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
_,
A FFT RMATION VOTE
]
EEJRQHSE SHEET John C. Hoyle TO:
Secretary of che Commission COMMISSIONER DICUS FROM:
SECY-97-046A - FINAL RULE ON RADIOLOGICAL CR i
l
SUBJECT:
FOR LICENSE TERMINATION f
1 X W/ COMMENTS Disapproved Abstain j
{
Approved id d by l have carefully reviewed the proposed final rule from the cosonorrs :
[
health effects and as a rs a Health Physicist with more than 15 years of research experience in radiation f:rmer Director of an Agreement State Radiation Control Program.
i ALARA for
- 1. I have concludes that the staff's proposal to use release criteria of 26 mrenVyr n l
~ e safety. The 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 EPA has concurred with its success in finding that releases from NRC d
no significant impact on public health and safety. I have considered the E PA to determine water MCL levels. Based on my analysis and given the o ifi t benefit i
d t
put with respect to public health and safety will accrue from a separate pathway standard for grouri d te note thatthe to groundwater protection, I do agree that this 13 vitally important. Therefore, I a d the l
rule will require licensees to evaTuate further reduction in does frorn the gr id tions. The 25 mremlyr unrestricted dose criterion from all potential sources based on ALARA i
lf to EPA proposal to use a separate MCL standard in combination with outdat I
ddition these l
non uniform results that could both significantly under and overestimate actual doses.
i ble benefit MCL's could make cleanup so costly as to be non vlable fo t
CL to the use of the 26 mrem / year limit plus ALARA without a separate ground water M ith
- 2. Given the above radonale for my declefon with respect to the proposed final if rm l
the staff's recommendation to place it in compatibility Category 2. Dolng so wou i i i of J
licensed nuclast facilities in the U. S. This is not m the natio ld point out that ALARA ment l
under Category 1, Agreement States could a ing the practical result of is anintegral(and offectival part of the rule. Therefore,f ALARA goals. Thus}ation protection rule the the 25 mrom/vr standard Dy appropriate application o i
the rule in Category 1 is the establishment of a uniform national rad i
Agreement decommissioning oflicensed nuclear facilities that also pro application of ALARA.
~ 3. I have reviewed the EPA cornments on NRC Involvement with considerat potential restricted release of sites at levels exceeding i
lease staff will receive and review public comments gathered by the licensee prior to ma i
determination for the facility, Additional comments are attached to this vote sheet. Subject to the comma 4.attached,I approve the final proposed rule.
1FA o ct n can i
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ad)s99 MW Release Vote /
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Withhold' Vote
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l Entered on dAS" Yes U, No
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9705230086 970521 9
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 implementing regulatory guidance to the commission for review and i
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.
i 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 understandings of the uptake and doses resulting from uptakes of radionuclides through drinking water.
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 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 Part 30 (such as in Section 30.31, and 30.34).
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