ML20128F718

Summary of 960906 Meeting W/Crcpd Norm AC in Charleston,Sc to Elicit Comments & Discussion from AC on Most Recent Draft of Part N of CRCPD Suggested State Regulations for Control of Radiation

ML20128F718
Person / Time
Issue date:	09/27/1996
From:	Fauver D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-3 NUDOCS 9610080183
Download: ML20128F718 (4)

Text

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k UNITED STATES NUCLEAR REGULATORY COMMISSION C

WASHINGTON, D.C. 20555 0001 o

g September 27, 1996 MEMORANDUM TO: Michael F. Weber, Chief k

Low-Level Waste and Decomissioning Projects Branch i

Division of Waste Management, NMSS i

p David N. Fauver, Senior Project Man d i N ""

FROM:

/

Materials Decomissioning Section i

Division of Waste Management, NMSS 1

SUBJECT:

MEETING SUP91ARY: SEPTEMBER 6, 1996, MEETING OF THE CRCPD NORM ADVISORY COMMITTEE The meeting of the CRCPD NORM Advisory Comittee convened in Charleston, South Carolina, at 8:30 a.m. on September 4, 1996, and adjourned at 12:30 p.m. the j

same day. The unanimous decision to adjourn early was compelled by the impending landfall of Hurricane Fran.

The NORM Advisory Comittee is comprised of representatives from industry, State government, the Department of Energy, the Environmental Protection Agency, and the Food and Drug l

Administration (see attached attendance list).

}

The original purpose of this meeting was twofold: 1) to elicit comments and i

discussion from the Advisory Comittee on the most recent draft of Part N of i

the "CRCPD Suggested State Regulations for the Control of Radiation," and provide feedback to the CRCPD NORM Commission, which has responsibility for i

drafting Part N; and 2) to convene a second meeting, attended by the NORM Commission members only, to consider the input from.the Advisory Comittee and begin drafting the revised Part N.

The schedule called for two days for each part of the meeting.

I The half-day that the Advisory Comittee ended up meeting was mostly spent discussing the broad topic of what regulations, standards, and guidance should be considered in the development of Part N.

The standards suggested for consideration include:

.l 100 mres/yr (10 CFR Part 20, ICRP) 1 15 mres/yr (proposed decomissioning rule) 10 mres/yr (NESHAP) 5/15 pCi/g Ra-226 (UMTRCA) 30 pCi/g Ra-226 and 20 pCi/m'/s radon emamantion (proposed Oklahoma state reg).

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4 pCi/1 radon (EPA indoor mitigation level) i 500 mres/yr (NCRP 116)

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other misc Mk After discussing the pros and cons of these various standards, the majority of the advisory Committee seemed to support a dose / risk-based standard as opposed to the concentration-based standard in the current draft of Part N.

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9610000183 960927 PDR WASTii WM-3 PDR

d M. Weber l appeared to be supported by Ray Paris. However, the dose / risk standard to use

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was not agreed upon. The industry representatives spent some time discussing the merits of the 500 mrem /yr limit (NCRP 116), but in the end it appeared that most of the committee members conceded the inevitability of the dose standard being 100 mrem /yr or less.

Ray Paris indicated that he was going to reschedule the NORM Commission meeting to draf t a new Part N, essentially starting with a blank sheet of paper, that would be dose-based as opposed to concentration-based.

There were also some discussions about the scope of draft Part N.

In light of recent discussions within NMSS regarding the definition of source material, j

and NRC's regulation of source material, it is interesting to note that the draft Part N currently states that "the presence of source material within any i

substance shall not constitute an exemption from this part for NORM therein contained unless the material meets the criteria for classification as a source material." Apparently, draft Part N would regulate source material meeting the unimportant quantity definition in 40.13(b), based on the presence 4

of Ra-226, notwithstanding the presence of uranium and thorium.

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Attachment:

As stated i

3 i

i a

i

2 o

i SEPTEMBER 6, 1996, MEETING OF CRCPD NORM ADVISORY COMMITTEE q

j ATTENDANCE LIST I

Greg Crinion Walter Cofer Jackson & Walker CRCP0 Norm Commission Michael Kletter William Russo Dupont U.S. EPA Office of Radiation and Indoor Air W. S. Geiger l

IMC-Agrico Co.

Edward A. Tupin Norm Commission i

C. E. Roessler Center for Devices and Radiological l

Private Consultant Health l

Food and Drug Administration f

David S. Gooden Thomas Cardwell Dir., Biomedical Physics l

Texas Dept. of Health Saint Francis Hospital Bureau of Radiation Control Radiation Management Advisory Council, OK 3

Michael T. Ryan i

i Chem-Nuclear Corporation David Bernhardt Rogers & Assoc. Engineering James E. Hickey CRCPD Consultant Ken Alkema(

Envirocare of Utah i

Max Scott LA State Center for Energy Studies Jon Richards U.S. EPA, Reg. IV, Radiation Office Anthony J. Thompson Shaw, Fittman, Potts & Trowbridge Alexander Williams 3

(for Nat'l Mining)

Department of Energy i

Lew Cook Chevron Research & Technology Co.

David Fauver U.S. Nuclear Regulatory Commission Sam Finklea Office of General Counsel SC DHEC Tom Amidon New Jersey Bureau of Environmental Radiation Ray Paris CRCPD Norm Commission, Chairperson Oregon State Health Division Attachment

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M. Weber ;

appeared to be supported by Ray Paris.

However, the dose / risk standard to use was not agreed upon. The industry representatives spent some time discussing the merits of the 500 mrem /yr limit (NCRP 116), but in the end it appeared that most of the committee members conceded the inevitability of the dose standard being 100 mrem /yr or less.

Ray Paris indicated that he was going to reschedule the NORM Commission meeting to draft a new Part N, essentially starting with a blank sheet of paper, that would be dose-based as opposed to concentration-based.

There were also some discussions about the scope of draft Part N.

In light of recent discussions within NMSS regarding the definition of source material, 4

and NRC's regulation of source material, it is interesting to note that the draft Part N currently states that "the presence of source material within any substance shall not constitute an exemption from this part for NORM therein contained unless the material meets the criteria for classification as a source material." Apparently, draft Part N would regulate source material meeting the unimportarit quantity definition in 40.13(b), based on the presence of Ra-226, notwithstanding the presence of uranium and shorium.

Attachment:

As stated af b c; /L,

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DISTRIBUTION: Central File LLDP r/f NMSS r/f PUBLIC MA JSurmeier RNelson LBell CPaperiello rne F%

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