ML20055J226
| ML20055J226 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9008010221 | |
| Download: ML20055J226 (2) | |
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N0TATI0N V,If Yd' EASED TO b PDR '.
RESPONSE SHEET 7/st 7/9o 4
.....% <............ ps ini TO:
SAMUEL J. CHILK, SECRETARY OF THE COMMISSION l
FROM:
C0lHISSIONER CURTISS
SUBJECT:
SECY-90-169 - MODIFIED ENFORCEMENT POLICY l
FOR HOT PARTICLE EXPOSURES - REVISION T0 i
INCORPORATE RECOMENDATIONS MADE TO NCRP i
REPORT NO. 102
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i APPROVED DISAPPROVED x
ABSTAIN NOT PARTICIPATING RaousST DISCUSSION L
j COMENTS:
See attached comments.
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i Commissioner Curtiss' comments on SECY-00-iGO:
I disapprove 4 the proposed modification of the NRC Enforcement Policy for " hot particle" exposures and would have instead preferred adopting the staff proposal in SECY-89-370,as an int. erin measure for the follcaing reasons:
There remains a lack of consensus within the health physics e
community and there has yet to be an appropriate opportunity for public comment on the significant question of what nonstochastic effect(s) of potential health consequence should be prevented through hot particle exposure limits.
This would suggest that an interim policy concerning hot particle exposures should be targeted at preventing any such effects and should consider the uncertainties associated with available data.
-c Notwithstanding the above, the NCRP recommendations upon e
which the proposed enforcement policy revision is based are unclear as to exactly what nonstochastic effects the proposed limits are intended to prevent (itat the qualitative distinction between acute " deep" ulceration vs.
acute " superficial" ulceration presented in NCRP Report No.
106 is vague).
Additionally, the health risk estimates for hot particle exposures causing acute deep ulceration (the nonstochastic effect which purportedly can occur at or above the proposed exposure limits) are based upon what the NCRP characterizes as incomplete data, While the area of skin exposed to radiation from hot e
particles is, as the ACRS has suggested, a central issue, there are technically sound alternatives to establishing an upper limit on hot particle size and the proposed Imm limit l
appears to be arbitrary (i.e. Why should different limits i
apply to exposures to radioactive particles with a largest dimension of 1.1mm?)
e If strictly enforced, the required assumption that a hot particle found on a person was in direct contact with the skin throughout the possible irradiation period may be unrealistic, overly restrictive, and will tend to nullify any potential ALARA benefit that the revised policy might have with respect to reducing personnel survey frequencies.
As discussed in Enclosure 3 to SECY-90-169, Item 3.,
the e
NCRP recommendations appear to be internally inconsistent.
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