ML20062F324
| ML20062F324 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1990 |
| From: | Rogers K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9011270212 | |
| Download: ML20062F324 (4) | |
Text
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u..^...................a RELEASED TO THE PDR V 0 $ E/ p/90 NOTATION I
lLE S P_ 0 M M T0:
SAMUEL J. CHILK, SECRETARY OF THE COMMISSION i
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C0MISSIONER-ROGERS i
SUBJECT:
SECY-90-322 - NRC C0044ENTS ON DRAFT CIRRPC POLICY REPORT ADDRESSING THE NEED FOR NARM REGULATION APPROVED e. U -u DISAPPROVED ABSTAIN n
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NUCLEAR REGULATORY COMMISSION wAsHINOTON, D. C. 20606 I.
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l Dr. Alvin L. Young, Chairman Cosmiittee on Interagency Radiation Research and Policy Coordination U.S. Department of Agriculture Administration Building, Room 321A 14th & Independence Ave., SW.
Washington, DC 20250
Dear Dr. Young:
I an enclosing comments on the CIRRPC draft report, " Naturally Occurring and Acceleratoo Produced Radioactive Materials (NARM)," as requested in your June 6, 1990 letter.
These comments were developed based en a review by and I
with the approval of Offices of the Commissioners and the Executive Director for Operations of the Nuclear Regulatory Commission.
They therefore represent l
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 comments will entail considerable additional effort.gCIRRPC's involvement inaddressingtheNARMissue.h
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Sincerely, ps vr.
Bill M. Morris, Director N.N Division of Regulatory Applications Office of Nuclear Regulatory Research l
Enclosure:
CIRRPC Report Approval Form cc: Dr. William 4. Mills, CIRRPC/0RAU l<t" t
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f NRC COMMENTS ON DRAFT CIRRPC POLICY rep 0RT ON ' NATURALLY OCCURRING AND ACCELERATOR-PRODUCED RADI0 ACTIVE MATERI AL5 (MARM)"
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General Conenent and Policy It is requested that the Committee on Interagency Radiation Researc and Coordination's (CIRRPC's) draft Policy Report on Naturally occurrin clearly Acce!cistor-Produced Radioactive Material (NARM) be revised to no Wdress the issues that originally prompted the Cosmiission to refel the NARM The report, when properly revised, would provide';&:::"
issue to CIRRPC.
C ;r i.ee t..t Federal radiation protection programs, in conjunction with State It would also programs, adequately protect the pubitc and the environment.
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 arsociated with discrete sources of NARM.
Compared to earlier Federal and State efforts to characterize these concerns, the Working Group report presents a '.aore benign view of the radiation hazards I
j associated with possession, use, ard disposition of discrete NARM sources.
CIRRPC should eitne refute the conclusions of these comprehensive studies on this subject or propose toecifia 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.
b Specific Comments p
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1.
Page 5. NARM Waste Disposal h The report states that EPA is developing regulations to require dis posal of
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discrete radium sources at low-level waste sites authorized 'ander tie Atomic z 4e...., C/AURission,_ supports The Energy Act or at special NARM-waste disposal sites.
a _...,.... v. m EPA's efforts tor c'r: tt:t it.... wun...
v rise dis = 1-feciliti;;, irci;dir.; 5 special NARM vaste disposal facilities.
As a practical matter, however, discrete NARM sources till probably(be dispose or by of in waste facilities licensed by NRC under the Atomic Energy Act If disposal in NRC licensed sites is necessary, there will 1
AgreementStates).
also be a need to establish standards for packaging, waste form, long-term isolation, and other aspects of NARM waste disposal to assure that these l
wastes do not constitute a hazard to the health and ofety of the public and to assure that there is no impact on the safe disposal F the AEA wastes at l
these sites. One approach would be fce EPA to establic such standards.
We would appreciate CIRRPC's view o'. whether this is tecomunended or whether other alternatives, short of broadening the Atomic Energy Act, can be identified.
2.
Page 7. Control of Accelerr. tor-Produced Radionuclides The report states that radionoclides 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 information to reach conclusions about the need for additional Federal regulatory control of discrete NARM sources. The Commission concluded i
l 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 ty a of anecdotal information about the risks posed by discrete NARM sources tiat motivated the Coumission to refer the issue of NARM regulation to CIRRPC for characterization of the risks associated with i
NARM and appropriate designation of NARM responsibilities.
gs Based on the same types of anecdotal and inconglete informa on, the Working Group report on NARM reaches conclusions about the absence f health and safety concerns.
Further, the report does not characterize the blic health signifi-cance of the mishandling of NARM materials, nor address nyironmental concerns associated with NARM.
Therefore, the report as written da,44e-4e> respond to the heart of NRC's referral:
does the possession, use, or disposition of NARM pose risks to humans and the environment sufficient to warrant additional regulatory control at the Federal level. The report should be revised either to refute l
the conclusions of the earlier assessments of the risks acociated with NARM materials or to propose specific initiatives to improve public pantaction from the hazards associated with NARM.
In addition, it would be helpful to the Cosnission 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.
i 5.
Page g. Regulatory infrastructure The report notes the existence of T 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 necessaiy and sufficient to control NARM sources.
These two observations would seem to suggest that public health and safety could be benefited by expanding the Atomic Energy Act to provide NRC with authority to control NARM under the same regulatory infrastructure that already exists for other radio-active materials. However, the report concludes that no such expansion is The report should be revised to provide a basis and rationale for necessary.
this conclusion and specifically indicate how the existing infrastructure is
- chieving the necessary and sufficient level of control of NARM sources.
6.
Page 10. Definition of Discrete Sources The first task of the scope of referral to CIRRPC was to "... develop a defini-that might be regulated by the Federal tion of discrete sources of [NARM] king Group developed a characterization of Government."
In response, tie Wor discrete sources of NARM which uses the terms "sourck," "radionuclide component,'
and "significantly above background levels."
For example, using this defini-tion, gypsum wall board and other high-volume, low-activity sources could be defined as a discrete source of NARM, yet most Federal agencies would not generally consider such items to be discrete sources. We believe that the report should be revised to provide a definition or characterization of discrete sources of NARM that can be the basis for attaining consistency in future actions and decisions related to NARM regulation.
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