ML20058N474
| ML20058N474 | |
| Person / Time | |
|---|---|
| Issue date: | 01/30/1990 |
| From: | Curtiss NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9008140153 | |
| Download: ML20058N474 (2) | |
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RELEASED TO THE PDR
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RESPONSE SHEET Initials
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TO:
SAMUEL J. CHILK, SECRETARY OF THE COMISSION
'FROM:
COW 4ISSIONER CURTISS
SUBJECT:
SECY-89-370 MODIFIED. POLICY FOR HOT PARTICLE' EXPOSURES
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t APPROVED X/with DISAPPROVED ABSTAIN-i y
comments
.NOT PARTILIPATING REQUEST DISCUSSION COW 4ENTS:'
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I, See attached comments.
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1/30/90 DATE WITHHOLD. VOTE
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1 CORRESPONDENCE PDC
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Commissioner Curtiss' comments on SECY-89-370:
I do not object to the issuance of the changes to our enforcement policy for hot particle exposures that the staff has proposed in SECY-89-370.
My approval of staff's proposal, however, should not be read as an agreement with the staff's arguments and assertions about compliance with the backfit rule.
I do not believe that the backfit rule even applies to changes in NRC enforcement policy such as the one proposed here.
The staff should carefully examine the final recommendations of the NCRP and ICRP as soon as they become available, particularly with regard to which health effects, from the standpoint cf risk, should serve as the basis for hot particle exposure limita and what available data suggests are appropriate exposure limits to prevent or limit the risk associated with such health effects.
Further, these recommendations should be considered in light of the negative impact on ALARA practices, and hence radiological risk, that accompany licensee personnel survey activities necessitated by hot particle exposure limits.
If as a result of these activities the staff concludes that some further adjustment to the NRC enforcement policy for hot particle exposures is justified, the staff should propose such adjustments as soon as practicable and not wait for completion of rulemaking on the subject.
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