ML20125C458
| ML20125C458 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1992 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9212110199 | |
| Download: ML20125C458 (3) | |
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. RELEASED TOTHE POR 8 NOTATION ,,
V0TE:: _474:/M deter
- 6 E e m o m o n . . n .inuras ... 4,.e T0: SAMUEL J. CHILK, SECRETARY OF THE COWISSION l i
i i FROM: C0mISSIONER CURTISS ,
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SUBJECT:
SECY-92-238 - FINAL TECHNICAL POSITION ON i
ALTERNATE CONCENTRATION LIMITS FOR TITLE II i URANIUM MILLS X/in x/in APPROVED part DISAPPROVED Pa"t ABSTAIN l _
( NoT PARTICIPATING _ .. REQUEST DISCUSSION l C0tHENTS:
{ See attached comments.
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t 9212110199 920819 *iwtq k COMMS NRCC PDR SIGNATURE j
CORRESPONDENCE PM
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RELEASE VOTE /X / August 18, 1992 DATE r)
WITHHOLD VOTE / /
i 090058 k(r[jk ENTERED ON "AS" Yes x- NO qq
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Commissioner Curtiss' comments on SECY-92-238:
, The final Alternate Concentration Limit (ACL) guidance document in the subject SECY paper repr6sents a significant and important milestone that I trust will be useful to both staff and licensees in the implorantation of the uranium mill tailings regulatory regime. I commend the staff for the work that has gone into this
. effort. I do, however, have one significant concern with the -
guidance docuuent. The approach recommended by the staff for i evaluating proposed ACLs explicitly endorses a risk level of 1E-6
. lifetime (approximately 1E-8 annual) for potential exposures to members of the public from the consumption of groundwater, with licensees given the option of justifying risks in the range of l 1E-4 to 1E-6 lifetime (approxicately 1E-6 to 1E-8 annual). I am 4 not prepared to endorse these risk levels as a basis for
- evaluating the acceptability of proposed ACLs. Instead, I i believe that decisions on potential risks to members of the public should be based on the following approach
In making the required finding that a proposed ACL does not represent a substantial present or future hazard to human health when use of groundwater for drinking
- purposes must be considered, as well as in determining
- that the proposed ACL is ALARA, a demonstration that the combined risks from the radiological and nonradiological constituents is equivalent to the risks
! for memters of the public in 10 CFR Part 20 represents a reasonable upper bound. Recognizing that a 50 millirem per year dose is used to calculate permissible concentraticns for unrestrict^d releases to air and r water in revised Part 20, this 50 millirem dose would represent an annual individual risk of about 3E-5.1 A
- reasonable lower bound for ALARA efforts would be an annual individual risk of IE-6, if it is determined i that achieving this level would be cost-beneficial, i
The risk reduction that would be achieved with an annual risk standard of 3E-5 for ACLs is, in my view, sound and defensible
- when compared to other radiological risks already subject to existing regulations. In particular, this approach is consistent 4 not only with 10 CFR Part 20, but with EPA's fuel cycle standards in 40 CFR 190, as well as with NRC's regulations in 10 CFR Part
- 61 for low-level waste facilities. Moreover, further reductions beyond this level will not, in my view, result in a substantial reduction of significant risk to the public health and safety and the environment. Accordingly, I would recommend that the discussion of risks in the guidance document be deleted and the foregoing inserted in lieu thereof. The analysis of comments '
should be revised accordingly. EPA should be c.dvised of this i i Assuming a risk conversin" factor of SE-4 per rem.
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