ML20049H467
| ML20049H467 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1982 |
| From: | Mattson R Office of Nuclear Reactor Regulation |
| To: | Arsenault F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 8203030093 | |
| Download: ML20049H467 (3) | |
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q MEMORANDUM FOR:
Frank Arsenault, Director Division of Health, Siting and Waste Management,xRES FROM:
Roger J. Mattson, Director Division of Systems Integration, NRR
SUBJECT:
ADVANCE REVIEW OF ENO C0tNISSION PAPER We have reviewed the subject Coninission paper sent by R. B. Minogue memo to H. R. Denton dated January 11, 1982.
We agree that a revision of the EN0 criteria is the best alternative. We are concerned however, that there does not appear to be an adequate tech-nical basis for the proposed formulation of the health effects criterion involving the arbitrary squaring of the average dose to the population.
The approach contained in the earlier Peterson draft is more straightforward and would be more readily understood by the public.
Driginni Signed by,3 peger J. :!.attsog/
Roger J. Mattson, Director Division of Systems Integration DISTRIBUTION CCentral File _
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Division of Health, Siting and Waste Management, RES FROM:
Roger J. Mattson, Director Division of Systems Integration, NRR
SUBJECT:
ADVANCE REVIEW 0F EN0 COMMISSION PAPER
/
We have reviewed the subject Comission, paper sent by R. B. Hinogue memo to H. R. Denton dated January 11, 1982. /
l We note that Alternative 4 is somewhat inconsistent in that it states that, regarding expansion of criteria,,"(s)uch an expansion would require legis-lative action," but goes on to say that " legislative action should not be sought since the language of the ENO definition... permits resolution by NRC rulemaking." The wording should be changed to remove this apparent incon-sistency. This comment ha_s' been infonnally conveyed to 11. Peterson by F. Congel.
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In addition, we have serious reservations that the present draft represents an improvement over that outline in the earlier Peterson draft. We will initiate a meeting w'ith you within the next few days to discuss our concerns in more detail.
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Roger J. flattson, Director Division of Systems Integration
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i HD40RANDUM FOR: Robert B. Minogue, Director Office of Nuclear Regulatory Research /
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Roger J. Mattson, Director
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Division of Systens Integration, NRR
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SUBJECT:
REVIEW OF ENO COMMISSION PAPER /
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The Radiological Assessment Branch has reviewed the subject Commission paper sent to H. R. Denton by your menorandum dated January 11, 1982. Our comments appear below.
Our comments relate to Alternative 4. /This alternative is somewhat inconsistent in that it states that, regarding expansion of criteria, "(s)uch an expansion would require legislative action", but goes on to say that " legislative action should not be sought since the language of the EN0 definition... permits resolution by NRC rul anaki ng."
The wording should be changed to renove this apparent inconsistency.
This problen has been described'to H. Peterson by F. Congel.
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Roger J. Mattson, Director
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Division of Systons Integration
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