ML20043C044
| ML20043C044 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1987 |
| From: | Spangler M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006010235 | |
| Download: ML20043C044 (12) | |
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Safety regulation De minimis risk concepts in the US Nuclear Regulatory Commission, Part 1:
As Low As Reasonably Achievable Miller B Spangler t
Althoaqgh the Angel use of the de minish concepa of
}E ENDPOINT OF OUR haingcol 16 h death, insign{ficent loss k centuries odd, the application of But prior to denh come risks. ne they larp or smeA concepts to sqfety regulation la fairly overnt, small, voluntar Among the saggested applications in regulering redle.
natural or maneade,y or involuntary, new or old, snessurabbe or unquanti6able, the son Asserds eret theserting q(regulemryprioritiest es a suas of all the risks we face add to unity. This is an Jteor'for As Low As Reasonably AcMenable (4LdM) imencopabls 8 set. % an!y sking n=m=aMmA can kop l
consMeredens; es e cut ofleirlfer collecase das, to ben a mansure of control owr is how and when we l
avarssmensst for warl*g 88ter h*88ds */# cogP feel
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4 Dy limitad unes; es efloorJbe ddInitions q(lo~ tent nesre; es e
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Pesemption qrtriviality in irget proeveningst efasser ba sone d 6e estraordswuy k'y number ddismo l_
edministrerin sad regelsery qficiencyt end s proride risks we encounter and the faite limit of our ruouttes persporthefor perflic underssending, includim policy a cowns t%em. Alas, control is amie kas egsctive fedgments.
e.an it ospt to be bemuse of the wide f.ivettence Dispaper (Phrt J ofs tArvepertseries)ssoneefses betwn hea individual members of the puMic perceive de Hstoricel eveintion ef the saplicit avetssent ef de risks sad bcw esperts in industry and pwament niintmh risk cor.ceps 6f de US Nmelser Aquissory eva:uste risks and assunilate come weights with other Comekslon in the o.avecise of the ALdM enterion in
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radiologicelprotection endisfacility decommhstan a, decisions (Spangler,1982 and 1985).
e soorts ofinsft tfor more generelapplicesions in de
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h anrist mengement e/secAnologicot risks. De ather suoparts Ca sshugnant hsmes) willeesmine the use of wbm laws and gowramental agencies how been
..hi,ahed for the social management of risk, among de minish risk conceps: la regwleting wrentam mines other purposes (Douglas,1985) It is a thesis of this cad m/th sad meste management, end in setting sq/rty paper that policy fonnulusion which focuses en the 'de goals and treering the risk ansnaprment hases 4/seiert manimis' or immigniAma' naars af senaan risis can, to a smelser accidenss, useful essent, narrow the pp between how the public perosives and regulators great a numericaUy larp group
. af the risks we face that individusUy or collectiwly may Keywords: risk assessment; safety regulation; de ininumis riek; han aman impon. W funds and energia ihmby nudserpeerping" ~Hm encilay released can then be used for a more efective meatment decommismon of the more truly agaiAmat risks deserweg priority attention for social manapment.
The concept of We muumis' impacts is not new.
Introduced in the Enghsh Coun during Eliasbethan rule in the 16th century, she term ap,'mered in the latin "de minanis non curat le. As explained in dictionaris, this espression means that "the law Miller B 5pansler i Specia! Assistant for Policy pevelopment, (or the court) does not take accotant of trifles, the 08 bee e(Nuclear Raneter Regulauan. US Nuclear Ragulatory genersi principle that some breaches of duty, or Coaunimon, Washington. DC 20555, USA. This artiens, and sbe smetakes in procedure orin deeds, are too trinal to be meet two ports (to appear in our neat two issues) are ne updated made the ground for giving a legal remedy, or version of Chapter 12 ss published by the author in Dr humu dismissing a claim, or as the case may be" (Walker, Ruh Chne Whipple (editor) Plenum Press, forshcoaung 1987.
1980).
1 L
Pro)est Appealsal Decembre 1987 0268 8867/87/04023112 US80100 231
,r-900601023r, s91130
.h1 bFR49886 PDC
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Dr enmum rid sensgm
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Bossume irifbag' or 'rivial' enen beve a pejoratiw his b inponant even thoigh this involves as satidy east, en appmpnete synonym for de miniums,would process er against eranges or the l.
appear to be insigni6 cant', whose maange(quan with inenagibles (Grenen, eennoession is "lachag 19g1 and Spangler,1983).
connderug, inckag wa mennes or isnport, em e
shi, posiden or inausace." ne For suample, the fuel eydes for using eiew coal or dictionary also de6nes tri6ing as "lachas in uranium to pseermee electridty how a number of apl6sance or solid wonh."
einder funesenal elements such as mining, fuel Although de minonis is not a new concept, fu processing, restion, power generation, and waste apphoenon to risk analysis and risk i is esposal. Ne the character d noks to the relatively re.sent - in se last de.ede or so.as a.,,1,mg
- asinonis to. is.the pu.blic and. occupational workers from the two fuel of i
, si,ro e,.s,rovi m nom em.a.
me,mi,u. of.g" Mar,'"ar "!ll"o'4" ice'"as'hae* "':*r.':
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p+=dusa - for ur.-a e
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llll=,,'T =,o'm'".'i"* f,om/.'"*,'M ",e,",j:,i'"al
. *o* es,-re < *e gh; from er poUutanu io nau *. <
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l namgaine==t even in essas where consequences are anaom and hann and d comband u n se paennaDy high l-quae t provided that their probabuities are
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d low probabdity, seven enveme - and esapa suorily - low.
"'"{r a=ca~deu af auchar pown plaou.
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his principle is observeble in the behavior of the public repr6ag routine decisions in their daily liws Since it takes about 15#00 tons of anal to generate the' whenever se probabi'ity of associated fatahty is same amount of eleswicity as one ton of uranium fuel, i
regarded as wry anal' atetistics show that, from a the risk of transportation fatalities from the use of the fatality standpoint, the bathroom is often the least safe istter is insagm6 cant in both an absolute sense and even room in the house. Yet, without signi5 cant attention to more so in relation to the annual nsk of public fatalities to a risk.
decision, we do continue to take beths in the transport of cos!.
despite the of fatal falls or drowmngs and to use However, the purpose of this paper is not to ow.ke l
our electne shaven and hair drien simpete the tid of an analysis of the risks, casu, and bena6ts of nuclear l
alecuocution.
and alternative energy sourses, biber,it has the more We eAes press down on the acceleretore of orar
!anited object've dderiving geuersh*able insights from ~
sutomobiles to avoid being late or swtly to aborten the as emmistks rf bow one reg 9htor) agency, the US bmmiosn or !stigue af drivin6 widle snowing something Mucleat JugM Casanussion (NkC), is progressm3 of the relauen between scarsmal increases in speed and in making esplicit use of de mininds risk coocepts in margina: increases in the risk of fatality. I;ven if reguissing high standards of radialogic*l protection in informed of the smarginal !acrease in risk of cancer froen censin segments of the nuclear fuel cycle. Some of the natural backsmund rsdiadon (coenic and ternstrial)la risks to w,rten and to the pinrM public froen the a month of residence in I:enver versus a month in nuclear fuel cycle nught luontiabiy be regarded as de Mann or New York, most of us would pay little heed nunums, either becate the consequences are r
l to such a anell nsk. Here are literaDy hvadreds of individuauy or couertinly very small or de probabihty I
esa:np!ss of smsU risks in daily living regarded t.:
of ~ ' coat'y larger consgeaces is estremely low.
EragaiAmat se de tuninus. A catalogue and escussion of these kinds abound, not only in energy of many of these are provided by Wilson and Crouch produccon, but also, for esemple, in the manufacture, (19g2).
transport and storest of basardous chemicals or their waste products and the use o(pasticides and herbicides in agriculture as testi6ed by the sitention of US couru l
Establishing staudards to decisions as to whether a risk standard is de nunmus or not (Spangler,1947).
Dua, the notion of de minunis risk decmon behavior in everyday living can sern as a bn4e as to how risk
-t espens and safety regulatore in government Regulatory laterest can establish a hierarducal system of pnorities for achieving a more optiten! and equatable balance in the Among the sigested opphastions of de minuais risk use of societal rumources for risk reduenon in concepu are: tbc setang of regulatory priorities; as a competition with other bens 6cial uses of these same resources to improw the quality o(living. hl. emends e pleasurable activities as odd as the avoidance of harma.
Same of the risks to workers and the D' "" Purpos d subHAing mandar6 d &
I'neral ublic from the nuclear fuel E
taimnus risk a safety regulanon as to remove imagmsenni rids from se mena of debeu no ths cycle might be regarded as de graim.=rgas can be focued on mahng equit**
minimis because the consequences compenscos of the risks, costs, and bene 6ts of
=chnological options (in:luding project opdans such u are small or the probability of 85cility siting > amaum se type (as nu "
significantly larger consequences magmtudes) of consequences may be different for the opdone being compared, it is essential to consider the is IOW full scope of dearable and undesirsble consequences.
232 Projoet Appraisal Dwedre JN1 e-m
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'$ser for as low as reasonably achievable (AL. ARA) ene abanor in a milben (le,10' yr) t seenderances, as a cut es level for souecdve dose apprepnetely be as an af assessmenta; for outer bounds of w 7_H de maimis risk.
Ibe other abe lower some -
assasi as a Seer for does oflow levefweste; as a with individuni risk yesur than ens abamos in a j
presumpdos of uivishty in legal prossedags; to foster thousand per year er espesure adgkt be regarded as admumoustive and regulatory eEimency; and to provide clearly unecespiable. He mides, is4etween anee ve for pubbe " ~
'M including policy would then be the valid anma of debest for risk <mst-is (Devis,19N and 1957). '
bens 6: analyses to be perissened in social dennon.
is a powns recognidon of the denrabihty in malang in deternusing whether risks are asespenble or pubhc
' anaking to bene e de amanus risk standard not.
en values of sammen use that roughly Accordmg to Qarke (1985 sepet authors characterias the levels of hadividual risk that are indmdual does entedh for ve set regarded as edimently meshgible not to merit the level of ammuni radiation risk is held to be of aseitional personal espeeditures to reduce them funber so eseners to the individual at IF' to IF' (Baker er al, (Whippia,1987) Anconhas to Clarke (1985) of the UK 1933; Clarke and Pleshasa,1934; and Mambold, National Radiolopeal Prouccon Board, there is a 19H) widely held view that frw people would comunit their Guidance for the use of value ladesseets in a
)
own resources to reduce an annual risk of doeth of one deternunation of risk is radiados protocuon l
shance in one hundred-tbousand and that evue frwer is pnmded la ICRP No 26 which recommands would take action at a chance of one in a milham per a system of ladi related prosecuan with done i
J year of esposure to a given hasard.
limiestions based on the fouowing pnacaples (ICRP, lt is to be noted that there is an important 1977) bend d
f of t a'
hic this r
w focuses. All risk lewls regarded as insign6 cant (or de mieinus)ibedd by this wry name token be regarded as o 7.,
AaB k tapt u b's a mNy nee mihag ns,. Howewr, bactery 6n.ls certain other awptsole ruks ggi, ggy g g g i
i as to be a:eeptabe whenever the
.sken into a: count ( optuninstion of espe tsd net beneSeial affect.: in a isk-cost-beretit beag i
(RCE) analysis are perceived,to outweigh the espxted
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g' principle is implicit in the concepts presented armte hastanas h ICRP.
his in Figure 1 as reproduced froen an article by Richard A difunt safety whilosophy h spurne related Wilson (1984). De numbers in the left band snargin on protectico vehich is based on tbt pnnciple that risk c(individual deaih were derived from the work of optimiutiers should include senessment of how much r
Lore Brian Finwers, Chaincan of'the Frya' the tot 4! radiation froco a given source would decrease Coenmission on the invironment of the Ueited due to various possible protective measures. Even if the Kingdom. De use of an inte-ted scale / mk reflects ruk of harm to each esposed individual were very the desy'sbility of espressing an 6:recsingly higher small, exposure of a large aanber ofindividuah au'ght standard of safety.
onuse a collessve bares that could perhaps be evoided Awdawiily, the upper sone of Figure I with risk of at r-ahte cost and esort.
individual fatality per year of espesure that is las than As noted by Bemason and LindeU (1985), the management of an instaBatian that releases radioactive substances into the atmosphere may claim that the individual doses at some distance from the rele me de mianus and may 6erefm k meleend.
l these amau doses may cause a siamble couestin dose a'
l wis:b au'ght weu be reduosi at reasonable afort, the
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concept of a societaUy ted, or source 4eeed, de I
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s nummis risk standard desireble to consider accorchng to this view. Both an individual based
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"y approach and a source based (or soewtaUy agregated) e$
approach are to be found in the regulatory plulosophies j l P,,,
of the US Nuclear Raguisery r--iwaa and are
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'i.ciudad in se d.eunion g mis paper.
1
-m-Regulation of radiological rink
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e
. __IbI ne NRC and lu professional staff participate in or
$ % @D take cognisance of the debberedans and reports of the Internadonal t'--maion on Radiological Protection
@'"d
(ICRP) and a number af other organiastions and Figure 1. Probability of death for en Individual por sneeungs reisting to radiological protection. his also year of exposure (ortlerr of magnitueolin includes coordination with the standard-setting terms of scooptable/ unacceptable reek radsological protection activities of the US Ermron-Project Appralaal Decesibre M87 233
i ar---rm apa mental Protecnon Agency.
not me amende d een immenisoonships is -
The Baergy Reorganization Act 6'wq'd ** ",*P,,f,,*,l's,",",,,",g gi,,,,M gives the NRC authority for YP
- "'d kapnance to NRC's hamncal halopment of Standard Setting: in the protection gMpoham andard of ublic health and safety saany P
,u spc6m branc mehnioni posidona. hidsed, the ned for brevity permits of NRC's regulations have been only a imind cowrege d 6e em mhant NRC eSorts guided by the subjective criterion niadog a tu impucii and sapheit um d de mimmis
,iskamice, of 'no undue risk,
)
he Energy Neorganiastion Act d 1974 and the 1
Atomic Ene Act of 1954 have provided only i
spiahtstive en which the NRC must base its the Code of Federn! Regulanons how been principauy pob'en'es rules sogarding its primary responsibilities goded by the subrective enterion of 'no undue r.isk' to for bhc health and safety. For pubuc health and safery:
'% protecting the f '^
t d o e menial bc e (10 CFR Part 50, Appends: M, Section $d) On the basis of the foregoing safety review considerations for mates nuclear power reactors of standard denapn, the "The Commission shan issue such licenses on a Comunieman may issue a heense if there is.
non esclusive basis tc persons applying therefor reasonable assurance that (i) such safety questiens (1) whose proposed ecovisies will serve a useful will be satisfactorily resolved before any of the purpose proporunste to the quantities of special proposed nuclear power rannor(s) are removed from I
nuclear instenal or source material to be utilised, se manufacturing ste and (U) seking into l
(2) who an equipped to observe and who sgree to consideretiot. the a te enterit re.uninad in Part 100 observe such safety standards to p=otect br.alth of 2 chepter, the proposed Mctor(s) can be and to immmize danger to Efe or property as the constructed nud wetend at tite having rammi= ion may by rule miabbsh, and (3) who characuristcs that Isd within the site poremeters i
agru to ar.ke availa' ale to the Coaumst. ion such ptetulated for die design af the routor3) without j
technical ir."ormation nr.d data concming undas nok tothe bedth and safety dthe public.'
activities under such beennes as the camerhaie,o e (10 CFR Part 100, Sect;on 100.10) A.nong other may determine necessary to promote the common factors, the ConunissiQn in determining the defense and security and to protert the healtt, and s,oceptr.bility of a eine for a power or testing noctor safety of the pablic. All such information may be wiU take into account Aspendia A, " Seismic and I
used by the rammasion only for the purposes of Geologic Sitieng Critark for Nuclar Power Plants",
the - =ae defense and suurity and to protect which describes the estare dinvestigations required the besith and safety ef the public."
to obtain the geologic and seismic dets necessary to detennine site maitabiht{ ear pown plant and to provide reasonable Also, Secnan 161b of the Act gives the Commission assursace that a nuc can be authority for standard setung. Additional nlevant and d
a ate thout provisions of the Energy Reorgemaation Act of 1974 Qtruct regarding rwk-cost-beno6t analyas and related NRC regulatary functions are:
o Title III, Section 307(c) requires NRC to inske a ALARA standards clear statement annually of the short-range and long-range goals, priorities, and plans of the Comnussion A innior step in NRC reguistory decision making as they miste to the bene 6:7 costs, and risks of involved rule enahng leading to the adoption of comunercial nuclear power.
ALARA radiation protecdon standards for the design a ne kinds of bene 6ts' the Congress had in mind in and tion of hght water reactors (LWRs)in May pasang this Act are found in Section 2(a) under 1975 'RC,1975). The purpose of this regulation is set "Declaratism o(Purpose":
forth in 10 CFR 5 20.1(c)
Section 2(a) De Congrees hereby declares
"(c) in accordance with recommendations of the i
that the general welfan and the common Federal Radiation Council, approwd by the I
defense and acurity regare adfective action to Premdent, persons engaged in activities under develop, and increase the ediciency and licenses issued by the Nuclear Regulatory I
niiabihty of use of au enerTy sources to meet r=== ion pursuant to the Atoauc Energy Act the needs of present and future generstions, to of 1954, as amended, and the Energy l
increase the productivity of the' national Reorganiassion Act a(1974 should,in addition to economy and strengthen its position in regard complying with the reqarements set forth in this to international trade, to make the Nation self.
part, make ewry reasonable effort to maintain sufEcient in energy, to advance se goals of radiation esposure, and releases of radioactive notonng, protecting, and enhaecing environ.
materials in efDuents to unrestricted areas, as low mental quality, and to assun public health and as is reasonably achievable. He term *as low as safety."
is reasonably achievable" means as low as is However, in the protection of public health and safety, reasonably achievable taking into account the many of NRC's regulations as establised in Title 10 of state of technology, and the economics of 234 Project Appealeal Domii6rr 1987
1 Araumervidesage j
haprovement b reladon t) bene 613 to the public we beben 6at we een accept the reaservatig henhh and enfety, and e bar eacetal and socio-value sfl1000 per toal bedy persongen for these esameauc coanderations and in relation to the aosdene6t evalatiser. $ines we eenhas that the
]
usikestion of steadc energy in the pubhc uhamstely noospied seine may well grow to be i
interest."
less then this, we abound leave lt open to demonoustice in bdividual esses that a lower he AMRA concept. of me, is em synonymus
$gure abound be used if the oppheast chosess to I
with the de mamms risk enecept most the risk <ost-and om ade em dammuusdos."
bene 8: analysis used in establi en acceptable level j
of risk may arrive at a risk s that,in some cases.
The value of $1000 iper persooguen evened is roughly asund be greater &an an insagm6 cant (or de =Immia) equal to $7.4 million per beauty everted using a retio level of ask. Yet, as illustrated in Figun 1. the use of er 135 htalities per millies person rees. He laner ALARA type procedures withis the some of risk-cost-ratio amployed in a renset Envireassental Impact bene 6: analysis souid also provide a basis for Stateneet (m) by the stas (NRC,1984)is somewhat establishing an e it mandard of de adaunis risk above the a%t of the reases of values for healities brysed which no analysis of costs and beno6ts adlien penoegens maimated by the 1980 BEDt4D ased be employed to determine the acceptahdity of risk.
(67169) and the 1977 UN5CEAR Report (75 The regulation involved both quantitative design 17 r===h is substantiaUy kWier then the eqw,by m, the ALARA value establiebed temporarily ebiestives and an interim aumeneal safety esst tradeos criterion as a guide to the desirobility or the ty undesushdity of further empenditures to increase the value of $250,000 to $$00,000 per biality owned
.Sevel of radiological protection. The design obiectives referenced by other agencies ki risk reduction decmons beorporated in the new rule (10 CFR 50, /gpendia I)
(EP/,1976). With reference to Figure 1, & equity include:
sslue - in this case, couenstively chosen - provides e 1. unit the amount of rsdioactivity nicased in liquid
[u W'
i r
sRlueats fmm era lighs seter cocied pown teacior Zone (A),is smeptable to tevels that would ten tue ancutJ esposure to an Regarding the subject d de innimis nsk,if one uses kuhridual in en unrestr,cted area to not more than se ruio d 135 haune pr millmo pe son mm, em i
three milkrems for the wnole body and not enore de h tm rid W E W I d$ mne d enn 10 mininas to any agan, whok body does to se individuel in an unrwincied e 1.1: sit releases d redioactivity in gaseous eSluents arts from gasmus eBauents is computed at a probability 6am any light water cooled wer ructor to keep of 6.7 a 10' fatality pr;r year of esposre, w shghtly annual espores e an mdin al in an unrestwie' less thou one chance in a minion for pnosiure fatality.
ares to a usar:r.um of 6ve millirems to the w".nole WM a meum e d 3 anm imm liquid body, and not more than 15 nulhrems to the skin.
eQuenu m an individd h a unraticud wu in se e Limit releases ce tedioactive iodine and other vi d a nelew pim h compuW u radioactivity froin uny light water cpoled power yielding a WWy W four che in m miE;on d reactor to keep annual esposures to the thyttnd of an pnetun h@y pr yew despinn.
individual in an unrestricted area to no more than 15 in eiser evat, be individu! rid d fmuty b 8"IU'""
l within the range of comunon use values sugested above Dunng the rule making proceeding for AppendLa I to as quahfying as de matais risk from hazards falhng 10 CF1L Part 50, evidence was received relating to the below these upper bounds. On the other band, the estabushment of useful enteria for deciding the standard lianinns an individual in the general a
riateness of reducing esposures to se population popuistion to 500 mreas of annual esposun fmm au even
. Contributions to the record wen in terms sources of radiation escept natural background and of cosu of funber measures compared to the bene 6ts of medical sources (see above) would yield a probability of any reduction schieved. These ranged from $10 to 8980 premature fatality of 6.7 chances in 100,000 yearof for whole body esposure to a unit of collective esposure. This value would not be as de (population) dose, the person-nm. (The penon tem is a summis sccd ' to most usages of at term for l
snessure of esposure to radiation of large groups of individual risk. In this event, it would be desirsble to I
le, for esample,100 people each being esposed to sotk ways of mita'geting se risk using a esfety-cost A rem, or 1,000 people each being esposed to 0.001 tradeof value such as the $1000 per person rem in rem.)
NRC's ALARA concept.
The NRC standards for occupational redistion dose in resencted areas an much less sinngent than for i
Worth of dose reduction f
in su decision, the e-in said:
The body dose limit for occupa-fbe recad, in our view, do not pmvide an tional workers is ten times the adequaie n= sis io choose speci6c deller value for maximum for an ladividual in the the worth of decreasin We propose, therefors,g the populeuon dose...
StDerRI population And Subst&Dtially et the earliest practicable date to conduct a rule making hearing to establie above what might be regarded as a appropnate monetary values for the worth of d8 MIRIMI8I8Y8I reduction of radiation doses to the population...
Meanwhile, and purely as an intenm measure, Prokat Apprelaal Dawm6er 1987 235 4
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indivuhnals in mess of uanstricted pihbc acessa. For it should be nosed that the proposed estetvalue for 6 esseple, in 10 CPR $ N.101a the whole body dose minuas risk of 1 anon in a year to in6viduals in the limit sur E-a _ - --' merkers is a massman of 1.25 amiculades of couestive populados does is reegbly soms in any see guarter and any be inamesed to equivalent to a amens heality row (set is, prematun 1
3 reus per guener under ese6tions speeded, er a estal death) af about 1.4 chances in ten milhos per reactor of 12 reos per year.This is ten times the naammum for year er operation. This is about a facter of erven lower an iridividual In the general population and is also than the 10 per r level age,ted in Piswe 1.
autenantiauy above what might te regarded as a de However, the eats t of one numericef cutes manuais lent, especiauy if such a dose were repeated level as a de seinimis (or i==rasAcant) gjak (or a tennin l
year aner year.
class or classes of regulatory demaions does not, in pnnapia, sessa that asse hisbar (et lower) level of risk might also eene to be reganled as isoisadeant for Pernaissible doses othe einesse deseman.
Por esemple, the c==='=ia= bas not yet addreened NRC's cunent regulations on
'ble doses, levels, the question as to wbst is the highest risk number it and eencontrations of radios een Aret pubhabad would regard as de seinimis for any class of regulatory in Pan 20 of 10 CPR h January 29,1957 (22 PR $48) decisie in tory proteeden. Nor has an A proposed avienon of Part 20 oovinas numerous in deve as yet that would aspecu of NRC's Standards for Protecuan Against the use t
levels for 6 forest Radiation" was forwarded to the Commesion on April classes of regulatory dommon and, indeed, whecer an 22, 1985 for approval for issuance as a proposal for aggregate sonetal itandard of de misanas rbk would be pubhc comuneet (NRC,1985) One section of this profemble to as individun! perspecuve of de amanus proposed revision deals esplicitly with establiAing a risk or vice wrea (Scanger,1987).
policy of Js mismus risk (pp. 4 9 of the Couanission Many considerations snight afect chaices of pper)-
philosophies and eutes levcis, racluding whetes the l
risk is from ronnae traimions or estastrophic accidents.,
'De Mlaimis and whether the uncertamty surrounding We estimates l
The need has long bnn recognised for a de of the risks is broad or not. Obviously, future rdvances mirunis feature ir the standoms for protectice in ae=ade knowledge that reduce such uncenanoty assest indstion in order to avoid emendag could beve r. bearir.g oo the tuted level below wtw.h a regulatory sedons be wl.at is needed to risk is reganied as de amaims.
f adequately protect lic beslth. However, the present Pan 20 provides seiner a de mirdens new! for the most esposed ir4vidual member of Integrated philosophy
+
I the public, nor a level for the eutc6'of :ollective done amiculations. The lack of these levels in la developing an integrated philosophy regardag the i
radiation protection sandards has resulted in introduction of de anninus nok concepts, attention I
unwarranted esponditures of resources for needs to be directed to an appropriate interfacmg of t
incremental risks which an considered triSes in NRC's rules with the radiological protection rules of comparison to the risks which individuals are the EPA (40 CFR Part 190) as established in 10 CFR subjected ta daUy as part of normal living habiu Pan 20.106(g) lumnases engaged a,6w nguimmanu d "In ad& don m o l
T pplementary laformation of the uranium fuel cycle uans proposed nvision of Part 20 docusses the subject to the provisions of 40 CFR an 190, possibility of a provision which would denne a de Ennreamental Radieuon Protection Standard snininus source of radiation as one which would for Nuclear Power Operations, abau comply with bc unkkely to cause any individual to receive a 888 P""'
does in escess of 0.001 reen in a year... This concept of de raiamus has reesived favorable in 1985, NRC emn-i n r James Aaselstine raised a endorsement freen both the technical and legal quesmon regarding the relaticeship between se limiu standpotata. However, eencerns how been rained proposed in the Pan 20 rension (SECY 45147) and that such a provision could be abused by EPA's Uranium Puel Cycle Standard (40 CPR Part hemason, in par:icular with respect to radioactive 190). The stas roepended that the two standards are weets a ' tions, and that it would pennit gin'te diferent in their derivation and ki the functions unoon d use d radionetive matenal in they serve (Minogus, 1985). Although both are consumer products. The avision introduces the redsstion protection sandards, one (Part 20) mistes to menospt of de amunis values but only a limitation of health risk. The other (40 CPR Part 190) limited application of the concept allowag relates to se appbcation 'of the ALARA principle licaneses to use a cutos value 1 stem involving an acessement of the cost and efectiwness of (0.0lmSv)in a year to individuals in calculations esposure lianiting technology for specs 6c types of fuel af couectiw dose.
cycle facilities.
Geeral acceptance of this concept would, it has been the longstanding preence of the NRC bowever, make possible its broader consideration and other organisations associated with radiation health in addressing '
t regulatory quesuons, such protection to implement radiation protection by setting approved Federal guidance anCor on la_ pren'den upper limits of esposun based on as defams lo evel radioactive waste. Ceaunent r and NCRf' on this issue is speci6cally requested in the notice d proposed rulemakmg "
recomtnendations. But then actual esposures are kept 236 Pveleet Appraisal Davie ##7 1.
Ar aumeir sud.emips c low as is reassembly achiemble (or ALARA) below
&cilhisa, li$t water reaceers, and feel theos limits. his approach ses est innb b the Pedent soprocenias... home tenhasent analyses psevide Radmisen Proteriian Omdamos issued in 1960:
assammanu af the bestab efocu amme eb "1.18 Ra&asion Protectien Guide (RPG) is the g a sence ash e
me.nnes due which abound not be emedad venous aparemens of th,e Afsl sysis.
wi em arou es.sid no. d
- reason er ed,c,,,m, ad,,,, e em,,,6,,v
,,6,,o doing so; mry eSen abound be made to sedues releases dthese eSmeets, enomge 6e mainmaam d 9. nm 6pm as la ad6nen to these analysen, there is tr below this guide as praedcable somsederable other lafeemation a planned i
his inner terminology has evolved Aum "as low as releases hem these types af. dees of the NRC hellines availabk.
practiemble (ALAP)" to "as low as is ruseeeably his inchades the generic An esbievable (ALARA)". he sembinaties of essiosure esmeersums the procesabihty of eElment eestrais limiu and lower ALARA esposwes is today en inherest for light.wstergooled rescara, estaaelve 8adags hetm of na radiation pressenen af the utilities, the NRC, and the AEC resected he huit in abe proposed Part for espoem af by evironmental sentemess for a v,enery of the general public is 0.5 rum ($00 mAhren) per yest. It individus! bcGinen, and Anally, abe resolu of a limbs the sus: ef the deses tem all seurons of re&asien numbwr of detailed evissemanal surwys escept background re&ation and medical espesum to a eenducted by the EPA of typical operating patient. His limit derives freen the ensung Pederal helhaise."
Radiation Guidance sad is soneistent with the Agens I to 10 CPR Part $0 sootnina design recomenendations of both the Neuomal Counal en i
uly;eenvm de$ning ALARA sd5uent nienses and, Radenon Protecnons ud Menamtessu qCRP) anri although it contairs ac:ica levds,it does not eestain the International t'a==- en P ;= Protection oost imiu in the usual seine. EPA's # CFR Part 190 (I%
aloes dance dos: Emiu for nortaal operence of uranium his, limit and correspon&ng oergevocal pressenen m cona4, health 4ased halts 5" fuel cycle facilities, but these am not rigid, absolute cred upper bounds to limits, as the standard allows NRC to punt a variera l
acctpable doess and should be coenpbed with to escoed these limits in eness where the need for regardless of cost. The reference level of 0.1 rem (100 scounued operenom has bem denausmed, und mulkrem) per, year a the propoord Part 20 dennes a
,,,,,,.nw muon k king take to nduce h esposuru.
hesswe acnon level arvi is consisunt with De Appetula 1 denen obiectives wk'.4 preended
' the insumace d EPA's # CPR 190() en expressed l
recommendations in ICRP Publicanon No.26 and with l
desP. recommendetioes oder consideranos by the sepastely for each reactor en a site and for individual l
NCRP.
espusure pathways (achk sness, redamodanes and l
It deSnes e,kal c(radianon Som a spr.i6c source.
paraculate, and hquid eSuents) De EPA standards i
If 2 hait a encorded, the bcensee must conduct a 40 CFR Part 190 analy to the atire eiu and to se further invesuganons to determine that the combined mal dau esposure pa% ways.
esposure to individuals, includag the radianon dose The een &serence are uken into account, se -
from the source in quesuon, does not exceed 500 two sundards are nheiwi compatible. his is not nalbrem per year. In addicen, under the proposed Part surpnang since the EPA upon the same AEC 20, each heensee would be required to apply ALARA studies and the operating esperience used by NRC to prompia.
develop Appendia 1. It abound be noted that the EPA 40 CFR 190 standard is incorporated into the present and AcceptaW risk ProPed Part 20 by rdauws.
he health risk bened levels in the proposed Pett 20 Cost efecthstaeas i
reDect a judgment of the level of risk which would be l
acceptable in comparison with other riaks. In contrasi.
EPA's Ursnium Puel Cycle Standard (# CFR Part Control d redumedve misanes and wasu processing imhnology for rouwn ud o6er fuel cyck fuihtin m 190) and the reactor design obpectives in Appen&s,I to wwy ain essenve and eis resulu in wwy low ALARA 10 CFR Part 50 represent,etandards set on the bass of the quantiSed deterannsoon of what is as low as is levels. This is why it is appropnote that the EPA #
reasonably achieveabis, or ALARA.
CFR Part 190 standards (referenced in Part 20) and the Dese Imts am punarily technology based. That is, kwh umined by e==Faa~ with Appendia 1 am the are based en analyas of technological capabilities dy lower then the proposed Part 30 timiu and macekvda costs and et misted mducuan in ofeite populanen However, the EPA shaderds in 40 CFR Part 190 doses and potential health efecm; they are based on what is both technicaDy and economicaUy achievable be opense typ= d fue eyck failina. he amis of NRC is allowed to exceed dose
=hieving the= nandards m imPucit in their dewlop-amat. As EPA stated in the environmental statement limits where the need for continued rayms 40 CFR Pvt 190 (EPA,1976, pp. 5 6):
operation has been demonstrated "N aviron==ta! *cu orplanned reka.cs d and corrective action is being radiosenve effluents from components of this cycle have been analysed in detail by the EPA in taken to reduce the esposures a series of technical reports covering fuel supply Protest Appressal Dsoswear ##7 II
b ***i'* ****
ALARA type levels sely for arealum fuel cycle evaluados of NRC pebey as doesumismaning audser and asemat senem1ly be used as an indisties hanides (NRC,1978) In addiese se essamereal ef what is ALARA for other elssess d NRC-hcensed nucient power and research reacters, other ammiser bel N
hetities he impenant esdoenen is sat the theit for cycle heilities included in the d---% plan 1
membere af se pubhc in the pnposed Pan 20 theiin en uranium mins, Urs esaverses e, fuel se sum af the deems from au seuress escept hbrisasion plants, and fuel is. Also, a sad ar+cial redamen. In osairest, the EPA study was initiated of the more them liesseed is an ALAkA.hased standard for uranium fuel factices that udliar byproduct and source materials eycle heilities and lifit water reactore.
(such as.f-
- apphonneas) which supresent e l
a =MaWa(i risk is, af oowes, Just the oppente of an upper boundary between neceptable rather limited f--
and--
handle small amounts of r=da=g problem because they
==aapa using ALARA precedwes for deteradaias a lower The nuclear Said is reaching the dayee of maturity bound of de minimis risk below which cost-bene 6t-that requuss inenased utsomos to the pro i
analysis and brther risk redeemos is not regered. De recreussat or d
=g af hadlities. hun, s per ore de minisms risk esacept escussed above in the nuclear plaats and equepasant wiu pressetly be etering proposed svises to Part a does not serw this purpose the tenminal pened of their mastul hves. Since most of but rather the more lamited sinactiw of estabhalung a thsee heilities how base involved in handlag cutes value of 1 mrom per year to individuals in redsonctive asianals, nephams in policy development is enlauledag seueceive does fees a given touros,
- pon the safety of ee '
- process, u
On Jamaaery 9,1904 e maddad wreios d se headling and espose! of rendues.
~
propseed NRC revision to 10 CFR Pan 20 was As sated in Angulatory Guide 1.M. '-
published for public e arment in the Fedevil registar Misroatives pressotly acospiteac to the stas includi
($2 FR 1092). he new revison dropped the coacwpt of mothbalhas, entombasst, prompt removaudamanthag, applying a de minimis risk standard to the teost er e combination of any of the three (AEC,1974).
esposed individual, but retained the concept of applying Prmeetive storage or :n6&balhng involms mmoval of l
a de aminus risk esos standant of 0.001 rum au fuel and source mastrist, the disposal of au liquid (or 1 mram) per year for coliscove dose calculations and solid weste and places the ineihty b a state of with the following suplanation:
protective stemge.
I Ensembasst requims sindar treatment and,
.,A more limited appbcede of the de mimmis d6damu, se Mw wh ad we se d (
a miscrm)ed inlete au %
a mespa has been
. Fouowing sunaider-anon oflower en hagber nwnbers, a value of decay to unrestncied levels. Ammoval and &sean? lag 0
no iw a et d require that all re&oacun struceres.==p==ats and su t
e si o be sonestive doess to populsdans. Apphcation of the I
use kwl a couectin de mumsta would, mang other things,liant both the eine of la each heenseg enee the susmust be satis 6ed that l
the populanon and the time owr which coUective a imible h'=ia==hisii'ig me&M nisu aM em W does would need to be considered in evaluating spPucant penm(or has se capabihty 2 ymsde se acdvities assocated with the rensane of radioactive
]
,,g,,,;,, of a reactor operstico, h oppheno of the de vainimis may be m
Hae by concept could have a substantial inouence on the pm8m y
g de w evaladens d coo &does wbm wry large re8BAMung in 88mPoesats to decay. Di.s type oflicense numbers of people are subjected to very low dose penmis, ymmon af ee &cGhy and smauung redsoncun materials but contanuss to unpose t
[ la dose tsu7uld f*4mrom88ts UPon the bosasse to ensure that there is e
rule
}
(0.0
- Pee
- gaga *g=,. 6;,<Pt Cll"ma"e"e'""." '."r.4'E ""'adl2ll.' "
d i
.o sups at or m'
De hamme unins mapausble (w se afe 0**
,g,"g { ",nad ao e
Populeuco are evaluated, the acceptabdity of the mi al ad 8ppupnau plat associated potential risks can also be compared to the mim of potential mks exponeocad by the
[M,,, ",,*"
g, enni g
sesun &m th pubhc anse populan,on over the same ame interval.
g 8ppbca d h,",",i m y,,g Simee residual quantities of source materials (and
'" de s
e
&m8 to my lar59 amben of penons, the especally of surface======= of reeoouclides) are e(te gate usan in the daa==a=== alternatives for are routies$yIubjected for nuclar facahnen, se conosptfa risk wans quiu mabuslung a &
fro na ural aname mandant af amp =
bachyound radiation) is also very substantial and
- I Proporuanal to the number of persons considered?
g,t been ab uncover in NRC's denlopment of regulatory pohcies is p%a,,b**$ $g Q3,% *
- d Facility decomunission
,,g g In December,1978 a repon (NUREG.04M, Rev 1) was
'The principal issues to be addremed in issued by the NRC that described a plan for re.
developing or reevaluating decomaussioning l
238 Pro)est Appraisal Doori,ibre 1987 1
i.,
~,, _ ---
ar.d r.m
' y am 6e acompobility of sadioactive residue I
(i.e. -de emaisu'semia) and er aanomal One would be hard-put to 7pouey Ys,Eenseemeeem N "'
M"'
8""**
- detersnine the quantitadve health
< svece l amas direci effects lanplications of the necept-
"d "**1" '""** 6 *priempc mar l' "7 8
7 ea able surface containiantion levels haportant.
However, this report did not propsee any gunstintiw a
ta debution de dose that 9"'8088I"
{mpuestian esse
,q t (
an is, low dose equivalent in risk to other activisies that are punerally sosepted without eeneers) also Y
),
meant that a proposed level of residual e here en a legion af 4iferent mians of alpha, beta, seheactivity is soil - and presumably also for omfaae roya, and so es, and their es sostandantaos of heility hardware - was certain to be that sould produce the same re&perse energy ance level as in Jeopardy, menswed la te number af disla pre minuts, (One Curie is equal to 3.7a1p'sintepe-0 di tiens per esosed. De depth of penetration in hamen iissues and)agnus is a hacena of me type UdBeatty of quantiScation radiation and ther assoc 1sted mergy levels; An appew:laties of thw fairMes la enabish'ng im o Dere are a vmiety of earlielopcal pathways by acceptable emndard of de munimis risk for auch which bumen empene cou'd ess4: in harm (for l
purpress is inherent in the it.ciplesities and modeling instance, dermal saatact or inhalaties with fbsidw i
l uncerta aties that satswd into the establishment in dust or particulates, inhalation of gaseous i
1974 of the numerical accep.able marface contammation redi:,ta:lidas, ingestma of contanunated food and l
levels shown in Table I (Reg G. aide 1.86, page $).
dnnkmg water, and othem);
i nose standards am still utihard today for revieweg a e he variable population des,eities at diferent fr.cihty dammantling plan and termunamon of a heense.
distances from ine surface costanunents and their hus, if asid ail ra& ados levels do not escoed the daughter re&amuchdas that could become airborne i
l values in Table 1 the a===aa may termannie the or womrborne and 6e unpredictability of Assum r
beenee, If these levels are escended, the licensee retains levels of burman activities; and the possesson caly license under which the daemantling e De scienti5c uncensinties in dose response activities have been conducted er, as an alternative, modeling or the use of t__M# data to infer may make application to the State (if an Agrooment cancer atalities 8mm given dose lewis for diferet State) for a byproduct asterials license, types of radiation, especially for low doses (Crump, j
Among the many difEculties in determining the 1980; NAS,1980; and White,1984)
Table 1. Acceptable surtees contamination levels Nuclide*
Average" Maximum *d Removable' '
8 16,000 dpm s/100 cm' 1,000 demt/100 cm' l
U nat, U 236, U 238, and 6,000 dpm s/100 cm associated decay products Transuran6ca, Ra 226 Ra 228, 100 dpm/100 cm' 300 dom /100 cm' 20 dpm/100 cm' Th 230, Th 228, Pa 231.
Ac 227,1 125,1 129 Th net.Th 232, St 90, Ra 223. 1,000 dom /100 cm' 3,000 dpm/100 cm' 200 dom /100 cm' Ra 224, U 232,1 126,1 131, 1 133 Seta gamma emitters 6,000 dpm$ Y /100 cm' 16,000 dom $.7/100 cm'1,000 dpm$-7/100 cm' (nuclidos with decay modes other than alpha emission or spontaneous fission) except Sr go and others noted above Source:USAEC Regulatory Guscit 86 (AEC,1974).
Notes:
- Where surface contamination by both alpha and beta gamma omitting nuclides exists, the limits established for alpha and beta gamma omitting nuclides should apply independently.
- An used in this table, dom (disintegrations per minute) means the rate of emission by radioactive material j
as determined by correcting the counts per minute observed by an appropr6ste detootor f or background, officiency, and geometric factors associated with the instrumentation, i
l
' Measurements of everage contaminant should not be averaged over more than 1 aguare meter. For objects of less surface area, the average should be derived for each such object.
8 8 The maximum contamination level applies to an stoa of not more then 100 cm,
' The amount of removable radioactive matchef per 100 cm' of surface area should be determined by wiping that area with dry filter or sof t absorbent paper, applying moderate pressure, and assesaing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.When removable contamination on objects of less surf ace area is determined, the pertinent levels should te reduced proportionally and the entire surface should be wiped.
l l
Prefect Appealeal Demisiber JN7 2H 1
as miemb em maaps 1,
j 06ses te aneure of 6sse venables, one would be hard.
O If the sundard b esieveble se a east efecen basis l
put se impose the bonitt edecs
.- " to the for site alsass, then k is assspiable' sesspenMe seface oestammation levels if Tabf 1. For a ne standard should be missed to risk asussement.
sedlesetive hilout som weapons testas led to e he standard should be est by EPA.
a enlue of about 5 mean per year of espesure in e A renseeable massmune dose este that is nationauy the early 1 Mon, but has dech.oed substannauy ance accepted abound be embhabad with the States' right t
them. As assed abow in the abacussion of 10 CFR Part a set sencier espeews levels en a 7 4 -~ : basis.
30 ssenderda,5 arem per year of whole body dose is e The poup did not how enough infonandon to reach lc.
roughly eg.sivalent to a cancer fatality rate of 6.7:10" ds6midve conclua6ana, but listed eencerns that l
deaths per year of esposure, federal espens abound study:
Assenlag so common use interpretations of risk to the individal,5 arte per year
- es pmblem of M including any 3
he regarded as de munions won it not for the 8"8" ** ** EI'
- I"850'Y-unresolved problem of scientinc uncertainty. Whnber
- the enforceability because so close to bachyound.
l the asuet of osataminated surfaces from heility
- the eine and type d the populadoo which would be a5 scud.
L d=*a====== lag we,uld reach this level of redsonctive suposure to large regions of the country at the
- the standard should esCect the duration of the accepteble levels of Table 1 is an unresolwd question.
esposure.
l Also, the senag of accepuble residual levels of
- the relation of the mamamm dose este to a insalth coataminunon regares a deciaise on ubst credit can be efect.
taka, and for how long, for isolatag the contaminadon e la detersuning a more reasonable number for tise, i
by direct custody (guards, fences, and no on), or by opuens such as a percentage of backgrow, a sliding coa 6 ming media occh as paint, concrete, soil cover). It percentage (10 CFR 50, App !), w use of levels I
is an underlying as non that NRC will actively presently set for esposun in opersting reactors seek to prevent a ration of sites where the abound be invesugsted.
l rar_ains d nuclear ity operations stand guarded or Fouowing the State-level workshops, a public meedag
- M was held in Weabington, DC in accordance with the i
. At the same time, the NRC recognizes that see p.g,,s. Raguser souce of August 25,1975 (43 FR stes, such as w,ior power plants, an taniquely se,ted to 38025). Asuoduce included repreenutives # h this purpost for the foreseeable future, and it any not nuclear industry, pub'Je hieret groups, pwm be reasonable for our society to espend substantial and the sutes. As reported in NUREG 04M resounss and inenese doses to the workers,to v 1), one of the conclusions was (NRC,1978, page decoaumsaico an old nuclear facility site to a pnsune 35) condition, if a new nuclear facility (or other generating I
plant)is to be built there.
"In regard to residual radioactivity levels ('de ne above examples focus on the level ofindividual nunums' values)it was commented that the dose risk associated with only one pathway of radiological values of1 to 25 mrom, as used as an IUustrative esposure, ignoring other pathways from recycling example in the NUREG wports presented, were l
contanunated materials, and so on. Dus, the quesu'oa too low and impractical because of didiculty in of the aggregative individual or societal risk from measuremanu at these low levels... De nunums multiple pathways has not been esplored in this levels are those levels of radioactive contamin-adoo which an so low that the site or object so contest.
contaminated may be released without further concern or restnction - taken from the Latin: de State workabops misses esa swer lez (the law does not deal with trifiss)."
la *"ium: tion *ith ** d"*3*P*at of a pim for n.
As pnviously noted, the acceptance mutace commmin.
i evaluanon of NRC pobcy a d=ea=====aa'at nuclear ation levels stated in Table 1 currently roman the faciliden, a saber d mate workshops wm held in appbcable NRC aumarical standards for facility j
1978,,plus - others esce them. W the a.,
...ta=iar However, the NRC is avvaluating detersunation of a level of individual risk a the gg, 4,a==ianianlag pob'ey, a process that began with camon-use mage of de tenums risk, thus worhebop' the properation in 1981 of the Draft Generic
)
um asked to address the foDowing specine question Environmental Impact Statement (GEIS) on (NRC,1978, p. F 11) is a masunum dose rate of
- De Dreh GRIS dealt with a wide scope of nuclear r-
' of Nuclear Facilises (NUREG 0586).
I nfom/yr to any individual aAer cleanup an ac basis for mis release? What other bas,s you fuel cycle facihties but escluded from consideration for i
recommend?
reguladen se'-- -' t d N lud he prevaihng view was that an acceptable and low level wmu pounds, deep geologic high kwl nasonabk standard must be set, he redonale for weste bunal, and ureman aiu and miU tadings which l
choceng the standard must be well docenested.
m being canadered in separete rule makms activities, Specinc painu discussed were as fouows:
and decoaumanioning of uranian mines which are not o his standard is unrealistic (4 groups).
under NRC lunadmion.
e A range is more appropnate: minimum I mrem to P "#a"'"""datiW
- ere made as to regulato y mammum 5 mrem (2 groups) decomaussioning partsw!us including such aspects as e DLiferent dose rates abound be set for diferent types appropnate initial planung requirements prior to of facilitica; these should be set on a site by site comaussioning, 6nal planmng requirements prior to basis.
sernunation of facility operations, residual radioactivity 240 pr.)est Appraisal Dareder 1987 l
i I
- _ -.. -. - - - -.. -. - - -. - -. - ~ -. - -. - - -.. - --- - - - - - - - -.
er asWe6 edd meses
.c level for arveseisted assues, and asmseems af Amdag nuclear $seDides safely tem servise and sedue goddual der W ressectivity D a level that seisase of she touperty for amesmissed see urudanden efilsanas.
rer this the term basisar hellidn'is used to Roaldeal endienstivity levels referto
- site, and essesses, and equipment i
amedsted whh any-besmead eseldry.
to the DruA GEIS, an inspansat and To reisess pnporty tr _-M use, a da-h issue is the problems of determining permissible level er sumidual retsassider must be asceptable remdual redssectivity levels regered br-establiebed. These levels are not proposed in this ruis, seisaar af property for unrestricted use. It is the but are being developed in a separate ndsmaking
'ty er the Envirassmental Protection y
acusa. In the past, limits have been provided as A) es estab' mb such a senadsed which was guidasse in such desimmaans as Regulassry Oulde 1.06, a
enJune 18, 1986 m en Advance Nedos of and how somedases base determined en a ense by ense i
a-_'-*--
es its&ames Pressedan Criteria for basis.
Osammy el land and PecGities eenmannsted with No mestien er de minimis essespa is made he Ramdual Raessedse Materials" ($1 FR 22364) the propseed rulesmalmag for Adlity I
Discuameos have been held wkh the EPA about eritana. However, the plasmas requirements I
preliminary guldsmee br NRC in estabhalung me essaidored esens of that the
)
l~
to whieb are smalmstant with eventual EPA i---'
Q wiD he cerned eut in wish '
. Due to the veristy of 4dlity types and Part 30 and y th:t deems wiD be bapt as low as levolved, it is not femm'Ide to set a single reassembly.
le.
.does limit that would be valid under an osadideas br J
aD fedlities. It is ascemary to assess the radioiopcal 1
impact in serens 6( the radionuchdas and pathways Notes tavolved and the costs and bens 4ts which result.
i Rased on then t-i-etions, on dancuences with
- 1. noeutetory esamion meidnp voiet#w to the *m6nwa.
the EPA, and on considerations that the level of eten of eenew :o we er pec,pertw,' or the evoiannoe or residual rwhosctivity estaned most be safe and uneue nom imps 6ostey invohee oost eeneseersione comestaat with easting gedance and be asesurable unthout wmon nek would be eressess to the seru sovei ey i
and cost ediactive, the hilowing resuha were unmerrenwr> esponenurse en 'whaw of esimy tearm es, determined. Firedy, a residual radioactivity level for containment earvotures with too ft thick messa, penanting release of a nuclear facility for unsetncted populanon eassueen sona W hunemes W seuem miles, essene of standby desel generatore for musiliary use,shoukt be ALARA. Guidance in establialung such a e,,,,,,,,,,,,,,, _,,,,,,,,,,,,,n,,,,,,y 3,,
haiting lent is best aupressed in terms of a value amo, e memorandum try NRC's Office of General which bounds the dose for the maiority of facilities Counsel on the defwtion of 'Ameouem Protecten of discussed in this report. This value is deternuried to be the Hesten and safety of the puelic-(sionwit,1eret 10 area /yr whole body dose equivalent, but could be
- 2. The arm 'eevey value is uses fw the oeferroest lower for spea6c facihties. '!)e 10 mrenvyr limit is tradeWI orttenon to avoid the undesirable connotetson chosen recogmanag that it may be unpractical and of puttine a price en human we which, eher au, le unneessanry la ease esses to meet a 5 mreavyr limit 8'toenut 71 e issue of sovity is et stehe, however, since seendered in prevmus abacusecas with EPA. This is a pokey that leeds to ernster esponetures por me because o
- d
- "8 l
deuctabdh.f cost-4 sos 6: canaderations and problems in opportunmes for sevene owe is en ineouitsbee y, samphng, ador mgsom patterns.
oommitment of society's resourose that otherwies could Discusson with EPA indicated that the 10 ersavyr how been used to me a e=Ww number W Wet limiting value would not be considered unreasonable. In au cases, a dose limit above 1 areuvyr wouki regen justi6 cation. For a few sivustions, it is espected that References residual liasits wiD be outside the bounds of the 1 to i
10 erenvyr range. For these spenal situations, emee by.
AEC, "remineuen of eseretene nooneos ter nuaient sees analysis in wres af cost and boos 6: efectiveness
'***s" Reguietary Guise 1.as, us Atomic Energy C********
wiD be required to establish apprepnate limiting newis"a R E saker. W s'8""* i'7' The second result was that for impl=== ration of Cool and W A MWs, "NRC draft revtsien residual re&oactivity level, the dose value selected must fe,",is 3$"[sa.
7 be coewried to e contaminated material concentration D teninson and a Linden, "easse and trenes in er acevity for lastrument snessurabdity. Such seest.on protection comoy", seminer en faserrace eseverson is door through the use of modeling and Questione in Nuoter Noelth ensf safety, eponsored by depends en what re&conclide as present and how the OECD Nucteer anorgy Aeoney, Pens. April 161a, they result in individual re&oactivity esposum.
1944.
Renhetic esposure conditions abound be used in such L sickwet, Jr, *Aeoovete protection of the health and modehag, recogmang, for annaple, the dwellag utmy of we punhc", Memomneum to we Commismon-accupancy is less than full time, that self stusldag is an
e from the NRC Office of General Counsel. October R h",,,,,and A Fiesehmen., 'impA sth Co m' aportant esposure-reducing factor, and that weathenng The estabilehment of ee resuces resuspenmon of the contaminated snaterials.
mini On February 11,1985, the NRC published for pubb,e serun (May 1964).
osament a yd rule, **Thea==ianiaamt Criteria R H Clarke, "Resological protection especte of for Nuclear reedities" (50 FR 5600). Decommissiomog esemption levels in the nucieer fuet cycle *, seminar on as ds6aed in this proposed rule speans to regnove interrace Ovestione in Nuclear Hearth ena Safety, Protest Appealeal Doesn6er 1981 241
- - - - ~ -~
M eenspr sponsored By the OECD Nuclent Snorgy Agoney, Pont IWeefoe AsesAfg 8pom Aderen 34 #970 eenigent, Thee e
Apre1618,1988.
f( 8 Gruma "Stestatteel esseets c2 lineer ost speletion'.
.tese sedend and Nuneser Carism, Unit 1 NUREG4083, Supelement No 1.Osleber 1984,
&S.
~'
at C R Richmond,7 J Welsh, and E D CZ.1; NRC, Proceaed vovielen of 10 CFR
- 30. Stendesee tednerek Neefth Ade4 Analpede (Getiinburg, TN, Ostaber ter Prolessen Against Reestion' *. SECY45147 Port 1, 1980p chapter 29, April 28,1988.
J P Devle, 'The se minimie seguistory out off concepts *,
M S Spengler, "The sole of interseeisi6nery onelysis in feelemony tolere the AsMeery Committee on Reactor ensping the gap hohieen the technisel en6 human Selegueste. US Nuoleer Reguietory Commission, sidee of Nek emeteement*, Alet Anefpedt volume 2, Petruary 9,1944,83 pages.
number 2,1g82, pages 101 114.
J P Devis, 'The loselbility of estabitehing a 'ee minimse' W D Spengter. 'A enseus of methode in the quantifice-level of redetion eene and a reguistory out off poHey for tion of fiele, aeste end tienehte in the escetal choice of nuaiest requieten", in Chrte Whippie to$tork De energy optione". Annede et Nuesser aneryy, volume 10, testinde Asea (New York, Pennom Proen fortheeming number S/4,1988, pages 119141.
1947).
M Douples, Adsk Accepeebetr Aeoorpag 80 the Soedet M S Spengler, 'An enesmetional perspective en nok and eewity leeuse eseasisted with the coal and nuoteer fuel Scenses (New York, Russell Sage Foundelen,1988).
Splene*, Journal et Pestes and infernesenet A#edre, 04steeputed try Seetc Seets,Inc.
volume 8, number 1. Wanter t ese, popes 101 131.
EPA. Inveenmenfel Aeddeten Prefection Meeufremente M S Spengler *Neunstic esinen and preference evolustion ser Normel OpereNons et ActMtes in the Urentum Fuel ter seeeeeing technelegient entiene = A user's view,' 6n Crede, Env6eenmental impact Setement for estableheng YT Coveito, JL Mumpower, PJM Stellen and VRR 40 CFR 190, EPA S20/4 7441S, volume 1. November Upputurt femtorek faveonmental impoet Asseeement, 197S.
Technoiety Asseeement and Area Aneo ets NATO ASI, r
M Grenon, 7he Nuedoor Apode and it.e Soler Orenger Genes G. Vol 4 (Seren, Sonnger Verlag,1946) pages Airernatives in Worft Knotyy (Outore, Pesgemon Prose, 917 ef 2.
1981).
M S So ingler, "The need for de nenimie reek stenderes ICMP, Aederson Pmteerson: Aeoommenestene et the in er;utatory esc 6eaon making: en inev' dust or tocatet Internettonal Commiseron on AedeJoptsel Protection nek ancept?* in R S McCott gee *er). Envorennenter (New York, Pergamon Press,1977)ICRP Publeetson No Noetth ReAs: Assessment and Wenepoment (Weterloo, 2S.
Ontenc, Canada, University of Waterloo Proes,1987) l C S Meinhold, *Cretene for a de minwme levet" Symposium pages 206 238.
et the US Health Pnysics Sacety, New Orienne, June 3-0 M Weiker, The Orfo* Compendon To Lew (Osterd, 4,1844.
Clarendon Prese,1980L R S Minogue, Memorendum for Comminaioner Aseeletme C Whippie teetork De Assadmde AdeA (New York, Plenum en *Reetenehtp between presoned revisen to 10 CFR Press, forthoeming 1987).
Port 20 and EPA reesten protecten elenderos,
O White, Jr end J E Brower testors), wortehop on a
August 2S,1866.
ProbJem Areen Assooeted with Developing Carcinopen NAS, The ENects on popuietrone of Esposure to Low Gu60elones, SNL $1179, Center ter Aseesement of Levole et fontains Aederen, Report of the Committee Chemical and Physioel Heserde, Brookhaven National on the Sological Effects of lenismg Redeteone, SElR lit, Laboratory Upton, Long taland, New York, June 1964.
Notenal Acacomy of Sciences, July 1980.
R Wilsort
- Commentary: fteks and their acceptabihty",
NRC,9rese neeeese No TS t08, Ann l 30,1976.
Sesence Technoingy, end Human Velves, volume 9, NRC, Plen for Aeewolverson of NMC policy on number t. Sprtng 1984, pages 1122.
Decomedeadoning et NucJoer Facettes NUREG 0436, R Wilson and E Crouch, redevaenefit Analyste Reve6cn i, December it76.
(Cambndge, Massachusette: Sallmeer Publehing Co, NRC, programmetic Enotenmental Impact Statement 1982) Chapter 1.
An60 sed to Deoontamination and Deposal of Andeactree l
242 PrWest Appresses owemarr nar
-~ -.
.