ML20055D032
| ML20055D032 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Geoffrey Miller HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9007030124 | |
| Download: ML20055D032 (7) | |
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A9,,,,, #p June 29, 1990 CHAIRMAN The Honorable-George Miller Committee on Interior and Insular Affairs United States House of Representa?4ves Washington, D.C.
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Dear Congressman Mil.ler:
i As promised'in Chairman Carr's letter of June 22, 1990, I am providing the information and documents you reouested relative to the development of HRC's policy statement on below i
regulatory concern (BRC).
Enclosed are copies of the Commissioner notation votes on I
SECY-89-360; copies of all drafts of the policy statement developed since January' 1, 1990; a copy of IAEA Safety Series 89, " Principles for the Exemption of Radiation Sources and Practices from Regulatory Control"; and a list of all NRC
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professional staff who worked on the BRC policy since January 1, 1986.
Also enclosed is-a narrative which describes the staff's preparation of the BRC policy for Commission review.
The origin of the change in the individual dose criteria from-1 millirem to 10 millirem per year and the individuals involved in this aspect of the policy's evolution are addressed.
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.I trust that this information is fully responsive to your request.
Sincerely, 9-mes R. Curtiss Acting Chairman
Enclosures:
As stated FULI, TEXT ASCil SCAN cc:
Rep. Morris Udall Rep. Don Young f/
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_ DEVELOPMENT OF BRC POLICY STATEMENT 1
Three offices were involved in development of the BRC Policy Statement.
These were.the Office of Nuclear Regulatory Research (RES), the Office of Nuclear Materials Safety and Safeguards (NMSS), and the Office of Nuclear ReactorRegulation(NRR). At the time the proposed policy was developed
-in 1988, the Directors of these offices were, respectively, Mr. Eric Beckjord, Mr. Hugh Thompson, Jr., and Dr. Thomas E. Murley. The Office of Research had the lead for preparation of the policy statement, and NMSS and NRR provided technical support, and reviewed and concurred in the proposed policy. Mr. Beckjerd's principal advisor was Dr. Bill Morris, Director, Division of Regulatory Applications.
Dr. Morris directed Mr.
William Lahs Acting Chief of the Regulatory Development Branch, in the l-preparation of the policy. Dr. Themis Speis, one of the Depu.ty Directors of RES, also had oversight responsibility for the effort. Dr. Murley's principal advisor was Mr. Frank Congel, and Mr. Thompson's principal advisors were Mr. Robert Bernero, Mr. Richard Cunningham, and Dr. Donald Cool.
These individuals agreed that I millirem per year (mrem /yr) was an acceptable value for the individual dose criterion of the policy; that is, i
a dose level at which it could automatically be concluded that no further effort, including cost-benefit analysis, would be needed to reduce i
exposures.
In doing so, it was also agreed that exemptions could be granted on the basis of higher individual doses provided the dose was i
1 below the dose limits in 10 CFR Part 20 and was as low as reasonably achievable.
When the proposed policy in this form was forwarded to Victor Stello, Jr.,
then Executive Director for Operations, Mr. Stello called a meeting to discuss thq proposal. He questioned whether the proposed individual dose criterion value of 1 mrem /yr would provide sufficient flexibility in practical application of the policy.
The question of whether higher values, including 10 mrem /yr, would constitute a' threat to health and safety of the public was also discussed.
Some at the meeting thought that selection of dose criteria nearer 1 mrem /yr would be more consi5 tent with existing or proposed dose criteria of other organizatious both within and cutside the U.S. and hence IMs l
controversial as a policy element. At that meeting, the only possible safety basis for selecting 1 mrem over 10 mrem identified was the possibility that exposure to 10-mrem doses from multiple practices could result in doses approaching or perhaps exceeding the 100-mrem /yr public dose limit in proposed revisions to 10 CFR Part 20. However, no one could l
identify plausible ways for this to happen.
Mr. Stello directed the staff to modify the policy to adopt a 10-mrem /yr l
individual dose criterion. The Office of Research did this and transmitted the policy to NRR and NMSS for concurrence.
NRR concurred but Robert Bernero, Acting Director of NMSS in the absence of Mr. Thompson, wrote a memorandum to Mr. Stello expressing his concern that under the policy, exposure to sources of radiation for multiple exempted practices could lead to doses approaching 100 mrem /yr, the public dose limit in proposed 10 CFR 20. Mr. Bernero did not concur with the policy on i
that basis. A meeting was then held by Mr. Thompson with NMSS and RES in l
order to. understand the safety concern and, if appropriate, deveicp a revision to the policy that would resolve concern. A revision to the policy was developed which included specific policy elements, such as broad definition of practice, implementation of a collective dose criteria, and the commitment to review each exemption to assure that the effects of multiple practice were thoroughly evaluated prior to approval of a new I
practice. This change provided assurance that significant exposures to multiple practices would be unlikely. On that basis, Mr. Thompson concurred in the policy for NMSS, and Mr. Bernero and the other staff mentioned above also concurred.
It is worth noting that the final BRC policy is a further evolution of the numerical criteria that provides even greater protection than the proposed version of the policy.
!, I Li i
NRC PROFESSIONAL STAFF WHO HAVE WORKED ON THE BRC SINCE 19B6 EDO-James Taylor James Sniezek Hugh. Thompson Lidia Roche George _Pangburr Kathleen Black Mat Taylor VictorStello(leftAgency)
Research Donald Cool i
William Lahs Donald Hopkins
' Catherine Mattsen Shlomo Yaniv Frank Costanzi StanleyNeuder(leftAgency)
Eric Beckjord Themis Speis Clemens Heltemes Bill Morris-Zoltan Rosztoczy (sabbatical)
RobertAlexander(leftAgency)
James Malaro Alan Roecklein Carl. Feldman -
HMSS Robert Bernero Guy Arlotto
--Richard Cunningham-Glen Sjoblom
-John Austin John Hickey Regis Boyle Mike Bell (IAEA)
Leland Rouse (deceased)
Jerry Swift Ed Shum Chad Glenn Mike Lamastra Pat Vacca Cynthia Jones John Greeves Richared Bangart
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NRR Thomas Murley Frank Miraglia-Charles Willis Frank Congel-Lemoine Cunningham-John Buchanan Wayne Meinke (retired)
OllieLynch(leftAgency))
Ed Brannagan (left Agency Richard Starostecki _ (left Agency)
OGC William Parler Stuart Treby Jane Mapes Martin Malsch
' Robert Fonner Joseph Scinto Governmental and Public Affairs Harold Denton Sheldon Schwartz l
Carlton Kammerer Fred Combs Vandy Miller DonaldNussbaumer(retired)
Kathleen Schneider Cardelia Maupin Sprios Droggitis
.Rosetta Virgilio Office of Conaressional Affairs Dennis.Rathbun Tom Combs
'l Advisory Committee on Nuclear Waste Dade Moeller Martin Steindler William Hinze CliffordSmith(leftCommittee)
Richard Major Raymond Fraley Richard Savio-Owen Merrill (left Committee)
Regional Offices Region I
-Tim Martin 2
Malcolm Knapr Ron Bellamy Marlene Taylor Region II-I' Phil Stohr Doug Collins Bob Troj'enowski l
Region III-Carl Paperiello Chuck Norelius Cill Axelson Roland Lickus Region IV Bill Beach Bill Fisher Charles Hackney Region V Ross.Scarano Greg-Yuhas Dean Kunihiro g
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_ COMMISSION OFFICES Kenneth Carr Margaret Federline Michael Weber ^
Karen Cyr Stephen Burns George Felgate (left Agency)
L Thomas Roberts Maria Lopez-Otin Charles Ader Forrest Remick Rob MacDougall Brad Jones (left Agency)
Kenneth. Rogers Gail Marcus Susan Bilhorn James Curtiss l
Joe Gray-Kitty Dragonette Janet Kotra Lando Zech Dennis Rathbun
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Janice Dunn-Lee L
SECY Samuel Chilk John Hoyle l
Andrew Bates Ann Tipton I
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