ML20141G923
| ML20141G923 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1997 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20141G895 | List: |
| References | |
| SECY-97-046A-C, SECY-97-46A-C, NUDOCS 9705230086 | |
| Download: ML20141G923 (2) | |
Text
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VOTE
]
A FFT RMATION EEJRQHSE SHEET John C. Hoyle TO:
Secretary of che Commission FROM: COMMISSIONER DICUS l
i
SUBJECT:
SECY-97-046A - FINAL RULE ON RADIOLOGICAL CR FOR LICENSE TERMINATION f
. 1 X W/ COMMENTS Disapproved Abstain j
Approved
{ id d by
[ cosonorrs : .
lrshave carefully reviewed the proposed final a Health Physicist with more than 15 years of research experience in radiation health effects ruleandfrom as a the ,
f:rmer Director of an Agreement State Radiation Control Program. i ALARA for '
I have concludes that the staff's proposal to use release criteria l ~ e ofsafety.
26 The mrenVyr n' 1.
unrestr6cted release of a facility will provide adequate protection of the public hea m d Even affectiveness of application of ALARA in combination with dose limita cannot b d
EPA has concurred with its success in finding that releases from NRC r PA to determine no significant impact on public health and safety. I have considered ifi t benefit the E water MCL levels. Based on my analysis d and t put with given respect the o d te note thatthe i
to public health and safety will accrue from a separate pathway standarddfor the grouri l to groundwater protection, I do agree that this 13 vitally important. Therefore, tions. The Ia rule will require licensees to evaTuate further reduction in does frorn id i lf to the gr 25 mremlyr unrestricted dose criterion from all potential sourcesI based dditionwith on ALARA these l EPA proposal to use a separate MCL standard in combination benefitoutdat i bleactual non uniform results that could both significantly under and overestimate t doses. ;
MCL's could make cleanup so costly as toCLbe non vlable fol to the use of the 26 mrem / year limit plus ALARA without a separate ground ith water M
- 2. Given the above radonale for my declefon with respect to the proposed if rm final l of
' the staff's recommendation to place it in compatibility Category 2.
ld point out that ALARA i Dolng i i so wou J licensed nuclast facilities in under theCategory U. S.1, Agreement This isStates notcould the practical result of ma the ment natio ing l
i is anintegral(and offectival part of the Dy appropriate rule. Therefore,f application o ALARA goals. Thus}ation protection the rule!
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' the 25 mrom/vr standard 1 is the establishment of a uniform national rad Agreement the rule in Category decommissioning oflicensed nuclear facilities that also pro application of ALARA.
~ 3. I have reviewed the EPA cornments on NRC Involvement with considerat i potential restricted release of sites at levels exceeding lease staff will receive and review public comments gathered by the licensee prior to mai
' determination for the facility, :
4.
Additional comments are attached to this vote sheet. Subject to the comma attached,I approve the final proposed rule.
1FA o ct n can i
~ s u \T Ks I Release Vote / x/
ad)s99 MW ;
~
/ UATt /
I Withhold' Vote /' / l Entered on dAS" Yes -
9 U, No ~
9705230086 970521 ,
PDR CONNS NRCC !
$. CORRESPONDENCE PDR ;
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' Addition comments of Commissioner Dicus on SECY-97-046A:
- 1. The direction in the December 9,1996 SRM re submission of the l i implementing regulatory guidance to the commission for review and l j approval within one year of the date of the paper should be repeated ;
in the SRM for this paper. The ALARA guidance for groundwater i
- should be included.
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- 2. A note should be made in FR and the Regulatory Analysis that EPA's MCLs are based upon outdated modeling that does not reflect current l
> understandings of the uptake and doses resulting from uptakes of l radionuclides through drinking water.
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- 3. The Regulatory Analysis, on pages 3 and 4, states that the criteria would not apply to sites which have submitted a sufficient license termination plan or decommissioning plan within .[6 months after effective date of the final rule] and such plan is approved by NRC within [18 months after effective date of the final rule]. These times are 12 and 24 months, respectively, in the Federal Register. Staff i should clarify these times.
4
- 4. In the GEIS, p. 3-3, citation of regulations, categorization of facilitica, ,
item 1, it is stated that sealed source users are licensed under Parts l l
l 30, 33, and 35, but did not include Parts 34, 36, or 39. In item 2, it states Part 30, 33, and 35 in discussion of short-lived byproduct radionuclides. It did not include Part 39 for 1-131 use. The GEIS l should list all parts of the regulations, or state licensed pursuant to l Part 30 (such as in Section 30.31, and 30.34).
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