ML20128H744
| ML20128H744 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Fraley R Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20127A006 | List: |
| References | |
| FOIA-85-3 NUDOCS 8505300623 | |
| Download: ML20128H744 (6) | |
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IOl93 MEMORANDUM FDR: R. G. Fraley, Executive Director Advisory Comnittee on Reactor Safeguards FRON: William J. Dircks -
Executive Director for Operations StBJECT ACRS SUBCOPNITTEE REPORT ON TRANSPORTATION REGULATIONS This is in response to your memorandum dated August 11,1983 enclosing the cossents of the ACRS Subconcittee on Reactor Radiological Effects on the radiological aspects of the transportation regulations in 10 CFR Part 71.
Enclosed are staff' responses to the Subcommittee's comments. The responses generally reflect our realization that in these days of diminished staff and other resources we must carefully choose our tasks and priorities because we cannot accouplish all worthy objectives.
William J. Dircks Executive Director for Operations
Enclosure:
Staff responses to ,
ACRS comments EDO-13427 RES-001928 ,
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EMORANDlM FOR: R. G. Fraley, Executive Director Advisory Comnittee on Reactor Sateguards FROM: William J. Dircks Executive Director for Operations SUBJECT ACRS SUSC0144ITTEE REPORT ON TRANSPORTATION REGULATIONS This is in response to your memorandum dated August 11,1983 enclosing tne comments of the ACRS Subconnittee on Reactor Radiological Effects on the radiological a:pects of the transportation regulations in 10 CFR Part 71. .
Enclosed are staff responses to the Subcommittee's comments. The responses generally reflect our realization that in these days of diminished staff and other resources we must carefully choose our tasks and priorities because we'cannot accomplish all worthy objectives.
William J. Di ks
. Executive Director for Operations
Enclosure:
Staff responses to ACRS comments ED0-13427 RES-001928
. Distribution:
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,, Staff Responses to ACRS Coments ACRS Coment No.1 There is apparent ' confusion and ambiguity in the interpretation of current NRC regulations relative to dose limits for tne public ;
(10 CFR 20.105). Althougn Subcomittee members thought that everyone
- agreed. on a limit of 500 mrem /y for the maximally exposed individual members of tne public. NRC Staff members indicated that current regu- l lations could be interpreted to permit doses an order of magnitude ;
higher tnan this. Tnis is a matter that should be imediately addressed and resolved. We urge that the NRC regulations be made consistent with the guidance previously provided by the Federal Radiation Council.
Staff Response The intent of 10 CFR 20.105 " Permissible levels of radiation in unresticted areas' is to maintain radiation doses to individual members of the public '
within 500 mrem /y. There is some ambiguity and thus an opportunity for possible confusion in.10 CFR 20.105. In. concept, however, Section 20.105 <
is relatively simple. It offers an option of two approaches, paragraphs '
(a) and (b), to controlling radiation in unrestricted areas, and is thus
- somewnat arbitrary. '
The alternative of paragraph (a) is for a person to propose different limits on levels of radiation in unrestricted areas, based on the person's knowledge of average radiatian levels and anticipated occupancy times in the unrestricted area. NRC will approve those different limits if '
the applicant demonstrates that the proposed limits are not likely to cause radiation' exposures in excess of.500 mrem /y. Paragraph (a) is consistent witn the 1960 Federal Radiation Protection Guides (RPG's).
Most licensees cnoose to implement the standards specified in paragrapn (b) wnich limit short tenn dose rates. The two limitations there, to '<
be applied in parallel, reflect consideration of the expected low pro-bability that the specified dose rates might persist in combination with .
personnel occupancy for prolonged periods of time. Tnese probabilities were never expressed, but the limitations were thought to provide reasonable assurance that no person in an unrestricted area would be subject to radiation doses in excess of 500 arem/y. Note that the limits are not expressed in radiation levels, but in radiation doses a person l would receive if he were continously present in the area. This allows l no consideration of the occupancy time of the exposed person. Hypotheti- l cally a person could be' exposed continuously for a time period in excess of five weeks and thus receive greater than 500 mrem /y. - .
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Although we recognize the ambiguity in 10 CFR Part 20.105, we have not noted any widespread confusion among the NRC staff in implementing this section. However, we do understand that the working group drafting a proposed revision to Part 20 intends to remove any ambiguity and make the requirement of meeting the RPG's an explicit one.
ACRS Coment No. 2 The Subcomittee learned that few data exist relative to the number of people involved in radioactive material transportation activities, the
. number and types of vehicles involved, the number of trips being made and the number of packages being handled, the percentage of the loadings that fall within various ' fractions of the dose limits, and the collective deses involved. There is also a need to estimate growth rated for the
. radioactive materials shipping industry so that projections can be made
- of future regulatory needs in this area. We recommend that studies be '
initiated to gather such data. ;
Staff Response
- The Subcomittee recommends that studies be initiated to gather data on i numbers of people, vehicles, trips, and packages, including their external .
l radiation characteristics, involved in the transportation of radioactive .,
material. The staff is presently conducting a survey of radioactive mate- C rial shipments aimed at collecting information on radioactive material I packages and shipments and their characteristics. Other information, &
such as total number of people involved and the number and type of vehicles used, were not considered important for an update of our environmental statement on transportation (NUREG-0170 dated December 1977) and were not included in the survey.
By far, the largest number of shipments involves transport of radiophar- l t
maceuticals in Type A packages regulated by DOT. Growth in the use of ;
radiopharmaceuticals is leveling off and no significant increase in '
the number of transport workers involved is anticipated over the next l few years. Occupational exposure, however, is a matter of concern. See ,
coments in Item 3 in this regard. Anticipated growth areas involve ship- l ment of spent fuel and high level wastes under the Nuclear Waste Policy l Act, shipment of spent resins from reactors to disposal grounds and i increased low level waste disposal. Environmental assessments, including public exposures, in these areas will be made in connection with various :
rulemaking and licensing activities, j j ACRS Coment No. 3 i Unless employed by an NRC licensee, freight-forwarders and drivers of vehicles !
! transporting radioactive materials are currently not subject to NRC regula-i j
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tions. Recent surveys and analyses by NRC contractors and others suggest that such people can incur doses substantially in excess of the established (Federal Radiation Council) limits for individual members of the public and perhaps even in excess of the established limits for radiation workers. The Subcomittee recomends that the NRC request DOT to implement as soon as possible that portion of the proposed IAEA regulations that would assure that such people are classified as radiation workers and appropriately monitored. ,
Staff Response ,
We share the Subconsnittee's concern that transport workers of certain types can be exposed to radiation substantially in excess of established limits for members of the general public while not subject to federal regulations which control those exposures. For those situations observed under our research programs, the exposed transport workers were operating under voluntary radi-ation control programs which appeared ,to provide adequate protection for the work being done. Part of our research was aimed at establishing a relation-ship between numbers and external radiation characteristics of packages in transport, and the radiation exposures of persons handling those packages.
The ultimate objective of this research was to develop a control system by which D0T regulations could reasonably identify those carrier operations which need radiation control programs, and to require the. In a parallel effort, we have encouraged the development in IAEA transport regulations of a gener-ally applicable carrier radiation control requirement that every carrier s handling any radioactive material packages evaluate and categorize his oper-ations in accordance with criteria established by IAEA to establish those '
radiatio'n control requirements which must be implemented.
The NRC program for developing carrier radiation control requirements has been
,placed in indefinite hold since 1982 because of reductions in staffing for y transportation tasks and in order to perforin higher priority standards tasks.
.fAs the Subcommittee noted, the parallel effort for developing an IAEA require-ment for carrier radiation control programs is progressing and should appear in the IAEA transport regulations as revised in late 1984.
We have forwarded to DOT the Subcomittee's coments stressing the importance of this matter and will pursue the matter with DOT. DOT now imposes OSHA .
requirements for radiation workers involved with the transport of radioactive material in dedicated carriers owned or leased by the pharmaceutical companies "
(includes both trucks and aircraft). Preliminary discussions with DOT repre-sentatives, however, indicate they are not completely satisfied with the system. We plan to hold meetings with DOT to esplore methods for improvement.
! ACRS Coment No. 4 -
The Subcomittee noted that the subject regulations could allow radiation .
l exposures to members of the public and to the drivers of trucks transporting spent fuel and solid waste that are substantially greater than stated in Table t
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S-4 of 10 CFR 51.20(g). Apparently the old supporting document for this Table has been updated by a NUREG report now ready for publication. It is important that the values in Table S-4 be revised, as appropriate, to reflect what is pemitted by the revisions to 10 CFR 71 and that new evaluations be made pf the potential consequences.
Staff Response We have recognized for some time that the supporting documentation for the S-4 Table in 10 CFR 51.20(g) was in need of updating. WASH-1238 " Environmental Survey of Transportation of Radioactive Materials To and From Nuclear Power Plants" was developed and issued in 1972. A number of changes have taken place since that time. We expect to have a document available within the next few
' months to replace WASH-1238. Initial indications are that the values in Table S-4 will not require significant change. ,
A distinction must be made between the current study of shipments to and from nuclear power plants and earlier NRC studies of shipments primarily consisting of radiopharmaceuticals, wherein transport workers were handling the hundreds of thousands of medical packages involved in that distribution system. Our -
experience in the latter area cannot be applied to the shipment of reactor fuels and waste, with shipments made primarily in exclusive use vehicles with little handling by transport workers. -
ACRS Comment No. 5 In addition, the Subconnittee was concerned about the extremely slow schedule on which current plans call for these problems to be addressed (e.g., imple-mentation of the final rule in 1987). The current situation, if not promptly
. corrected, could have the potential of resulting in unnecessarily high doses to transportation workers and could reflect poorly on the Comission. We urge that work be promptly initiated to gather the recommended data and that the NRC Staff work with DOT to develop a program for resolving these defi-ciencies. Such a program should include the development of an adequate plan to enforce the requirements ultimately developed.
Staff Response .
We share the Subcomittee's concern for the long schedule times associated with the resolution of transportation problems. On the projected schedule ,
for U.S. implementation of the 1984 transport regulations, final rules by DOT and NRC by 1987 seems to be realistic, if not optimistic. The -
IAEA schedule calls for a final meeting of its revision panel in November 1983, with a final review by IAEA's standing advisory group in the Spring of 1984. The schedule calls for the IAEA Board of Governors to act on the new regulation in late 1984. Recent experience has shown that imple-mentation of IAEA regulations in the U.S. does not come quickly or easily.
In the meantime the staff is seeking ways to improve the regulatory sys, tem
- in this area. ,
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