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) | |
Text
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3 RELEASED TOTHE POR 8
NOTATION V0TE: _474:/M
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deter e m o m o n.. n.inuras 4,.e T0:
SAMUEL J. CHILK, SECRETARY OF THE COWISSION l
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i FROM:
C0mISSIONER CURTISS i
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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 l
APPROVED part DISAPPROVED Pa"t ABSTAIN
(
NoT PARTICIPATING _..
REQUEST DISCUSSION l
C0tHENTS:
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See attached comments.
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9212110199 920819
- iwtq PDR COMMS NRCC
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SIGNATURE CORRESPONDENCE PM j
RELEASE VOTE
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August 18, 1992 DATE r)
WITHHOLD VOTE
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090058 ENTERED ON "AS" Yes x-NO qq
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I 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 evaluating proposed ACLs explicitly endorses a risk level of 1E-6 i
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 not prepared to endorse these risk levels as a basis for 4
evaluating the acceptability of proposed ACLs.
Instead, I believe that decisions on potential risks to members of the i
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 not only with 10 CFR Part 20, but with EPA's fuel cycle standards 4
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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