ML20044A556
| ML20044A556 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1990 |
| From: | Roberts NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006290205 | |
| Download: ML20044A556 (3) | |
Text
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AFF1RMATION 4 0 *M " " * " * " * " * " '
REL EASED TO THE PDR RESPONSE. SHEET !6 4 7/9o d'
- .....a. <..........
TO:
SAMUEL J. CHILK, SECRETARY OF THE C0tNIssION FROM:
COR4ISSIONER ROBERTS
SUBJECT:
SECY-89-360 - COR4ISSION POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL APPROVE 9 x
DISAPPROVED ABSTAIN l
NOT PARTICIPATING REQUEST DISCUSSION COR4ENTS:
1 agree with the Chairman's revised Below Regulatory Concern Policy Statement.
I do recommend that it be modified at places to clarify that the BRC individual dose criteria is 10 mrem with an interim 1 mrem for widespread use practicet.
(See for exemple the attached pp. 2 and 28.) f g N
SI NAT E
h 60 [0
' DATE '
[g06 ENTERED ON "AS" YEs NO ms= :er i,
CORRESPONDENCE PDC
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i statement, NRC intends to exempt specific practices from regulatory control if the practice results in small doses to individuals and the population at large and if available controls l
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cannot achieve reductions in these doses that are commensurate with the public and private resouress needed to implement the y
controls.
The policy statement defines the dose criteria and d,
e e
other considerations that will be used by NRC in making exemption g
decision *-
ThepolicyestablishesindividualdosecriteriaA(1
-[
o mrem per yeag(0.01 and 0.1 millisieverts per year')) and a and collective dose criterion (1000 person-rem per year (10 person-Sieverts per year)).
These criteria, coupled with other considerations enumerated in the policy statement, will be najor factors in the Commission's determination on whether exemptions from regulatory controls will be granted.
The policy statement is needed to establish a consistent risk framework for regulatory exemption decisions, to ensure an adequite and consistent level of protection of the public in their u9e of radioactive materials, and to focus the Nation's resources on reducing the, most significant radiological risks from practices under NRC's jurisdiction.
The average U.S. citizen should benefit from implementation of the BRC policy through (1) timely cleanup of contaminated sites; (2) increased assurance that adequate funds are available to decommission operat...sg nuclear facilitiest (3) potential improvements in medical treatment and other services that use radioactive materials resulting from optimal use of Federal, State, and licensee resources; (4) enhanced low-level kadioactive waste management practices commensurate with
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potential risks; and (5) increased assurance that consumer l
- 1. ' '
l j
Table 1 i
Hypothetical Hypothetical Incremental Incremental Lifetit : Risk From
{
Annual Dosa*
Annual Risk **
Contintina Annual Dese**
100 mram (1 mSv) 5 x lo*S 3.5 x 10'3 4
4 10 area (0.1 mSV) 5 x 10 3.5 x 10 1
arem (0.01 mSv) 5 x 10's?
3.5 x 104 5 x 10-3.5 x 10 0.1 arem (0.001 mSV)
- The expression of dose refers to the Total Effective Dose Equivalent.
This term is the sum of the deep (whole body) dose equivalent for 1
sources external to the body and the committed effective (whole body) dose equivalent for sources internal to the body.
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- Caleglated using a conservative risk coefficient of 5 x 10 per rem
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(5 x 10' per SV) for low linear energy transfer radiation based on the results reported in UNSCEAR 1988 (Footnote 2) and BEIR V (see also NUREG/CR-4214, Rev. 1).
l In view of the uncertainties involved in risk assessment at low doses.and taking into account the aforementioned risk and dose perspectives, the Commission finds that the average dose to individuals in the critical group should be seme-then 10 mram per er kt6 yearg (0.1 mSv per year) for each exempted practice.
In addition, an interim dose. criterion of 1 mrom per year (0.01 mSv per year) average dose to individuals in the critical group will be applied to those practices involving widespread distribution of radioactive ma':erial in such items as consumer products or recycled mate?tial and equipment, until the commission gains more experie. ice with the potential for individual exposures from multiple licensed and exempted practices.
These criteria provide m
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