ML20133G395
| ML20133G395 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1996 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20133G353 | List: |
| References | |
| SECY-96-139-C, SECY-96-221-C, NUDOCS 9701160032 | |
| Download: ML20133G395 (2) | |
Text
.,
NOTATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DIAZ j
SUBJECT:
SECY-96-221 - SECY-96-139 - STAFF l
REQUIREMENTS - CONGD-94-003 - IMPROVING NRC'S CONTROL OVER, AND LICENSEES' ACCOUNTABILITY FOR, GENERALLY AND SPECIFICALLY LICENSED DEVICES Approved Disapproved Abstain Not Participating Request Discussion COMMENTS:
)
/ $ NATURE /
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Release Vote
/V/
l\\-l'l-9b DATE Withhold Vote
/
/
Entered on "AS" Yes No FM"e888: Mi! 2 CORRESPONDENCE PDR
. -. -. -. _ ~ -.
. -. ~. _ _ _ _ _ - -
t I
COMMENTS ON SECY-g6-221 The staff should provide to the Commission a comprehensive risk based plan for addressing the accountability for and control of exempt, generally licensed, and speafically licensed devices.
The plan should contain a reevaluation of current regulatory oversight mechanisms. The plan should propose miemaking consistent with the following goals:
Protectag workers and the public from the risks associated with the intended use of each device; Protectmg workers and the public from the risks associated with the misuse or loss of control of each device; and Protechng the environment from loss of control of nach device.
The following table is an example of the kind of framework that could be utikzed. The staff is free to develop a ce.TC'f/different system, or modsfy this in any way it deems appropriate to ach6 eve the above goals.
Licensing requisement Exempt General Registry Specific Ucense License Normal Worker Dose (mrom/yr)
<10
<100
<500
<5000 Normal Public Dose (mrom/yr)
<<1
<1
<10
<100 Risk to worker or member of the public
<100
<1000
<5000
<10000 from misuse or loss of control (mrom/yr)
Estimated environmental hazard
< $ 10 k
< $ 100 k
<$1M
>$1M (cost of cleanup if controlis lost) per device per device per device per device Risk ofloss of control
<1:100
<1:1000
<1:10,000
<1:1,000,000 (W of regulatory oversight)
(per year)
(peryear)
(per year)
(per year)
Qualitative Overall Risk Trivial Low Moderate High The plan should include the following elements:
A plan for identifymg, and where necessary, asserting regulatory control over existing devices consistent with the above goals. The plan should focus its efforts on the highest risk devices first. The staff should consider the need for'mshatmg this effort in advance of the completion of the rulemaking.
A mechanism for identification, control, storage, and proper disposal of orphan sources, includeg a funding plan for such contingencies.
Resource need estimates for each year of the plan and for maintenance of the developed system after the plan has been completely implemented. Without sawifcirig adequate protechon of workers, the public, and the environment, the staff should attempt to develop the most cost effective plan possible.
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