ML20043C224
Text
___ _ _ _
37.3 2-Jf f
33
%s
$pp i
JUL 1 1988
~
MEMORANDUM FOR: Those on Attached List
~FROM:
B. Morris, Director, Division of Regulatory Applications, RES
SUBJECT:
INTEROFFICE MEETING TO DEVELOP STAFF CONSENSUS ON BROAD BASED BRC POLICY STATEMENT The purpose of this memorandum is to ask for your participation in a second interoffice meeting on this subject to further progress made at the meeting in Baltinore on June 9-10, 1988. This meeting will be held on July 7,1988, in conference room NLN-350 from 8:00 a.m. to noon.
The major technical issue involves treatment of collective dose. The issue is whether the calculation of collective dose should be cut off when individual doses reach some low level such as 0.1 mrem, or whether the calculated collec-tive-dose should include all individual doses down to zero.
In the latter approach, the policy would define a varying dollar value for-each person-rem of the collective dose depending on the magnitude of the individual doses of which it is composed.. Several significant issues involving presentation of the BRC policy also require resolution.
It is intended that a meeting agenda and two alternative draft BRC policy statements, including the differing approaches to collective dose treatment and highlighting other less significant technical and presentational alternatives, will be sent to attendees prior to the meeting.
Crisinai siansd ays Ca He R. Pos& cry
-C v Bill M. Morri. Director Division of Regulatory Applications Office of Nuclear Regulatory Research Distribution:
[ MULTIPLE) subj-circ-chron BMorris Reading Files ZRosztoczy
-TPSpeis RAlexander WLahs-SNeuder CMatt en DHo s
h
~DRA:RES~200,[-
2(If2-DRA:R5
-Offe: RPHEB:RES PHEBfRES Name: Wlahs:pt RAlexander Rosztoczy BMorris Date: 7/d 88 7///88 7/l/88 7/ I /88 0FFICIAL RECORD COPY j
90060402G2 891130 bFR49886 PDC i
N, W 2
. y..
.e 1 ;,
Addressees - Memorandum ElI N
F. Congel, Director DRPEP, NRR, IDE-4 J. Cunningham, Acting Chief, RPB, NRR, 110-23 R. Bernero Deputy Director, NMSS, 6A-4 R. Cunningham, Director, DFC, NMSS, 6H-3 J. Austin, Acting Chief, OB, IMNS, MMSS, 6H-3 D. Cool, Section Leader, PSS, OB, IMNS, HMSS, 6H-3 K. Dragonnette, RB, HMSS, SE-4 R. Fonner, Deputy Assist. GC for Rulemkg & Fuel Cycle, OGC,15B-18
w-qwuw PART a olngs er enAcnce En comsnc uchsmo enoceamnes; _gg927p j B60 ert64lenovelStatement
%sasselapposesh sched 9
g-1 i
of po y end puedwa Conandes as me.
summent. Amiseen susmer
+
s
' petitions pwouset to I 8JIDs for Dispeest of -
geoese Qene es is
\\
+
,a pined in plan
.Re&oective Weste Strooms Below t.
Reguletery Coneem.
outhnee e seasons beste ter assumpbebleg U.
9
'W I introduction and Pwpose the tesffis to pubheh seelstems se -
la siendede and pneedene desuments and esses ne 1
p* y of the entaiensin die poemel eveAmbthl lit. Agreement tutes.
IV.Foture Acusa
. l. Retrednesee'and paspese safenie suppauss The law.14 vel Radioective Weste policy pettuans mes he ned by the petietener W
'l Amendments Act of teelfthe Act)143 USC, the Commission is to set in en supedited sonb ei we; wu ennied kneery is.neen, meann.N the pousseer wesha to esswo f
secuen se of the Act oddam depenalof espeeted essen, the supperung indumstem J
weetee termed '%elow segulatory eeneere should he semplete emeegt es est a
that would not need to be embiect to Commission eeuen is primasey healted to seguletory control to esewe adequete ladspondent evoieetles and adminiewetes preteeuen of the pubhc heahh and safety.
puesteeles j
becesse of their ro6eactive sentent.The geel Deeleien erlierte for h4his wheter to of this section of the Act is for the great a pettuen invelee the seere5 Imposes of I
Commission to make procucal and unely -
me est6en, weste and I
decisions to determine when westes need not :
estien of the seampeen.
I 30 to a heenud lowhvel wHle de 1 este, followleg etterte address these emes.
These decisions will he empressed petitions wheeb demonstrate that diese.
tulemoking Aherneuve disposalwould erher(e ese met should he seitshie for conurve space in the emiettne ettee while expedited ecuen.
new sHes ete estabbshed and seduce une
- 1. Disposal and treatment of the westes as costs of disposal Italemaklag peutions may specified in the pettuen will soeult in no -
play a role in the nationellow level weste significent impact en the quehty of the husnan environsnent.
strategy outhned by te Act The Act jJ provices that the Commission estableh
& The mentmem espected e5eeuve dose p7ecedures for acung empediusuely on equivalent to enIndividualmember of the peuuone to esempt spectf.c radioective pubhc does not emoeed e lew milhrem per I weste einema from the Ceauninion's Ryear for normel opereuene and sabelpeted g,ehvienon, g4 a m eouscuve doses i.ne acei overii.
3>
e u, ote of we etaiemeniend E accomp,an,ying impiemontetion plan le to
[ population and general t on are emell.
- estabbsh tre standerds and procedures that
- 4. The potentiel redi sal eensequences
- will permit the Comminion to act upon
- el secHients se equipsunt malfuncuon rulemaking pennene in en expeditious involving the westes and intrusion inte menner se cahed for in the Act. Tius pokey d'*P'#1 elie' after le# of normal luutuhonal controle em not significant.
statement does not requtm peuuonere to
- 5. The esemphon will voeult as e espnifloant
. present s!! the informenon outhned or
'educuen in sociesel ooete.
7 demonstrate that the decision enteria for expedited handhng can be met. if such SIThe' waste is sempeuble with the expedited handhng to not wanted For proposed teetment and &spoul epuons..
easmple. petiuono mquesung enemption of 7.The esemphen is useful en e notnenal concentrouone of radionuchdes that might scale.l.e.,it le hkely to be used by a estegory result in indivicTual empoems higher than.
of heenme or et least e significant peruon of those recommended in the decision entene e estegory.
mey be submitted. but empedited handhng
& N radiological properuee of the weste cannot be eesured.
etwo have hun cherectertsed en a neuonal accompanytag implementeuen plan are.
basis. the vanobiht) has been pro 6ected, and Fir 3sli).this pobey statement erid the tenge of varieuen will not tavahdete intended to facihtats handhng of rulemaking supporung analyses.
peuuona for streems from multiple producere 9.The weste eherecternaation is based so and do not apply to individual hcensing date on veel weeles.
ections on smale producer weste. Individual to The disposed form of the weste has
~i heenms who mk approval for disposal of seghgible potenhal for recycle.
their uniques wasles me) contmue to submit St. lJcensees can estabheh effective, their disposal plans under 10 CFR 30.3044)-
licenuble, and inspectable progreme for the
- eele pnor to trenefer to demonstrate II. Standards and preendures ne eiend.,ds end,rocedme needee io
%ty'ff.ne 4,e,,m.n, e,.,,osei handie peutione expeditiously fellinto the oudsum (y, senttery landfull dose not need following thne categories (1) t'sformehon to be centrolled or monitored for redienen petitionere should file in support of the protocuen purpom.
pettuans. (2) standards for eseessing the 13 h swthode end precedwes used to l
adequacy of the proposals and providing manage the westes and to aseees the impacts peuuoners insight on the decision entene the are no different from these that would he Commission intends to use so thet all opphed to the _ ' Meneestaminated.
i mlevant informeuonaliseues will be
,,an g addressed m the pennon, and (3) the internal u nm are no voguletory or lesel i
i NRC adminittntive procedures for hendung obstacles to me of thw propowd WesteHet er r
the petitions These three categenes are ~
6epad owthodo i,
addressed in the attached staff implementet on plan The staff plan was III. Ayeoment States developed in nopense to Commission N b.14 vel Radioactive Weste pohey direction to provide detsiled gaidence on
'. Amendments Act of sets estabhehee e
+
240 p
V l
. App.B' PART 3 O RULES OF PRACMCE F3R D*ME8DC UCENSING PROCEEDING 8%t notional system for deshng with low level A Ceneral j the petitioner if the Commiselon is to act pO '
b wente disposal The system assigns in the 1.10 CFR Port g Requirements in en expedited manner. Peutiotia lot
.)
Sietes responsiblity for disposal capetity for g Environmentellepects rulemaking should therefore be a
h low level wastes not emceedmg Class C 3 Economic impact on $mell Entities submitted following the staff's g'
westes es defmed in 10 Cf1t 6165 Section 10 4 Computer Program supplemental guidance and
' Y"g ' !
of the Act encouroses 4 toduction in volume
- 6. Scope to suure expedimd action.
8e L Environmentalimpoefs. Petitions '".1/
of such westes subject to $teit responsibhtiy B Weste Characterisation for desissel through the option of determinmg
- 1. Radiological Properties must enable the Commissiot to imake a a.
that certaiss westes need not go to eusting 8 Other Considerations g Totals Imdtng of no significant impact am the hcensed disposel feelhtwo or new sites quality of the human environment.Such t
licensed under 10 C71t Part 31 or equivalent
- 4. Desis State regulefsons if rodeological safety can be
- 8. As 14w as Reasonably Achwveble Commission findinge must be based en essured. such dispoest would conserve space (ALARA) an Environmental Aeoessment that in the esisting sites while new sites are C. Weste Management Options complies with 10 CFR 41.30 and must developed. sad would sene as en important D Analyses meet the requirements of 10 CML 81.32.
edjunct to volume reduction efforts in
- 1. Radiologicallmpacts These to uirements include addressing meetmg the weste volume ellocation limits g Otherimpacts the n'ed or ihe Proposed action.
set forth in the Act. Thus. these rulernek.ngs 8 Regulatory Analysis identifying alternatives, and assessing ohould aid the Sietes in fulfillms their E. Recordheepmg and Reportmg the Potentiel environmentalimpacts of responsibilities under the Act Equity also
- 1. Surveys the Proposed action and alternatives.
suggests thet all waste generators be able to 8 Reports take adsantage of below regulator) concern F. Proposed Rule Consistent with 10 Cf1t 51.41.the Ill Decision Cnteria petitioner should submit the information options es part of theit weste management strategies Generators in both Agreetment IV. Administrative Hendhng needed to meet these requirements and do so in a manner that permits end non. Agreement States will be competmg
- 1. latroduction for space in the existing sites and the concept independent evaluation by the should be opphcoble nationwide Section 10 of the Low. Level Commission of the data and j8,','[,'"' 8'*[8jl,P84*nj,Po"*ht Redioactive Weste Pohey Amendments methodology used and the conclusions g,,
Act of 1985 requires the Nuclear reached national besis and that it remams equitable Regulatory Commission (NRC) to
- 3. Economic impoet on smallentitiet States base been encouragmg fmdmss that de$elop standards and procedures for When a rulemaking action is likely to certain wesies are below regulatory concern and do not have to go to low. level w este expeditious handlmg of petitions for have a significant economic impact on a sites The States have been voicmg this view rulemaking to exempt disposal of substantial number of small entities, the for a numbst of years through forums such as radioactive waste determined to be Regulatory Flexibility Act requires that g the Conference of Radiation Control Program
, below regulatory concern.The Act also g the impacts on these small entities must Directors Rulemakmss granimg petitons will 0 require.s NRC to identify information g be specihcally addressed (The g
nIe'qu r'lhr emakmg R petitioners should file.The Commission
- Commission's size standard for g Policy Statement provides general
! identifying a small entity is $3.5 million t
Agre et tes 6 will be coordmated with the State,
. guidance on how to meet the
- or less in annust receipts except for nqu ments sech n10 of the Act.
- private practice physicians and "n IV. Future Action The Commission will conduct e generic outhnes the overall approach to be educationalinstitutions where the rulemakmg on waste streams below followed, and hsts decision cnteria to be standard is 31 million or less in annual regulatory concern based on a number of used Implementatiot, of the general receipts for private practice physicians factors The factors melude public comments recened on the statement. the number and approach and decision critena of the and 500 employees for educational types of petitons for rulemakmg recened and Commission Pohey Statement involves institutions. See 50 FR 50214. December how effectne the statement is in enablitig developing more detailed guidance and 9.1985.) For any rulemaking. the timel) processms of petitions A gener c procedures. In accordance with Commission must either certify that the rulemakm3 is warranted to provide a more Commission direction, the NRC staff has rule will not economically impact or will efhcient and effectne means of developed more detailed guidance and have no signihcant economic impacts on 8 'he gAn,d a('ce procedures forimplementation of the small entities, or present an analysis of y',*g*h ics prop Commission Pohey Statement.This staff alternatives to mimmize the impacts.
rulemakhng will be published withm 90 days guidance and procedures cover:(1)
Because rulemakmps on below penodicall) review all rvlemakmsi in order Information petitioners should ble in regulatory concorp sinould provide rehef Furthermore the Commission ma) to assure that the relesant parameters hase support of petitions to enable expedited from requirements lot all affected not changed sigmhcantly and me> ask the processing. (2) discussion of the decision entities, satisfaction of this requirernent petitioner to submit updated information to criteria, and (3) administrative should be straightforward but it must be assist m the review.The Commission would procedures to be followed.
addressed in any rulemaking To facilitate expeditious preparation of the also have to conbrm that approved eternptions are consistent with any general ll. Informatico to Support Petitions proposed rule responding to the petition, standards issued b) epa' A. Genetc/
the petitioner should submit an Dated at Washmgion. DC this 25th de) cf evaluation of the estimated economic g
impacts on small entities.The vgu 886 todiIied it formation requirements for-evaluation should mclude estimates of For the Nuclear kegulator) Commission petitions f or rulemaking are outlmed in the costs for small entities in terms of Samuell Cm, the Commission's regulations in to CFR staff time and dollar costs. Any Secretoy to the Commissio
2 802[cl These regulations require the alternatives that could accomphsh the EditonalNote The staffimplementatior' petitioner to identify the problem and objective of the petitioner a proposed plan will not appear m the Code of Federal propose solutions. to state the rule while minimizmg the economic E'8 d*"
petitioner's grounds for and interest in impact on small entities should be Nucleat Regulatory Commission Staff the action, and to proside supportmg presented. The es aluation should implementation of Nuclear Regulator) mformotion and rationale. As a practical 5"CI' ' "" *S" "IOI'h' Commission Policy on Radioactive matter. the mformation demonstratmg ncre a
"8 Waste Below Regulator) Concern that the radiological health and safety ejd ed te impacts are so low as to be bel
- petitioned rule change i ini,wi,en regulator) concern must be provided by 11 Information to Surpen Petitions 2 51 August 29,1986
App.BdifJ App.B(IH
.PART 2 O RULES OF PRACTICE FOR DOMESTIC LICENSING PROCEEDINGS
.s g ciompi ing with 10 CFR Part 61 weste be conaldered in selecting acceptable petitioner's analysis should addreas the Deels for persmeter selection and classifcation requirements. Waste Options.
generators use generic ocahng factors D. Analyses ladicate how likely the extreme saae & A' and factors established for their specific westes through sophleticated analyses.
To support and justify the submittel, may be). In addition, the petitioner's
'4 The scaling factore are used toinfer the each petitioner should include analyses analysis should also addreas paamannat g 7
presence and concentrations of many of the radiologicalimpacts eseociated exposures from handling and treasport.. p
4 radionuchdes based on measurement of with handhng. transport. and disposal of accidents.The petitioner's analyste of only a few nuclides.The classthcotion the specific wastes. Any incremental accidente should include all
<j assumpt6ons, data, and resuha to yA shipment of the entire weste stream to scheme in 10 CFR Part 61 has been in nonradiologicalimpaete should be facilitate review.The potential for effect since December 1963 essessed. Also the petitioner should use Considerable data and experience the analyses to prepare and submit a should be evallable to allow detailed regulatory analysis with the one or a few facihties should be characterizing the radiological content petition.
essessed.This scenario currently salets and composition of the weste stream
- 1. Aodiologico/ /mpocis. De for 10 CFR 30.306 exempted liquid
,i being addressed in the petition The es aluation of radiologicalimpacts scintillation wastes and might result n
same principles outhned in 10 CFR should distinguish between expected from very hmited numbers of treatment facilities or decontamination services.
81.55(a)(8) may be opphed. i.e. values and potential exporures and events.
based on direct measurements. indirect Impacts should be assessed for the The analysis of impacts for trenoport, methode related io measurements, or expected concentrations and quantities handling and disposalshould include,
material accountabihty.
of radionuclides.The petitioner should evaluation of this potential circumetence S. As low os is reasonobly ochievoble quantitatively evaluate the impacts from unless it can be clearly ruled out.
(ALARA).The Commission's A1. ARA the proposed waste for each option As suggested in Paragraph as on page 20 of ICRP Pubhcation a6 8:
requirement in 10 CFR 20.1(c) apphes to requested.The petitioner should clearly efforts by licensees to maintein relate the analyticalImdmgs to specific Exception from regulanon and radiation exposures and releases of provisions in the recommended rule requinments on these bases should not be radioactive materials in effluents to changes. For ekomple, the basis for each used to make it possible to depose oflarge unrestricted areas as low is reasonably recommended radionuclide limit should SU'"Id*' 'l'*d'oective mewnalin diluted I* ~ i" d *d* d P" '* *'I"8 achievable 10 CFR Part 50. Appendix 1.
be eleatl> emplained.
describes ALARA for radioactive The radiological impacts included in Id up h?sh
" b'o"n f
P ev h
l materials m hght wster reactot effluents.
NUREC/CR-3585 and in NRC's many small doses to mdmduals Not should Licensee comphance with 10 CFR 201(c) computer program (IMPACTS-BRC) the> be used to exempt activities that. by is a precondition to acceptance by NRC cover exposures to workers and isolation or treatment. nete been made g of any weste stream as exempt.
mdividual members of the public and temporaril) harmless but that imply large g Therefore, a dencription should be K cumulatne population exposu:es.The A potential for release at:d could sne noe to E program calculates both external direct I h'sh mdnidual doses or high collecuve doses.
[ provided of reasonable procedures that
[ gamma exposures and exposures from h The analysis of expected radiological a
waste generators would be expected to
- use to mmimite radiation exposures g mgested or inhaled radionuchdes NRC's 6 impacts should clearly address:
computer program can be used to 9
-The maximum individual exposures,
- resultmg from the disposal of the e
exempt weste.e g,remosal of surface calculate the expected radiological
-The critical group exposures contammation.These procedures are impacts from generator activities.
-The cumulative population assumed to apply prior to characterisms transportation. trea tment. disposal exposures.
oprutions.uut nwi.ili po al input.
The maximum individual exposure the weste to be exempted i
lin tune.nu.an,uuh <e a u Me sange evaluation should include exposures to C Waste Monogement Options ni m.ougement option int luihng all members of the pubhc who may be The management options that the on ne neatun nt anil ihquaal in the exposed beginning with the initial Commission can deal with expeditiousl) seneutor lupment to munn ipal na te handhng at the generator's facility
'are those described in NUREG/CR-3585 management facihties, and shipment to through post closure.Both internal Onsite options include inemeration and hazardous waste management facilities.
uptake and external exposures should burial. Offsite options are murucipal The program covers impacts begmning be included.The individual may be a waste disposal facihties Isanitary with inmal handlmg and treatment by member of the general population (e.g, landilis). municipal weste memerators.
the generator through Imal disposal of consumer of contaminated ground hazardous disposal facihties, and all the radionuclides contained in the water) or a person receiving the hazardous waste meinerators waste stream. Sequential treatment, exposure from his or her occupation.
Pretreatment. e.g4 shreddmg of sortmg and incineration onsite and at Anyone who may be exposed and is not otherwise potennally recyclable municipal and hazardous f acihties can a radiation worker should be considered matenals. is a potential adiunct to either be assessed. Disposal of resulting ash a member of the public. For example, a onsite or offsite options Combmations and residue is included. Post disposal worker at a sanitary landfill or a of these options can also be esaluated.
impacts that can be calculated include commercial trash truck dnver would not For example wastes may be memerated releases due to intrusion. ground water be a radiation worker. However, on site and the ash shipped to a sanitary migration. erosion. and teachate occupational exposures to radiation landhl) The favored disposal options accumulation The program thus workers should be evaluated and should be identif ed and full) desenbed
. addresses both expected and potential considered in the cost / benefit analysis The petitioner should es aluate a full post disposalimpacts.
of the incrementalimpacts between range of options The practicahty of the The peuhoner's analysis of transport disposal at a hcensed facility and the proposed option (s) should be presented impacts should be based on a requested disposal options.
Weste compatibihty discussed earher is reasonabl> expected spacial distribution The total population exposures can be one aspect The national asailabihty of hcensees and weste treatment and estimated and summed m two parts.
and dismbution of the option is another.
disposal facihties which will accept the One part is the smaller critical group Upde r. national regulations and wastes The pennoner should address (usuah) the occupationall) exposed laws priammF to the proposed opuen parameters such as average and populanon) w here potential exposures sho.
ne desenbed and myht base to extreme transport distances The 2 53 Au gust 29,1986
i 4,,,cu e,
App. B(lil PART 2 o MULES OF PRACTICE FOR DOMESTIC LICENSING PROCE o
i-n.,
.f.
addren whether changes in technical external exposure anu the dose incurnd hulth effects. this level of risk a5 specifications or licei.ees may be from that year's intake of radionuclides, to an annual deu of the order af e.1 mee tse However,in meet proctical sessa.the used + g m'aines 1 While a range of1-10 milbrem per year needed.
3 might be acceptable, a one milbrem dose I enemPhon rules attaes in source related y E Prdposed Aule would lacilitate eapedited processing.
wuie stream alievn'd'
- h'*' * **""t.
- """"'d
d Weint w assetre H'8 d' ** Y "9". i "
h
~
extensive justihtstion Based on a Consideration should be g6ven to the maad ler De P'tition should include the int 4
for the propose rule (see to CFR mortshty risk coefficient for induced any optimination of red.stien y,etaseien and 2J02(c)(1)).The proposed text shoutc cancer and hereditary affects of 2x10" to the penibthty that many pract6ees and cover at least the following:
per rem (ICRP Publication 26) radiation seurose of the same kind essid combine new er la the foten so that the6r total effect may (1)The quantity andfor concentration exposure at a level of milhrem per year hmit for each radionuclide present would neult in en annual mortality risk be aisnihcant, even though each source l
(trace radionuclides could be lumped of 2x10*'(i.e 2x" effects /remx*8mm/
Q"'01 6d hi i
together with a totallimit),
year).
the critical group Tlus may involve The EPA is developing criteria for
,,,,,,,,,,,,,g g,,e,,,ig,,, ente and of the (2) A method to deal with identifying low level radioactive waste collective dose per unit practice er asurce,in radionuclide mixfures; that may be below regulatory concern order to answe that the indiv6 dual dose
.' e (3) The nonradiological specihcotions as part of that agency's development of requirement wili not be encoeded now or in to adequately define the eneral environmental standards for the futun. it seems almost certain that the necesser)d total annuel dose to a ample indwidual from ow level waste disposal. The EPA esempted sources will be less than ten 16mu (4) The specific method (s) of exempt pubbshed an Advance Notice of the contribution from the exempied source disposal.
Proposed Rulemaking on August 31.1983 IIpracticable, and if the supporting (48 FR 39563) and currently hopes to
[,yMN8N,di 6dus
.dyor by
. i' r,,.
information indicates the need, the text pubbsh proposed standards in early redeems the annualindwidual dose should also addren other features such 1987. Other EPA standstds that the esemption entenon from c.1 to 0.01 mSv {to as annual hmits on each generator in doses can be compared to are the Clean to i milhrem).
terms of volume mass,or total Air Act radioactive release standard of he NRC staff recognizes that at times, radioactivity, and admmistrative or 25 milbrems per year in 40 CFR Part 61 human mactions are not so strictly R
procedural requirements including and the uranium fuel cycle annual whole I governed by quantative considerations g process controls. surveys, etc., that ha5e g body hmi,t of 25 milbrems in 40 CFR 190.
as the ICRP excerpt suggests.
One milbrem is very small v. hen a Nevertheless, the 10" per year value g been discussed.The text should not g
include the various dose hmits used to e compared to naturstly occurring
' seems about as low as practicable.
j a
a background doses from cosmic and 7 seems too low to justify significant j.
f justify the proposed radionuchde hmits.
terrestrial sources. Background doses in concern. and so seems acceptable.
l 7 the United States are typically in the The United Kingdom's National L
- III. Decision Criteria 100-120 milbrems per year range Radiological Protection Board has The Comminion pobey statement exclusive of the lung doses from redon.
issued generic guidance on de minimis 1985)
- that estabhshes that the following criteria One milhrem is also small when dose levels ( asp-7. janusIl Radiation should be used by staff as guidehnes for compared to the annual 500 milbrem has status similar to Feder acting on a petition Each criterion is dose hmit for individual members of the Guidance issued b the President in this repeated and staff views on general public in Federal Radiation country.The Boardidentified effective implementation are discuned Council guidance, dose equivalents of 5 millirem Per year An important feature is that doses of as insignificant when members of the
- 1. Disposal and treatment of the up to 1 milbrem from the individual public make their decisions.The 5 wastes as specified in the petition will petition should minimize concerns over in llirem hmit represents the total dose
',:, ult in no signihcant impact on the c ntribution from all exempted A
ahty of the human environment,
,tr ms ICR lical o ad ressed practices For individual practices, the y
Discussen: Unless this fmding can be
'*['8" Board dwided by 10 (I e. 0.5 milbrem
'i"
made durmg information submitted by
,,n ted pH yurbo account r exponms from the petitioner, the Commission must paragraphs 83 and M on page n'i multiple practices.These hmite are prepare an Environmentallmpaci Many radiation exposures routmely apphed generically.14ss conservatism Statement to more fully examine the encountered in radiation protection.
under the well defined circumstances proposed action. alternatives to the
dy,"c"',*,'h', '[,1*i [yY,)p*n'*,,N'nh associated with specific weste streams th' proposed action. and associated and disposal options erwisaged in this potentialimpacts of shernatives.
dose limits or natural background. and are NRC statement seems justihed. In a Preparation would hiely involve well below dose inels at which th, Proposed policy statement dated May 6.
contractual support and would hkely appearance of deletenous health effects has 1985.* the Canadian Atomic Energy been demonstrated in indwidual.related Control Board specifically addressed take 2 years or more to complete.The
- ments. ii is widely recognized that Commission could not act in the petition there are radiati n d ses that are o small disposal of specibe wastes that are of no in an expedited manner, that they tnvohe riska that would be regulatory concern. An individual does
- 2. The maximum expected effectise regarded as neptigable by the exposed hmit of 5 milhrems per year was dose equivalent to an individual mdividuals Studies of comparative noks proposd for this hmited application.
member of the pubhc does not exceed a expenenced by the population in various A maximum individual exposure of 1 milbrem per year is also consistent with pp attoind ie t '""
few milhrem per year for normal Cg]t der flo
- e Appendix ! to to CFR Part 50. Appendix operations and anticipated events
) ear or less is not laken mio account b)
I specifies design objective doses for Discussen The effectise dose mdmduals m their decisions as to actions equivalent means the ICRP Pubhcation that could mfluence their niks Usms operationallight. water cooled nuclear 26 and 30 8 sum of the dose from rounded dose response factors for mduced power reactor effluents Thne design August 29,1986 2 55
,;c w "h. B(W)' PART 2 oj RUL.ES CF PRACTICE FOR DOMESTIC UCE T
n s
s-
"?
possesses:
expeditious action en the petitions. In 8CephsdNURBC/ORaesta NUREC/W,
J i
,W, eddition, the Handbook ne,tes genotel este and NUREG/CR 400s may be perehesed 5
h the U1 Government pnnung Omes l.,
eeboduling advice thel proposed rulee to (set)tr6 sese er by wnung to the grant petitlene should be published in er 5 Govemment pHat Omen.P.O. Sea la months efter acceptance end.
'smes e esim.DC bem N
publicellen for comment. Propased rules will be lerwarded to the Commiselon on 7 hnM in serves UA.
e 6 month schedule to the entent Department d Comme ee eles port Reyel -
permitted by resourse limite, the neture goed.apringfbeld.VA astet.CePies en and extent of public commente, and.
evelleek for inspecuen and/or espying for e internalCentrolof Rulemakl tee in the NRC Pubhc Decament Room 1ft?
DC seses.
procedures.Rulemakings inv H Street.NW, Wpen 83CRP Pubhsen
- Redeusa er reactere must be reviewed y the Protaten prinstple for b Deposal of Gehd -
ttee en Review of Generic q
Requiremente prior to publicetion.
"*8N
(
IdII"I'g,,,
e Proposed rulee involving meters will-of the i,te,neu,og c, iseies se therefore be forwarded to the god,eloeical Premonen? adopted {enmary 17, thaminalam on a 7 month schedule to :
1W7,5CRP Pubhcotion 30. !Jenite for lateke Gne extent permitted by resources,.
of Redesnuchdes by Werkers? adopted July -
eommen4, and approval procedures. In -
sere-
. Cepks of tlw Unlud Kingdom's desempt both esses, eve effort will be made to en eveneWe for inspecum as ecleeurn to publish rules no later then 12 SECY-eMe7A (relating 1o 10 CFR Part 30) months er noticing for public dead W as tees m me Commiseka's esament.
. Pubhc Document Room.1717 H Strwt NW, Although the procedures in part 11 of Washington.DC sesas The Untied Kinedom NUREC/BR-0083 include feet track -
documents er, evellebte for ule from: Her processing.the neture of the enticipeled :
Mejesty's Steuonery Ofhee. P.O. Don see, s
landon SEs SNH. United Kingdom, as Advice petitione so not fully comply with the document ASP-7 and a teleted technical decision criterie to follow this "P'"N "'sniheence d amou Dan d
. $,d euen 2 Memben d he pubhc." N alternetive d
Some of the key features of the
- Copia of the Canadie docunwnt en
,[ handling procedures include the evelleble for inspechen es en enclosure to a following steps for complete and fully SECY.e6-147 A (relehng 1010 CfR Port ao) y, ow supported petitions.
dated July as. Sees in the Commission's.
A 3 1.petitonore may confer on Pubhc Documut Room.1717 H Strwt NW, pi. r.1 matters with the etsff before W"hingen.DC auss.The Caudan paing H tition for rulemaking. Requests.
document was tesued as Consultetive to con er on procedural matters should Document C-e5. "The Basis for Exempting the !
be addreend to:The Director. Division Depoul of Certeln Radioactive Metenele
. of Rules and Records.' Office of from t.icensing" by the Atomic Energy i
I
- Administration, U.S. Nuclear Reguletory control soord.p.o. sex iose otuwe,
~
r - t L Commission, Washinston. DC 20555.
Onteno, Cenede. KIP $$e, z
'ICRP/e5/G-03. " Statement from the leos i Attention: Chief Rules and proceduree Perie Meeting of the Intemstienel Branch..
Commission on Radiologice Protect? See5-2.petitione should be eddressed to:
Ste.
a The Secretary, U.S. Nuclear Regulatory Commieston Washington DC 20555.
1' l
Attention:Docketmg and Service L
Branch. In keeping with 10 CFR 2.802(f).
l
.- petitioners will be promptly informed if
[
the petition meets the threshold requiremente for a petition for rulemaking in10 CFR 2.802(c) and can
- be processed in accordance with this.
i.
implementation plan. Ordinarily this L-I L
~ determinetion will be mede within 30 L
doye efter receipt of the petition.
L
- 3. Following thle determination. the tition will be noticed in the Federal stor for e public comment period of l
et est to days.
~ d.'!he petitioner will be provided copies of allcommente received.
scheduling infor: nation, and periodic
. status rep :rts.
The p?rcedures in NUREG/BR 0053 also inclee the process for deniel and f]
withdrew.: of petitions.
S:
-