ML20137J234
| ML20137J234 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/1997 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Dicus G, Shirley Ann Jackson, Mcgaffigan E, Rogers K, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20137J180 | List: |
| References | |
| COMSECY-96-057, COMSECY-96-57, DSI-7, SECY-96-057-C, SECY-96-57-C, NUDOCS 9704030250 | |
| Download: ML20137J234 (1) | |
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.......................c RELEASED TO THE PDR umso sms 8
NUCLEAR REGULATORY COMMISSION l l_h/
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j WASHINGTON, D.C. 20655 date initials I
January 27,1997 COMMISSIONER MEMORANDUM TO:
Chairman Jackson Commissioner Rogers Commissioner Dicus Commissioner McGaffigan FROM:
Commissioner Disz
SUBJECT:
COMSECY-96-057 ETRATEGIC ASSESSMENT ISSUE PAPER: MATERIALS / MEDICAL OVERSIGHT (DSI-7)
I agree in part and disagree in part with the Commission preliminary view. I agree with the recommen6ation to improve the existing program through initiatives such as business process re-engineering (BPR) and risk-informed performance-based regulations. I agree that NRC should reevaluate its materials regulations, and where regulations can be relaxed or rescinded without increases in risk, the regulatory program should be amended. I also believe however that initiatives such as BPR should not continue ad-infinitum, but need to be brought to closure.
I disagree with the Commission preliminary view that NRC should not seek an expansion of the materials program to inc'ude naturally occurring and accelerator produced radionuclides (NARM). There is no difference in risk between radiations produced by byproduct materials and NARM. There should be no difference in the Federal regulatory oversight of these materials. Both licenseu and States have to address the requirements of dWerent agencies, with widely differing programs and emphasis, to deal with very similar risks. This is an inefficient use of national and state resources. A consistent risk based approach to radiation protection, regardless of source, would both improve protection of health and safety as well as reduce costs. The Commission should not continue to endorse this accident of history. I believe the Commission should work with the Congress to consistently address all sources of ionizing radiation.
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