Since Mr. Stelle has recuested that the ACR$ review and provide coments on this issue as soon as possible, and since only i
Suticomittee draf t coments will be prepared during the Nay 4th meeting,
'3 the full ACR$ will not be able to review the issue and approve the Subcomittee's comments in a timely manner. :Hence, at the full Comit-tee meeting on May 5 7 Dr. Noeller will request ACRS operoval for R.
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Fraley to transmit to Mr. Stello the Subcomittee's coments.
Enclosurest As stated cc: With
Enclosures:
R. P. $avio
- 5. J. S. Parry R. Kathren
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D. W. Moeller. Chairman 5
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D. Crth Wittout inclosures:
i Otter ACRS Members Otter Acts Consultants:
J. Conoghue i
I K. trauskepf D. Crth G. Thompson J. Till M. Trifur.ac l
ACl$ Techrical Staff Otter ACRS Fellows h
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i LIST OF DOCUMENT $
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Below Regulatory Concern and g minimis Policy Development 1
l Appendix 5 to Part 2 - General Statement of Policy and Procedures 1.
Concerning Petitions Pursuant to Paragraph 2.802 for Dispesal of Radioactive Waste Streams Below Pegulatory Concern 51 FR 30839, dated August 29, 1986.
I 2.
20 CFR Parts 2 are 20. Radioactive Waste Pelow Regulatory Concernt Generic Rulemakingt Advance hetice of Proposed Rulemaking, $1 FR 433f7, put11thed 12/2/t6.
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$ttv-20 69, Current and Potential Applicability of Nie minimus" and 3.
March 8,gulatoryConcern"ConceptstoCommissionPTTcte "Be'cw Re 49PB.
Status Report, Regulatory Cutoffs.. Application of Below Regulate.
4 ry Concern anc h minimis concepts, Comnission Briefing, March 14, 1980.
Transcript of " Briefing on the Status of Efforts to Develop a De S.
14, 1968.
Minamis Policy" pp. 1 59, Washingten, D.C., Monday. Perch Staff Recuirements Memorandum, from $. Chilk to V. Stello, Jr.
6.
Sublect: BriefingontheStatusofEffortstoDevelopagg,minimius Policy, dated March 30, 1986.
l 7.
Memorandum from R. Cunningham to H. Thompson,
Subject:
Internation.
41 GLidance on the dg minimis issue, dated March 29, 1988.
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