ML20138A287
| ML20138A287 | |
| Person / Time | |
|---|---|
| Issue date: | 08/08/1985 |
| From: | Asselstine J NRC COMMISSION (OCM) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20138A277 | List: |
| References | |
| NUDOCS 8512110642 | |
| Download: ML20138A287 (2) | |
Text
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b o UNITED STATES NUCLEAR REGULATORY COMMISSION o
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WASHINGTON, D.C. 20655
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fuau=t 8, 1985 t
MEMORANDUM FOR:
William J. Dircks Executive Director for Operations FROM:
James K. Asselstine
SUBJECT:
PROPOSED REVISION OF 10 CFR PART 20 " STANDARDS FOR PROTECTION AGAINST RADIATION" (SECY-85-147)
I would appreciate responses to the following questions regarding the above referenced rulemaking.
1.
The proposed revision to Part 20 would establish a dose limit to a member of the general public of 0.5 rem per year.
Page 21 of Enclosure 1 of SECY-85-147 indicates that that dose limit translatgs to a calculated annual risk for an individual of 8x10~ per year, which is deemed on page 18 to be an acceptable level of risk. On the other hand, the objective of the Commission's provisional safety goal is "to establish goals which limit to an acceptable level the radiological risk which might be imposed on the public as a
- - result of nuclear power plant operation", including normal operation, expected transients and design basis accidents.
The cuantitative goal for 1atent cancer risk of an individual is about 2x10~6 per year (see page 31 of NUREG-0880, Revision 1). What is the rationale for two
" acceptable" levels of risk that differ by a factor of 40?
Why should not Part 20 be revised to conform to the provisional safety goal?
2.
If'one accepts the proposition on page 47 of Enclosure 1 that the dose limit to the general public of 0.025 rem per year established in 40 CFR 190 was based on ALARA considerations, what is the rationale for proposing in Part 20 a dose limit that is 20 times higher than that which is reasonably achievable?
3.
SECY-85-147A indicates that the British have adopted a "de minimis" standard of collective doses less than 100 man-rem comprised of individual doses less than 0.5 nrem per year.
What is the rationale for not proposing in Part 20 a societel "de minimis" standard?
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Assuming that the Connission publishes the final backfit rule that it affirmed on. August 1, 1985, can the staff certify that this Part 20 rulemaking represents "a substantial increase in the overall protection of the public health and safety or the connon defense and security"? If not, on what basis does the staff believe this rulemaking would be in compliance with the backfit rule?
cc: Chairman Palladino Commissioner Roberts Commissioner Bernthal Comnissioner Zech l
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OPE
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