ML20054C739
| ML20054C739 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1982 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-6 NUDOCS 8204210584 | |
| Download: ML20054C739 (3) | |
Text
Wm-4 P Ort Distribution: WM-82-103 3402.1/SAS/82/03/15/0 A MHL file WMHL r/f gg-h WM r/f p p 3 1982 NMSS r/f
/)SM JBMartin 6 p yy WMHL: 3402.1 REBrowning MJBell SASilling & r/f MEMORANDUM FOR:
Ralph G. Page, Acting Chief MRKnapp Uranium Fuel Licensing Branch LWRossbach Division of Fuel Cycle and Material Safety HJMiller J0Bu N
FROM:
Michael J. Bell, Chief p
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SUBJECT:
COMMENTS ON PROPOSED SAFETY G0AL l
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\\Q InresponsetoJohnDavis'requestthattheWasteManagemenkDivision staffreviewtheCommission'sproposedpolicystatementonaafetygoal$g for nuclear reactor accidents, we offer the following comments.
We believe that the policy statement is an important step toward realistic handling of risk.
If the philosophy expressed in the policy statement is publicly accepted, a comprehensive and rational risk management program will be encouraged.
We see no reason why nuclear power plant accidents should be the only sources of risk which may be managed according to a safety goal.
However, if a safety goal is to be developed for the fuel cycle it should not be bound by the numerical criteria or format proposed for nuclear power plant accidents. Since the releases of radioactive materials from waste management facilities are expected to be much smaller than those from reactor accidents, but may persist for much longer periods of time, a different approach to setting safety goals may be appropriate.
We have examined ways of adapting the proposed safety goal to high-level waste disposal. Our conclusions were that there are reasonable ways of t
applying the proposed safety goal to high-level waste, and that this goal is achievable. However, there are other areas of the fuel cycle in which levels of risk consistent with the proposed safety goal for reactor accidents may not be achievable by current practices.
Some concern has been raised atout what form should be used in expressing what is an acceptable risk. Alternative means of phrasing a safety goal DIST:
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" might include maximum dose commitments expressed as man-rem or as a fraction of natural background dose.
It is possible to derive dose limits which are equivalent to the risk limits stated in the safety goal.
The proposed safety goal uses the ALARA concept.
We think that this-concept may make sense in the context of an existing technology, such as commercial nuclear power generation.
However, it is not clear whether ALARA could be applied to a developing technology, such as high-level waste disposal, since it is very difficult to determine what " reasonable achievability" is, in the absence of experience.
During their review of the proposed technical criteria in 10 CFR 60, the Commission decided not to apply the ALARA concept to high-level waste disposal, but asked for public comment on this issue.
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MICIUa1 y, h75 Michael J. Bell, Chief High-Level Waste Licensing Management Branch Division of Waste Management i
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3402.1/SAS/82/03/15/0 fraction of natural background dose.
It is possible to derive dose limits which are equivalent to the risk limits stated in the safety goal.
Scientifically, there is little difference between the two approaches.
The proposed safety goal uses the ALARA concept. Weyh hat this conceptmakesgoodsenseinthecontextofanexist/ngtechnology,such as commercial nuclear power generation. However,/1t is not clear whether ALARA could be applied to a developing technolog,y, such as high-level waste disposal, since it is very difficult po' determine what " reasonable achievability" is, in the absence of experience. During their review of the proposed technical criteria in 10 CFR 60, the Commission decided not to apply the ALARA concept to high-levsl waste disposal.
Perhaps a criterion on the cost-effectiveness 4f a design change could be adopted in a safety goal on the fuel cycle Finally,webelievethatsomew[yofreflectingsociety'sriskaversion should be adopted in the safety goal.
It is clear that society is more afraid (perhaps wit.1 good reason) of a large accident than a number of smaller ones which cause the same number of deaths.
This risk aversion was addressed in NUREG-0739, and the reasoning behind not addressing it in the safety goal is_not adequately explained in the Discussion Paper.
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Michael J. Bell, Chief
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High-level Waste Licensing fianagement Branch
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Division of Waste Management
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