ML20043C141

Discusses Positions & Opinions of NRC & ACNW Re Proposed Commission Policy Statement on Exemption from Regulatory Control

ML20043C141
Person / Time
Issue date:	08/29/1988
From:	Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:	Stello E NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20042C963	List: ML20042C960 ML20042D060 ML20042D061 ML20042D067 ML20042D082 ML20042D085 ML20042D086 ML20042D099 ML20042D112 ML20042D113 ML20042D126 ML20042D130 ML20042D133 ML20042D186 ML20043B905 ML20043B907 ML20043B908 ML20043B909 ML20043B910 ML20043B911 ML20043B912 ML20043B914 ML20043B915 ML20043B916 ML20043B917 ML20043B918 ML20043B919 ML20043B920 ML20043B922 ML20043B923 ML20043B924 ML20043B927 ML20043B929 ML20043B931 ML20043B932 ML20043B948 ML20043B955 ML20043B956 ML20043B959 ML20043B960 ML20043B962 ML20043B966 ML20043B973 ML20043B974 ML20043B978 ML20043B982 ML20043B988 ML20043B990 ML20043B991 ML20043B992 ... further results
References
FRN-53FR49886, RULE-PR-CHP1 NACNUCLE, NUDOCS 9006040116
Download: ML20043C141 (2)

Text

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- i UMTED STAT 88 NUCLEAR REGULATGRY COMMISSION

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memworow.o. c.soess AUG 29 m MEMORANDUM FOR: Victor Stello, Jr., Executive Director for Operations FROM:

Eric S. Beckjord, Director, Office of Nuclear Regulatory Research

SUBJECT:

PROPOSED COMMISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL The subject Commission pater has been developed to respond to the Staff Requirements Memorandum (R.M) of March 30,1988 (Enclosure 1). The SRM requested options for a Commission policy which establishes a generic number for radiation exposures that are below regulatory concern (BRC).

Because of the broad nature of this policy, the development of the

) aper was undertaken with the assistance of an Interoffice Working Group whic1 included cognizant individuals from NMSS (5), NRR (2), OGC and RES (5). As you might expect, wide ranges of positions on various options were held by individual members of the staff. The ACNW also has reviewed the initial draft of the proposed policy and has expressed their positions and opinions in a letter to the Chairman on August 9, 1988 (Enclosure 2). The staff is in agreement with the ACNW on several key issues. However, on the subject of the need for a test of signifi-cance on collective dose, the staff has taken exception to the ACNW's view that such a criterion is unnecessary.

In attempting to incorporate ACNW comments, as appropriate, and to respond to your concerts regarding possible misinterpretation of numerical values called out in the proposed policy statement (enclosure 2 to the Commission paper), a revision of the Commission package was transmitted for office concurrence on August 15, 1988. We have received concurrence from NRR and GPA and a no legal objection from OGC, but NMSS has informed us that they cannot concur on the paper. They have transmitted the attached alternative version of the proposed policy (Enclosure 3) which they find acceptable. Basically, HMSS supports the view that only a single numerical individual dose value of 1 mrem per year should be emphasized within.the policy. This value would establish a condition under which exemptions could be granted based on only simple analyses. They also believe that the section of the policy on calculation and use of collective dose assessments is too wide-ranging and that this section should be focussed on a preferred option.

RES believes that the NMSS view, especially on the collective dose issue, is worthy of serious consideration as a policy implementation issue but does not need to be resolved in the policy statement.

RES also believes that exemption decisions can be made on straight forward cost benefit analysis, if certain individual dose and other conditions are met, and that this possibility requires emphasis in the policy statement.

60 116 891130

~CHP1 53FR49886 PDC 1

J_____-_--____-____

,..c-4 AUG 2 9 Iges Vi,ctor Stello, Jr.

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With the schedule for presentation of the policy to the Commission on J

September 16 and the nesd to establish a

• talking position" for the International Worksho) scheduled in mid October, I believe an impasse in staff opinion has been reacied which requires your consideration and resolution.

I have therefore forwarded the enclosed Comission package for your review together with the NMSS alternative. The two major differences lie in the resentations contained in (1) Sections IV of both proposed policies and l

p(2) Section Vil of the RES proposed policy vsSection V C of the NMSS alternative. Both RES and NMSS staff are in agreement on many aspects of the proposed policy. We are prepared to meet with you and the NMSS staff, and, if you desire, other involved parties, to resolve these two outstanding issues at our scheduled meeting on September 2,1988, or on an earlier date at your convenience.

V Eric S. Beckjord, Director Office of Nuclear Regulatory Research

Enclosures:

1. Comission Package

2. ACNW Letter

3. NMSS Alternative Policy l

i l

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