ML20058J082
| ML20058J082 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9011270216 | |
| Download: ML20058J082 (4) | |
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N0TATI0N V 0 T E_
RELEASED TO THE PDR *,
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sat 4UEL J. CHILK, SECRETARY OF THE C0t44ISSION FROM:
C0tHISSIONER CURTISS
SUBJECT:
SECY-90-322 - NRC COM4ENTS ON DRAFT CIRRPC POLICY REPORT ADDRESSING-TNE NEED FOR NARM REGULATION APPROVED w/ comments DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION C0tHENTS:
1 See attached comments.
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i Dr. Alvin L. Young, Chairman Comittee on Interagency Radiation Research and Policy Coordination-U.S. Department of Agriculture Administration Building, Room 321A 14th & Independence Ave., SW.
's Washington, DC 20250
Dear Dr. Young:
I am enclosing coments on the CIRRPC draft report, " Naturally Occurring and
~ Accelerator-Produced Radioactive Materials (NARM)," as requested in your June 6,1990 letter.- These coments were developed based on a review by and with the approval of Offices of the Comissioners and the Executive Director for.0perations of the Nuclear Regulatory Comission.
They therefore represent
.the Agency. position on the draft report.
We recognize the contribution by 'the CIRRPC working group to date in addressing issues'related to regulation of NARM and fully understand that resolution of our coments will entail considerable additional effort.4 CIRRPC's involvement in addressin the NARM issue is appreciated and we shall look Torward to timely '
completion o this important document.
Sincerely, i
Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research
Enclosure:
.CIRRPC Report Approval Form L
cc: Dr. William A. Mills, CIRRPC/URAU t
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NRC COMMENTS ON DRAFT CIRRPC POLICY REPORT ON " NATURALLY OCCURRING i
AND ACCELERATOR-PRODUCED RADIOACTIVE MATERIAL 5 (NARM)"
i General Comment
$hw M M is e;eested th the Comittee on Interagencf Radiation Research and Policy Coordination's (CIRRPC"s) draft Policy Report on\\ Naturally Occurring and Accelerator-Produced Radioactive Material (NARM)Abe revised to more clearly address the issues that originally prompted the Comission to refer the NARM issue to CIRRPC.
The report, when properly revised, would provide enhanced assurance that Federal radiation protection programs, in conjunction with State f
programs, adequately protect the public and the environment.
It would also l
provide a firmer basis for resolution of NARM issues at the Federal level.
To achieve this, the report must respond in a more definitive manner to items 2 and 3 of the scope of referral regarding the characterization of public health and safety or environmental concerns associated with discrete sources of NARM, Compared to earlier Federal and State efforts to characterize these concerns,-
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the Working Group report presents a more benign view of the radiation hazards associated with possession, use, and= disposition of discrete NARM sources.
CIRRPC should either refute the conclusions of these comprehensive studies on this subject or propose specific initiatives to improve public protection from the hazards associated with NARM.
In addition, it would be helpful to the Commission if the report discussed the nature of the risks associated with discrete sources of NARM and to the extent feasible, provided estimates of their. magnitudes.
Comparison with other risks associated with NRC regulated byproduct. source, and special nuclear materials would be useful in this regard.
^ Specific Comments ep p/of
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1.
Page 5, NARM Waste Disposal The' report states that EPA is developing regulations to require disposal of discrete radium' sources at low-level waste sites authorized under the Atomic 1
disp;;;d ef a;fely in pp.e. j Energy Act or at special NARM-waste disposal-sites..The Cristica sep;: rte EPA': - Hnrte ta re;eir: th:t th::: see-ebs er:
j pr3ata Msontal MH4ti;;, in;h;dir.; tE specia? "*"" ;;ste dispessi inuilitin.
. As a practical matter, h; rte-JdiscreteLNARM sources will probably(be disposed of in waste facilities licensed by NR7 under the Atomic Energy Act or by i
Agreement States);.If disposal in NR licensed sites is necessary, there will also be a neet'to establish standard or packaging, waste form,,long-term isolation, anc other aspects of NARM waste disposal to assure that these wastes do not constitute a hazard to the health and safety of the public and to assure that there is,no impact on the safe disposal of the AEA wastes at these sites. One approach would be for EPA to establish such standards.
We would appreciate CIRRPC's view on whether this is recommended or whether-other alternatives, short of broadening the Atomic Energy Act, can be identified.-
2_. Page 7, Control of Accelerator-Produced Radionuclides The report states that radionuclides produced by accelerators should be controlled to the same degree of protection as required for byproduct materials 1
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Earlier assessments of NARM, which were prepared by NRC and the CRCPD, relied on anecdotal infonnation to reach conclusions about the need for additional Federal regulatory control of discrete NARM sources.
The Comission concluded in 1988 that such information was not sufficient to merit proposals to Congress for expanding NRC's authority under the Atomic Energy Act to regulate discrete sources of NARM.
It was this type of anecdotal information about the risks posed by discrete NARM sources that motivated the Comission to refer the issue of NARM regulation to CIRRPC for characterization of the risks associated with NARM and appropriate designation of NARM responsibilities.
Based on the same types of anecdotal and incomplete information, the Working Group report on NARM reaches conclusions about the absence of hWth and safety concerns.
Further, the report does not characterize the public health signifi-cance of the mishandling of NARM materials, nor address environmental concerns associated with NARM.
Therefore, the report as written fails to respond to the heart of NRC's referral:
does the possession, use, or disposition of NARM pose risks to humans and the environment suffhient to warrant additional regulatory control at the Federal level. The report should be revised either to refute the conclusions of the earlier assessments of the risks associated with NARM materials or to propose specific initiatives to improve public protection from the hazards associated with NARM.
In addition, it would be helpful to the Comission if the report also discussed the nature of the risks associated with NARM sources and to the extent feasible, provided estimates of the magnitude of these risks.
5.
Page 9. Regulatory Infrastructure The report notes the existence of a substantial regulatory infrastructure for protecting the public health and safety from radiation sources under the Atomic Energy Act and other authorities. The report also states that this infrastruc-ture is necessary and sufficient to control NARM sources. These two observations would seem to suggest that public health and safety could be benefited by expanding t,% hk u;rg ut to pr=He uof Hth =therity te certrel "%
tmdeethe same regulatory infrastructure that already exists for other radio-active materials. However, the report concludes that no such expansion is necessary. The eport should be revised to provide a basis and rationale for this conclusion and specifically indicate how the existing infrastructure is achieving the acessary and sufficient level of control of NARM sources.
6.
Page 10 Definition of Discrete Sources The first ask of the scope of referral to CIRRPC was to "... develop a defini-tionofdscretesourcesof[NARM]thatmightberegulatedbytheFederal Governme t."
In response, the Working Group developed a characterization of l
discret sources of NARM which uses the terms " source," "radionuclide component,"
and "s/gnificantly above background levels."
For example, using this defini-tion,/gypsumwallboardandotherhigh-volume, low-activitysourcescouldbe defiried as a discrete source of NARM, yet most Federal agencies would not ger)crally consider such items to be discrete sources. We believe that the report should be revised to provide a definition or characterization of discrete ources of NAR" t%t can be the basis for attaining consistency in future actions and de o 1ons related to NARM regulation.
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