ML20043C088
| ML20043C088 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Brian Lee NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006040015 | |
| Download: ML20043C088 (4) | |
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Mr. Byron Lee, Jr.
AUG 2 61988 Nuclear Management and Resources Council 1776 Eye Street, NW., Suite 300 Washington, DC 20006-2496
Dear Mr. Lee:
I thank you for your letter of July 25, 1988, supporting NRC's efforts to develop a policy designating levels of radiation that are "Below Regulatory Concern" (BRC) and bringing to nty attention the various activities of the industry in this area.
The Commission places great emphasis on BRC activities. Ongoing staff efforts are concentrating on defining specific low level waste disposal and residual radioactivity exemptions. Also, a major effort to develop broad enveloping policy has recently been undertaken at the Comission's request.
Progress on specific tasks includes the following:
a proposed rule allowing on-site incineration of reactor-generated waste oil has been presented to the Commission and is expected to be published shortly; a policy statement on residual radioactivity limits for structures and soils is being developed; and the efforts on the broad enveloping policy have reached the stage where a I
proposal will be made to the Commission before October.
In order to be better prepared for expeditious evaluation and processing of the expected petitions for rulemaking for disposal of BRC waste streams, the
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NRC staff has had several meetings with EPRI, eel, and UNWMG at which industry progress on petition development and related technical issues have been discussed.
l The staff has also been following industry's technical activities in this area l
as described'at various technical conferences.
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In the development of the broad enveloping BRC policy, we are interacting with the U.S. Environmental Protection Agency. Once a proposed policy is published, I
. e expect comments from industry, the Department of Energy, and other interested w
l parties. We will, of course, appreciate receiving your views.
In the interim, the staff will continue its review of preliminary technical information developed by UNWMG, EPRI, and EEI for the purpose of keeping abreast of industry's ongoing activities related to anticipated low level waste stream petitions.
Sincerely, Original signed by Vict or St ello Victor Stello, Jr.
Executive Director for Operations DISTRIBUTION: See page 2
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when the absorbed dose at 10 mm is laternational Commismon on P maasaval Proesomos. D gereer overestimates of #s seed to estimate Ns, With this change in the range of d by a protection egnunst moninas radiation tasa external souruss:
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gienor of 2,it seemslikely that an appbcable value of the factor
% Mt to ICRP Puha-na.15, gunsforig, Nyt ymyn-y would still be les than twice the previous maximum quabry mon Press;ICRP Pubhation 21; 1973.
hy guesor of 11. Without detaded calculations, it is uncertain what laurnational Comenision on Radiological Prama'aan. Stau-y this M taight be, but one might expect it to be conaderably less aient from the 1985 Paris toesting of the imp, New Yoric than 22 and of the order of 2 x 6, or approumately 12.
The authors propose that calculauons of absorbed dose andPergamon Press; imp Pub, No. 45; 1985.
dose equivalent, as a function of depth and for appropnate ori-M -- J Comausson on Radiation Units and Measure.
y estations of an incident neutron beam, be made for the ICRU ments Determianhaa of doet equivalents resuluas ham ex-amhaart= MD:KRU;3CRUReport 30.cm<hneseer sphere for the proposed maximum Q for neu, tenal radahon sourtaa trens(ICRU 1986) Also, new calculations of the eSective dose39;1985.
equivalent in an anthropomorphic phantom should be made.
International Comm==ian on Radiation Units and Measure-The availability (sf these data wil! allow selection of: depth (d) meats. 'nie quality factor in radiation prosacean Betheads, for N'(d) such that the product of a factor M and D(d) does MD:ICRU;ICRU Report 40;1986.
A not underestimate #s and minimizes the range of the ratio of National Council on Radiation Protecnon and Messnessets.
9; Ns/H'(d) for all incident neutron energies.
Protection against neutron radiation. Bethesda, MD: NCRP; WrmAM M. BECKNER NCRP Report No. 38; 1971, i
HAnoLn O. WycKorT National Council on Radiation Protection and Measurements.
f' National Council on Radiation Protection and Measurements Recommendations on hmits for exposure to ionizing radia-7910 Woodmont Arnue, Sune 800 tion. Bethesda, MD: NCRP; NCRP Report No. 91; 1987, h
Bethesda, MD 20814 l3 controllability, as in the cases of cosmic rays and "K in the Comments on Various Views on the Concept of 'de human body. The I AEA Guide uses the term ';fElusion" from Minimis' regulatory control for such cases.
Then to the other concept, that of a de minimis dose. This is
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(Received 20 December 1988) assumed to be a dose whict'. for all practical purposes, can be said to be nonexisting. A de mmimis dose could therefore also
Dear Editors:
serve as a cut off value which would prevent small individual THE de mimmis concept seems to cause de maximis confusion. dose contributions to be included in the calculation o(s couect I was provoked to wnte this letter by having read the reply by dose. This thought is very appealing to common sense, tout, un-i Kocher to the letter by Murray and Cook on the subject of a de fortunately, common sense is sometimes a very primitive in.
I dicator of real sense. There are many shortcomings of tae con-minimis dose-There are two concepts which are quite different but which cept, so I shall only mention the most obvious ones.
are often confused. One is the very legitimate wish to exempt it is a misconception to think that some risks are mar =runWe some insignificant radiation sources and practices from the full rnerely because they are small. Acceptabihty depends on the ma:hinery of regulatory requirements (notification, licensing.
point of view. From the point of view of an authority, we may I
inspection). How to deal with this panicular problem is the feel that small risks ought to be acceptable, and it will be nec-l subject of a recent International Atomic Energy Agency Safetyessary, indeed, for the authonty to permit e number of risky Guide (IAEA 1988), which gaves two critena for the selection practices since nothing is absolutely free of nsk. But from the of sources and practices chgible for exemptiott pe d 6 d at d aman 2 are nM m%
- 1) individual risks must be sufficiently low as not to warrant acceptabic, it is quite common, and understandable, to have that I shah nm ampt ewn a my small risk if it 6e a on, including the cost of regulatory con.
pes me no a
h ed upon me and anses fran 2) na on p ot trol, must be optimized.
something i do not like.
There is a shp oflogic in Kocher's reply to Murray and Cook The second enterion means that the option of exemption will when he says that ** practices should be of no concern if doses be the optimum choice if the collective dose is small. Thus, the to all reference individuals are below the de minimis lew!, re-IAEA recommendation on exemption embodies the two re.
gardless of the hypothetical number of predicted health effects, quirements: a low individual dose and small collective dose.
because all individual nsks would be trivial." Yes, all indavidual The IAEA Guide reminds the reader that competent author-risks would be invial, but the collective impact might not be l
ities may sometimes find it reasonable not to exempt a source trivial. It is not a suffoent requirement for acceptance that every or practice, even if both individual and couective doses are small.individual accepts his own individual risk. Even with a very f
f For example, few authonbes would accept the deliberate addition small risk to each individual, the situation may well be such of radioacto e substances to toys or food (i e., with the intention that it is almost certain that somebody will be harmed or die, i
I to make use of the aetnity e.g.. as with lummescent paintmg When we sum up the impact on each individual. wt must there.
or for tracer purposes). It would also not be advisable to exempt fore count not only his or her small nsk of being affected, but j
a source with a potential of high doses in an accident even also the regret or resentment which each indnidual may feel at i
though the doses under normal conditions may be set) low knowing that somebody will be harmed. In Wilham Rowe's An t
hempam may aho need to be made on the buis oflxking 7
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July 1939, Volume 57, Number I 212 Heahh Phyam Anaromy ofAisk (Rowe 1977), this compliation was illustrated doubtful techniques which couW be easily isaproved at hEr eget, by the drastic example of a collective game of Russian roulette.
would it then act be worthwhile to ove some livest Been tone,.
A common objection to this reasoning is that, at low levels admittedly, other risk sources cause sacre harm.
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of risk, the collective impact would still be neshgible in com.
The heart of the matter may be that those wiise weal es eut-I~
parison with the overall collective sufering e.g., the total back-off of small doses might act see it as a cut of of low risks but ground of cancer deaths. That is very true, but quite irrelevant.
of aero risks, i.e., they snay not believe that ensaB doses have The omall background of cancer deaths may have many causes, any eSect at all. For senay people, this is cosae kind of "put i
and we do not know the balance of bene 6: and detriment from feehas" act mally supponed by edentiac esces. They could be 1
those sources, nor do we know to what entent those sources are right, tort the curvest postulatice of rednaison risks ia proportion contronable. But when we look at a particular radiation source, to the dose without any thresheW value is also considered try it is the bene 61 from that source that must outweigh the harm, saany to be, if act a proven fact, a rather likely possitalsty. la and it is the efort of controlling that sourts which must be the steence of coevnacias proofli of either view. I sugest that considered in relation to the magnitude of the harm, the profession of radiation protocuon should adopt a cautsous Kocher argues that the cut of oflow doses by a general de attitude rather than bothgerently crying for a de minimis, a con-minimis value "would ensure that the ALARA principle is not cept which I coander untenable ce both logual and estucal apphed to trivial risks, regardless of the magnitude of the col-
- grounds, lective done." I am not sure what "ALARA" concept Kocher /
- as low as reasonably achievable," thin ALARA, by its defini- [
has in mind, but ifit is what ICRP means by keeping all doses 80 h 3,
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j tion, would rule out unreasonable protection cKorts.
An irwhvidually neghgible done of I gSv to the U.S. population S 04 0 rockholm* Sweden would mean a zero collective dose with the cut os, but in reahty a collective dose of some 250 man Ss. With current assumptions on dose response relations, this is very likely to kill at least one References person, perhaps ses eral. Whether this is acceptable or not would International Atomic Energy Agency. Principles for the esemp-depend on the source or practice, if that death toll prediction tion of radiation sourtes and practices from regulatory con-related to the nsk of one day's trafhe in the United States, we trol. Vienna: lAEA; I AEA Safety Series No. 89; 1988, would be exuberantly happy. However, ifit were caused each Rowe, William. An anatomy of nsk. New York: John Wiley &
year by environmental pollution from one single enterprise using Sons; 1977.
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