ML20138A218
| ML20138A218 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1985 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Asselstine NRC COMMISSION (OCM) |
| Shared Package | |
| ML20138A222 | List: |
| References | |
| NUDOCS 8512110614 | |
| Download: ML20138A218 (3) | |
Text
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Cortified 37_ W 9 AUG 26 W
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l MEMORANDUM FOR:
Comissioner Asselstine i
THRU:
William J. Dircks DMam N I
Executive Director for Operations J
FROM:
Robert B. Minogue, Director Office of Nuclear Regulatory Research i
SUBJECT:
RELATIONSHIP BETWEEN PROPOSED REVISION TO 10 CFR PART 20 AND EPA RADIATION PROTECTION STANDARDS This memorandum provides supplemental infomation related to your August 7, 1985 request to the General Counsel regarding the relationship between the limitsproposedinthePart20 revision (SECY-85-147)andEPA'sUraniumFuel CycleStandard(40CFRPart190). The two standards are quite different in their derivation and in the functions they serve.
Although both are radiation protection standards, one (Part 20) relates to limitation of health risk. The other (40 CFR Part 190) relates to the application of the ALARA principle involving an assessment of the cost and effectiveness of exposure limiting technology for specific types of fuel cycle facilities.
l It has been the longstanding practice of the NRC and other organizations associated with radiation health protection to implement radiation protection by setting upper limits of exposure based on presidentially approved Federal guidance and/or on ICRP and NCRP recommendations. But then actual exposures are kept as low as is reasonably achievable (or "ALARA") below these limits.
This approach was set forth in the Federal Radiation Protection Guidance issued in 1960:
"1.18 Radiation Protection Guide (RPG) is the radiation dose which should
' not be exceeded without careful consideration of the reasons for doing so; every effort should be made to encourage the maintenance of radiation doses as far below this guide as practicable."
This latter teminology has evolved from "as low as practicable (ALAP)" to "as l
lowasisreasonablyachievable(ALARA)." The combination of exposure limits l
and lower ALARA exposures is today an inherent feature of all radiation I
protection programs.
The limit in the proposed Part 20 for exposu're of the general public is 0.5 rem (500Eires) per year. It limits the sum of the doses from all sources of radiation except background radiation and medical exposure to a patient. This 8512110614 850826 PDR COMMS NRCC CORRESPONDENCE PDR i
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. limit derives from the existing Federal Radiation Guidance and is consistent with the recomendations of both the National Council on Radiation Protection and Measurements (NCRP) and the International Comission on Radiological Protection (ICRP). This limit and corresponding health-based limits for occupational protection are considered upper bounds to acceptable doses and should be complied with regardless of cost. The reference level of 0.1 rem (100 millirem) per year in the proposed Part 20 defines a licensee action level and is consistent with recomendations in ICRP Publication No. 26 and with draft recommendations under consideration by the NCRP.
It defines a level of radiation from a specific source.
If this limit is exceeded, the licensee must conduct further investigations to detemine that the combined exposure to individuals, including the radiation dose from the source in question, does not i
exceed.500 millirem per year.
In addition, under the proposed Part 20, each licensee would be required to apply ALARA principles.
The health-risk based levels in the proposed Part 20 reflect a judgment of the level of risk which would be acceptable in comparison with other risks.
In contrast. EPA's Uranium Fuel Cycle Standard (40 CFR Part 190) and the reactor i
design objectives in Appendix I to 10 CFR Part 50 represent standards set on the basis of a quantified detemination of what is "as low as is reasonably achievable" or "ALARA." These levels are~primarily technology based. That is, they are based on analysis of technological capabilities and costs and the related reduction in offsite population doses and potential health effects; they are based on what is both technically and economically achievable for
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specific types of fuel cycle facilities. The costs of achieving these standards are implicit in their development. As EPA stated in the i
environmental statement accompanying 40 CFR Part 190 [ EPA 520/4-76-016 Vol. I, pages5-6]:
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"The environmental effects of planned releases of radioactive effluents j
from components of this cycle have been analyzed in detail by the EPA in a series of technical reports covering fuel supply facilities, light water reactors, and fuel reprocessing ([ references]). These technical analyses 2
provide assessments of the potential health effects associated with each of the various types of planned releases of radioactivity from each of the various operations of the fuel cycle and the effectiveness and cost of l
controls available to reduce releases of these effluents.
In addition to these analyses, there is considerable other information on planned releases from these types of facilities available. This includes the generic findings of the NRC concerning the practicability of effluent i
controls for light-water-cooled reactors, extensive findings of the utilities, the NRC, and the AEC, reflected by environmental statements for a variety of individual facilities, and finally, the results of a number of detailed environmental surveys conducted by the EPA of typical operating facilities."
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Appendix 1 to 10 CFR Part 50 contains design objectives defining "ALARA" effluent releases and, although it contains action levels, it does not ::ontain dose limits in the usual sense.
EPA's 40 CFR Part 190 does define dose limits for nonnal operation of uranium fuel cycle facilities, but these are not rigid, i
absolute limits, as the standard allows NRC to grant a variance to exceed these limits in cases where the need for continued operation has been demonstrated, and corrective action is being taken to reduce the exposures. The Appendix I design objectives (which preceded the issuance of EPA's 40 CFR 190) are expressed separately for each reactor on a site and for individual exposure pathways (noble gases, radiciodines und particulate; and liquid effluents).
The EPA standards in 40 CFR Part 190 apply to the entire site and to the total of all exposure pathways. When these differences are taken into account, the two standards are relatively compatible. This is not surprising, since the EPA drew upon the same AEC studies and the operating experience used by NRC to develop Appendix I.
It should be noted that the EPA 40 CFR 190 standard is incorporated into the present and proposed Part 20 by reference.
Control of radioactive releases and waste processing technology for reactors and other fuel cycle facilities are very cost effective and this results in very low ALARA levels. This is why it is appropriate that the EPA 40 CFR Part 190 standards (referencedinPart20)andthelevelsattainedbycompliance i
with Appendix I are significantly lower than the proposed Part 20 limits and reference levels. However, the EPA standards in 40 CFR Part 190 specify ALARA-type levels only for uranium fuel cycle facilities and cannot generally be used as an indication of what is ALARA for other classes of NRC-licensed facilities.
The important distinction is that the limit for members of the public in the proposed Part 20 limits the sum of the doses from all sources except background and medical radiation.
In contrast, the EPA standard is an ALARA-based standard for uranium fuel cycle facilities and light water reactors.
If you wish a more detailed discussion of these limits or of applications of the ALARA concept, we could provide a briefing for you and/or members of your staff.
Or41nalsiamedby:
a0 mute 3.utmaa Robert B. Minogue, Director Office of Nuclear Regulatory Research cc: Chairman Palladino Commissioner Roberts Comissioner Bernthal Comissioner Zech OGC JLbl 1
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