ML20125C455
| ML20125C455 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/1992 |
| From: | Remick F NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9212110198 | |
| Download: ML20125C455 (2) | |
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RELEASED TO THE POR 1
R_0TATION VOTE:
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CESPONSE_SilEEI E ~ J h........in] If C j l
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SAMUEL J. CHILK, SECRETARY OF THE COMISSION l
FROM:
COINISSIONER REMICK
SUBJECT:
SECY-92-238 - FINAL TECHNICAL POSITION ON I
ALTERNATE CONCENTRATION LIMITS FOR TITLE II i
URANILH MILLS APPROVED /OmOfftb OISAPPROVED F W 90ABSTAIH _
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Nor PARTICIPATING REQUEST Discussion l
l COMMENTS:
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9212110198 920904 d'YM
'41I'( ' G fI PDR COMMS NRCC SIGNATURE c<.s Ecya m e,L/fA CORRESPONDENCE PDR RELEASE VOTE
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0I e I, M W DATE-O WITHHOLD VOTE
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ENTERED ON "AS" YES /
NO
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ppgdgsionpr Reqlgyds Conments Qn SECY-92-2388 i
I approve the publication of L'nclosure 1 to SECi-92.-238 as a staff technical position on the methodology for the licensee to j
prepare and the NRC staff to review Alternate Concentration Limit (ACL) applilations for Title II Uranium Mills subject to l
incorporation of the following comments.
on page 27 of the proposed staff technical position, the statement is made that " Generally, a lifetime risk level of 1 x i
10 6 is utilized; howe'"ar, an alternate risk level in the range of 1 x 10 6 to 1 x 10" may be utilized...."
I am not persuaded that Title II uranium Iaills have to be reduced to this level of risk to be found acceptable from a public health and safety standpoint.
Based on a risk coefficient of 5 x 10
per person-rem, the lifetime risk level of 1 x 10 set forth in 4
the staff's technical position would be equivalent to about 0.02 i
mrem per year.
Such a standard is inconsistent with other safety standards established by the. NRC in 10 CPR.
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I believe that an annual individual risk level on the order of i
10*5 to 10 4 lifetime risk level of approximately 4)per year (i.e.,
10'3 to 10 would be an appropriate level for Title II uranium mills.
Therefore, I propose that the risk levels set forth on page 27 of the staff's technical position be deleted and that ACLs be calculated so as to be consistent with doses to the public that are acceptable under 10 CFR Part 20 or Part 61.
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