ML20150D385

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Summary of 880504 Meeting of ACRS Subcommittee on Waste Mgt in Washington,Dc Re Review & Discussion of Current & Potential Applicability of De Minimis & Below Regulatory Concern Concepts to Commission Policies
ML20150D385
Person / Time
Issue date: 05/20/1988
From:
Advisory Committee on Reactor Safeguards
To:
Advisory Committee on Reactor Safeguards
References
ACRS-2576, NUDOCS 8807130448
Download: ML20150D385 (18)


Text

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SUMMARY

MINUTES OF THE MEETING OF THE ACRS SUECOMMITTEE ON WASTE MANAGEMENT ,

WASHINGTON, D.C.

MAY 4, 1988 The ACRS Subcommittee on Waste Management met in Room H-1167, 1717 H Street, NW., Washington, D.C. on Wednesday, May 4,1988. Enclosure A is a copy of the Federal Register Notice of this meeting.

Purpose:

The purpose of this meeting was to review and discuss the current and poten-tial applicability of de minimis and below regulatory concern (BRC) concepts to Comission policies.

Implementation The above topic was reviewed and discussed in accordance with the Presenta-tion Schedule (Enclosure B). A list of the documents provided during this meeting is enclosed (Enclosure C); they are available in ACRS files.

Subcomittee Action Taken:

The Subcomittee drafted coments on the subject of this meeting in response to the oral request for such coments made by the EDO, V. Stello, Jr. during his meeting with Drs. D. Moeller and M. Steindler on April 14, 1988. The coments are to be provided for ACRS consideration during its 337th meeting, May 5-7, 1988.

Attendees: (Total - 33, See Enclosure D) l Members - 3 ACRS Consultants - 3 D. Moeller M. Carter F. Remick R. Foster M. Steindler F. Parker ACRS Staff - 3 NMSS Staff - 9

0. Merrill R. Bangart J. Parry R. Bernero R. Savio R. Boyle D. Cool t

RES Staff - 4 R. Cunningham l

R. Alexander K. Dragonette iI in T AT O o;;1973 g he p

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L. Rouse r S. Neuder 3 1 j, O ,

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MINUTES / WASTE MANAGEMENT 2

  • May 4, 1988 -

NRR/RPB -1 Others - 10 W. Meinke I. Introduction and Executive Session ,

From 8:30 to 9:30 a.m. Dr. Moeller held an Executive Session prior to the meeting being officially opened, during which the members and consultants present familiarized themselves with and briefly discussed the documents provided as attachments to a memorandum from 0. Merrill to D. Moeller et. al,

Subject:

Additional Articles and Documents on the De Minimis Issue, dated May3,1988(HandoutNo.1).

II. Welcone and Opening Remarks -- D. Moeller, Chairman At 9:30 a.m. Dr. Moeller officially opened the meeting and made the following >

connents (and questions) regarding de minimis and below regulatory concern (BRC) concepts.

1. The Subcommittee's attention should be directed towards BRC; de minimis should not be an issue.
2. The Subcommittee should address the BRC issue generically by identifying basic criteria for setting BRC levels.
3. Should there be a BRC level for population groups (collective) as well as for individuals? He said he believes there probably should l be.

l 4. Should "practices" and "sources" whose doses are voluntary be treated differently than those that are involuntary?

I

5. Should products that are releasable to the public be treated differently than items that are fixed in place?

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6. Is there a difference between established practices and ones newly proposed?

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' MINUTES / WASTE MANAGEMENT 3 Nay 4, 1988 .

7. , Is there a difference between natural sources and those that are artificial?  !

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8. The NRC Staff should take a conservative approach -- one that could 1ater be relaxed, rather than one that is initially relaxed, and might have to be made more restrictive later. (he levels could be set on the basis of (a) the risk associated with a given dose, (b) an assigned dollar-Sievert value for a human life, with an associ-cted cost-benefit analysis, or (c) observed variations in natural background.
9. Whatever value is chosen for the BRC, it nust be implementable.

Also. (a) once established, the value should be systematically applied across the board, (b) previously accepted values (e.g.,

Appendix I, gemstones) should be re-examined to see if they are compatible with the chosen BRC value, (c) the basic BRC number should be expressed in terms of an effective dose equivslent, from which derived guides can be developed which can be applied to individual situations to assure that the basic limit is being met, (d) a range of scenarios (on how a given source or practice moves through the environment and impacts on people) will be required to develop the derived guides, and (e) also needed will be a set of dose modeling procedures that have been evaluated and confirmed as being acceptable.

10. The establishment of a BRC level may not be something that can be done once and for all. Periodically, given sources and practices should be re-examined to assure that what was originally antici-pated is actually taking place.

Dr. Moeller offered the following additional comments.

1. The establishment of a BRC level does not mean that such sources will not be regulated. They will be, in the sense that the pro-ponerd must demonstrate that the practice or source will not cause anyone to receive a dose greater than BRC.

' MINUTES / WASTE MANAGEMENT 4

'May 4, 1988 .

2. A BRC level should be established. Not to do so represents a waste of national resources, and undue regulations can very well cause society to select options that will impose a greater burden on human health and the environment. This effort is really addressing the question, "How Safe is Safe Enough?"
3. If variations in natural background are used as a guide in setting a BRC level, the variations should be thosc in the ambient (out-door) environment; they should not be those associated with back-ground rates indoors since these often involve scurces that have been "technologically enhanced."

He concluded his opening remarks by saying that he hoped, (a) that there would be sufficient time during the day to dis:uss the subject and reach some definite conclusions, and (b) that there would be time to discuss the 6 questions posed in SECY-88-69 from the EDO to the Commissioners, dated March 8, 1988. He then called upon other members and consultants to make opening connents .

Dr. F. Remick said it would be good if we had one Agency-wide safety goal, from which all of these various limitations and thresholds would follow. He added that he hoped that might be an outcome of today's meeting.

Dr. M. Carter said that:

l i 1. BRC and de minimis can both be discussed.

2. Measurements at these levels are difficult to make.
3. The BRC level (or levels) proposed by the NRC should be compatible with those of other agencies. The criteria for arriving at a given BRC level need to be known.

l Dr. R. Foster said that:

1. The NRC should take a generic approach and get back to a single base.
2. BRC level is NRC's job -- de minimis is not.

1

MINUTES / WASTE MANAGEMENT 5 May 4, 1988 -

3 Should BRC have subsets? What is a single source, a facility or a single exposure pathway?

4. If you truncate t.he collective dose at some point, does this ,

relate to the BRC for individuals?

5. The term "below-environmental concern" is used in Environmentel Impact Statements. Do you use it in deciding whether environmental surveillance is needed?

Dr. F. Parker made two comments:

1. Because we spend 90 per cent of our time indoors, he did not agree with Dr. Moeller that they should be looking only at outdoor background. (See Dr. Moeller's comment No. 3 on page 4.)
2. This is a political issue and not a technical one -- we are in the wrong arena. Since this is a democracy, we have to go by what the public wants. The best we could hope to do is to make recommenda-tiens to the Commission, who should make recommendations to the Congress, and get the Congress to come up with a safety limit, and let the Congress define how safe is safe.

Dr. M. Steindler made the point, in response to Dr. Parker's second state-ment, that we still need to define the role of technology in the decision.

III. BkC Policy Statement -- R. Bernero and K. Dragonette (Handouts Nos. 2, 3 and 4) l Mr. R. Bernero said, regarding outdoor versus indoor background, that in health physics, they neglected the intolerable exposures. Frequently the actions taken were determined by the instrumentation available. Detectable radiation depends upon the instrumentation available; if you couldn't measure it, it was considered BRC, de minimis or trivial. Today we are defining the tolerable, which requires two steps:

1. Radiation exposure at a level where it is too difficult or costly to reduce it further.

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  • MINT)TES/ WASTE MANAGEMENT 6

'May 4, 1988

2. Having a theoretical threshold of BRC, we then somewhere encounter a threshold that challenges the linear hypothesis, that says, this is trivial and is not radioactive for all intents and purposes. ,

Which says, in effect, that certain low-level waste (LLW) is OK to release since we know its destiny. We need a definitive dose model, but individual practice varies widely.

Mr. Bernero also said that, after the Comission briefing on this topic, he told Chairman Zech that he perceived what the Comission wants is a single number or a statement that a radiation level is low enough that it ould not be controversial in a reasonable society, and high enough to be a practical and usable measure throughout all of our practices. To which the Chaiman assented, followed by Mr. Bernero saying that he was afraid that there is no such number, and that it would be a very tough pursuit to go look for one.

Ms. K. Dragonette gave the background and a historical review nf the BRC/d_e minim _is issue, indicating the NRC RES Staff, who now has the responsibility for th'is work, hopes to have a Policy Statement for Comission approval within 6 months, and rulemaking subsequent to that time. The objective is to set a BRC for LLW such that it does not need to be disposed of in a licensed facility.

Other highlights of her presentation and discussion follow:

1. If BRC is done on an optimization basis, there will be several BRC levels.
2. The criterion, "Negligible Potential for Recycle," pertains to scavengers at sanitary landfills, which is not covered by the NRC i computer model. For this reason and because of a 6-month deadline, the NRC ruled out recycled materials.

l Dr. Carter comented that it is required that you deal with real waste, and asked if you should not also use real disposal methods?

Ms. Dragonette said that NRC has granted a $2M, 2-year contract to EPRI for work on this problem.

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MINV.TES/ WASTE MANAGEMENT 7 May 4, 1988 ,

3. The question, "How do you deal with the situation where several groups ship to one land fill?" was discussed. Also pointed out was that the critical person in many cases is the truck driver hauling the waste to the disposal site.

IV. Release and Decommissionins Criteria -- L. Rouse and S. Neuder (Handout Nos. Sa through 5d and 6)

Mr. L. Rouse discussed Decommissioning Materials and Criteria. Regard-ing criteria for surface contamination, he said that none now exist (no limits), and that since 1950 many fuel facility plants have been decom-missioned using Regulatory Guide 1.86, Guidelines Document of August 1987, and ANSI 13.12, but that none of the guidance in these documents-is derived on a dose basis. NRR uses R.G. 1.86, NMSS uses "guidelines" and frequently makes following them a condition for a license. However, he said that the "guidelines" are not intended as a guide for releasing material to scrap. The tables in both the R. G.1.86 and the "guide-lines" are used by DOE in cleaning up old AEC facilities.

Regarding the limits for soils, for which the above guidelines do not apply, he said that the NRC found itself with a problem on what regula-tions to apply to thousands of cubic meters of slag and waste tailings.

Mr. Rouse said that NRC has published a Branch Technical Position for Thorium and Uranium residues (46FR52061). R. Cunningham said that BRC for this application would be set by an optimization process.

Dr. Neuder discussed acceptable surface contamination levels and the development of new guidance for the release of lands and facilities for l

unrestricted use. He said that the new guidance addresses the: (a) external exposure rate, (b) volumetric distribution, and (c) surface distribution. Its application will be initially to soils and struc-tures, then to equipment and materials. He said that there are 5 pathway considerations in the new guidance, (a) direct external ex-posure, (b) resuspension (inhalation), (c) agriculture (ingestion), (d) secondary transfer (ingestion), and (e) groundwater (ingestion). He added that the primary considerations for a BRC primary dose limit are

HINUTES/ WASTE MANAGEMENT 8 May 4, 1988 .

(a) cost effectiveness, (b) past experience and (c) health risk, and that the interim policy currently in use, until the new guidelines and policy are put in place, includes the above considerations plus secon-darylimits(viz.,externalexposurelimit,inventorylimit,andsurface limit).

Y. Irradiated Gemstones -- Dr. D. Cool (Handout No. 7)

Dr. Cool discussed the Irradiated Gemstones issue. After discussing the historical background, he identified three policy issues:

1. 10CFR Part 30 allows "Exempt Concentrations" which may be con-sidered BRC limits.
2. 10 CFR Part 30 prohibits radioactive materials in food, beverages, or cosmetics.
3. "Justification" -- 1965 AFC/NRC Policy prohibits frivolous radio-active products such as jewelry.

He said that the key issue of the Comission decision on gems is low health risk; that the concentration of radioactive materials in gems is in the BRC range. Hence, the Comission has directed the staff to expedite policy development on BRC issues. He added that the technical issues are:

1. Measurement techniques.
2. Induced radioactivity varies widely depending on mineral content of gems.
3. Occupational risk from cutting or grinding gems.
4. Applying a BRC limit to gems.

VI. CurrentNEA/IAEAActivities--R.Cunningham(HandoutNo.8)

R. Cunningham ciscussed international activities in the matter of the BRC/de minimis issue. After giving a historical background, he said that the basic criteria adopted by the joint NEA/IAEA Expert Group in March 1988 were:

MINUTES / WASTE MANAGEMENT 9

'May 4, 1988 .

1. Radiation protection must be optimized.
2. Individual risks must be sufficiently low.

~ '

Also, their general philosophy for exemption states that the following two criteria must apply:

1. The use of additiceal controls in a practice or source of exposure does not result in an additional reduction in the dose ,

received.

2. The costs of the regulatory controls are not balanced by the benefits of dose reduction that could be achieved.

Mr. Cunningham then discussed in detail the three categories of the framework for exeniption levels viz.,

1. dose limits (i.e., values that represent the boundaries of ex-posuresconsideredtobeunacceptable),
2. BRC (i.e., a range of doses where costs do not achieve further reduction, or are not balanced by benefits), and
3. trivial dose (i.e., values where regulatory controls are unneces-sary -- essentially what is otherwise referred to as negligible individual risk or de minimis).

Mr. Cunningham said that the guidance for trivial dose levels is:

1

1. A level of individual effective dose equivalent of some 10's of USv per year can reasonably be regarded as trivial by regulatory l

l authorities.

I

2. Collective dose levels should be small, and detennined as optimal (ALARA). This may be of the order of about 1 man-Sv per year of practice.

He said that the general procedure reconinended to be followed, is:

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MINUTES / WASTE MANAGEMENT 10 May 4, 1988 ,

1. Analysis of exemption
2. Calculation of individual and collective doses involved
3. Specification of exempt conditions
4. Establish method 'for determining compliance
5. Periodic re-analysis of the basis for exemption to detennine if adjustments are appropriate.

The US/NRC is hosting an international meeting in Washington on October 17-19, 1988 to address the BRC/de minimis issue.

VII. De Minimis and Below Regulatory Concern Policy Development (Integral Approach to Issues - W. Lahs (Handouts Nos. 9 and 10)

W. Lahs discussed the development of an NRC policy on BRC and de minimis, which became the responsibility of RES when NRC was reorganized in November 1987. He said that the most recent and near-term actions are:

1;. Status report to the Comission on March 14, 1988.

2. An April 29, 1988 response to a Staff Requirements Memorandum regarding techniques used by other agencies. (A copy of this item was provided by R. Bernero during the meeting.)
3. Options paper for the Comission establishing a generic BRC number

-- due August 1, 1988.

4. International Workshop on October 17-19, 1988, for which he has prime responsibility.

He discussed the impact of the gemstones issue on the proposed de minimis/BRC Policy, and the major topics discussed during tne May 4, 1988 briefirg to the Comission, which he also discussed with the Subcomittee, viz.

1. A radiation protection framework and the terms and concepts associ-ated with regulatory cutoffs.

MINUTES / WASTE MANAGEMENT 11 May 4, 1988 .

2. Policy development considerations -- in light of current NRC, EPA and international activities.

' ~ ~

3. Plans for the International Symposium.
4. Preliminary resource estimates for broad and specific policies.

Of particular interest were the following policy development considerations:

1. "Source Specific" vs. "Generic" BRC levels.
2. Characterization of cutoff levels.
3. Characterization of sources on a National basis.
4. Role of cost / risk tradeoffs.
5. Conversion of BRC dose levels to risk.
6. Difficulties in establishing "negligible risk" levels.

He stated that RES' initial ideas on policy development are to (a) respond to the C6 mission request for a generic number for BRC exposures, and (b) provide flexibility to develop reasonable and prudent exemptions from regula-tory control for: low-level waste stream disposal, decontaminated and decomissioned structures and sites, consumer products, etc. He said their approach is to use multiple (3) individual dose values to define a graded degree of justification for exemptions.

VIII. Closing Executive Session In the Executive Session following the fomal meeting, members of the Subcom-mittee and its consultants prepared a draf t sumary report for submission for consideration by the Advisory Committee on Reactor Safeguards. Key points in the summary were:

1. It should be recognized that the establishment of a level for Below Regulatory Concern is essentially the development of an answer to the question, "How Safe is Safe Enough?"

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MINU.TES/ WASTE MANAGEMENT 12 May 4, 1988 ,

2. If a BRC level that places a limit on the health risks to individu-als is set, this should assure that the associated collective doses are acceptable.
3. The basic BRC level should be set on the basis of health risk; once this is done, secondary or tertiary guides for implementation of the BRC will have to be developed; it should be recognized, howev-er, that it will be impossible (with current technology) to measure the doses corresponding to the health risk of the BRC.
4. It would appear that that health (fatal cancer) risks that would be representative of an acceptable BRC level would be less than 10-6 per year. Corresponding acceptable lifetime health risks would thus be less than 10'4 .

The Subconnittee also prepared answers to each of the six Issues outlined in SECY 88-69.

NOTE: A transcript of the meeting is availables at the NRC Public Document Room, 1717 H Street, NW., Washington, D.C. or can be purchased from Heritage Reporting Corporation, 1220 L Street, NW., Washington, D.C. 2000S, Telephone (202) 628-4888.

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Federal RMstee / Vd. 53, No. 78 / Friday, Aprff 2.2. 1988 / N:tices

. Apnl 28,1988, Room 104fL 1717 H Street, /AdWoory Coenmittee on Reactcie (DodtiN8 Mill

? NW., Wa shingt on. DC. V Safeguards, Subcommittee on Wasta Dett011 Edlaea Co. and Wolverine Management; WeeUng The entire meeting will be open to P SMMmMM public attendance. .

The ACR3 Subcommittee on WaSta (Formi 2); Exemption The agenda for the sub}cct meeting Management wiu bold a rneeting on I sh311 be as follows: May 4,1988, Room 1167,1717 H Street NW., Washington, DC. Detroit Edlaor. Company (Deco) and -

Thursday. Ap// 23,1933-3.30 o m. until the Wolverine Fower Sup ly -

The chure reeeting wiu be open to the conclusion of businen public attendance. Cooperative,incorporista (the '

The Subcomm.ttee i wd. l receive a The agenda for tha subject rsecting licensees) are the holders of Facility briefing from the NRC Staff on the2r shall be as follows: Operating 1.icense Ns. UPF-43 which zes e perat o Wednesday, May 41566-dJ0 cJa. {u ,,, y I e S te Cb a e ita icn an SCP) fo ,

untd the conclusien of busineu in excess of 3292 megawatts thermal the Yucca Mountain site. The DOE staff will address these comments and The Subcommittee wili recein a ne Ikense provides, a:non other provide information as to how the points briefing from the NRC Staff on the things, that it is subject to a rules.

raised wiu be disposed of before questions of Below Regulatory Conoem regulations and Orders of the Nuclear submission of the SCP. (BRC) and de minimis materials. Other Regulatory Commission (the '

agencies. such as EPA, are expecteti to Commission) now or hereafter in effect.

Oral statements may be presented by attend and provide background ne facility is a boiling water reactor members of the pubbe with the

  • I ""8U05 (BWR) loc.ated at the licensees
  • site in concurrence of the Subcommittee Oral statements may be presented by Monroe County, Michigan.

Chairman. wntten statements m!! be members of the pubbe with the accepted and made available to the cu a nenu f the Subcomminee H Comm:ttee. Record:ngs m!! he permitted Chairman; written statements will be D CFR Part So. Appendix J. Section Ill D.3s only during those pertions of the ed and made available to the states Type C tests Type C tests shall be meeting when a transenpt is being kept, "P'.ttee.

Commi Recordings will be permitted pertenned donna eich reactor shutdown for and questions may be asked caly by only during those portions of the refuehng but in no case at inten als greater members of the Subcommittee,its meeting when a transtnpt is being kept. than 2 years.

consultants. and Staff Persens desiring and quesuons may be asked on1 by ne tests would become due at Fermi-to make oral statements should notify members of the Subcommittee,its a for the isolation valves which are the the ACRS staff member named below as consultants. and Staff. Persons desiring 'subject of this Exemption on April 28, far m, advaace as is practicable so that to make oral statements should notify 1988. The tests necessary to meet this appropriate arrangements can be made. the ACRS staff member named below as section of Appendix j to to CFR Part 50 During the tnitial portion of the far in advance as is practicable so that are te utred by Technical Specification meetir:g. the Subcommittee rnay appreptiate arrangements can be made. 4.6.1.2 of the Fermi 2 Technical exchange preliminary siew s regarding Dunng the initial portion of the Specifications.

matters to be considered daring the meeting the Subcommittee may exchcnge prehminary views regarding HI balance of the meeting The Subcommittee will then hear matters to be considered dunng the By letter dated February 22.1968, the presentations by and hold discussions balance of the meeting.The Subcomittee licensees requested an exemption from with representatives of the NRC Staff wiU then hear presentauons by and hold section Ill.D.3 of Appendix j to to CFR and other interested persons regarding discussiens mth representathes of the Part 50 for certain Residual Heat NRC Staff and other interested persons Removal (R}G) shutdown cooling this resiew.

Further information regarding topica regarding this review. Iso!ation 5 ah es. The licensees to be ihscussed, whether the meetag Further information regarding topics requested that the initial 24. month to be discussed, whether the meetin8 testing interval for three RHR shutdown his been cancelled or rescheduled. the has been cancelled er rescheduled, the cooling inboard isolation valves (E11-Chairman's ruling on requests for the Chairman's ruling en regoests for the F009. E11-F408, E11-F608) be extended opportunity to present oral statements opportunity to present oral statements on a one-time basis until the first and the time allotted therefor can be and the time allotted therefor can be refuehng outage which should be no obtained by a prepaid telephone call to obtained by a prepaid telephone cau to later than the end of 1989.

the cognaant ACRS staff member. Mr. the cognizant ACRS staff member, Mr. The licensees have indicated that Owen S. Mern11 (telephone 202/634- Owen S. Mernll(telephone 202/634- performing the leak testing on these 1413) between 7.15 a m. and 4.15 pm 1413) betwun15 a m. and 415 p rn three vah es wiu require one or both of Persons planning to atter.d this meeting Persons planning to attend this meeting the following plant conditica.s:

are urged to contact the above named are urged to contact the above camed (a) Reactor vessel head removal; Individual one or two days before the (b) Both RHR shutdown cooling loops scheduled meeting to be advised of any I"[,

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  • h'I,'

d ' a . rendered inoperable.

chamges in schedule, etc., which may changes in schedule, etc., which may The licensees han cunent}y have occurred. h ' "- C C'" d. scheduled the next reactor beed remcnal Date: April 18,198a- Date. Apnl18,19eA operation to occur during the fitet Thomas G. Mcomless. Theam G. McCrdesa, refueling outage, To render both loops of Aessew E m ao u AscwAt Tachmari Rim shutdown cooling inoperable, the A rstrtur Frm~re DWAv'nrcMec1 licensees would either be required to A cti*w A c o

  • e. eA ruman the drywell and ructor heads (n Dec. anaas Ed 6-et-a ass wJ [m Dec. 6uas Fded 4-214A tea aml and flood the nssel, or wak unul deca)

.ua,a cae rm e,umo coce ese a.m ENCLOSURE A

PRESENTATION SCHEDULE ACRS SUBCOMMITTEE ON WASTE MANAGEMENT TOPIC: DE MINIMIS AND BELOW REriULATORY CONCERN 1

ROOM 1167, 1717 H STREET, N.W.

WASHINGTON, D. C.

May 4, 1988 8:30 - 9:30 a.m. Introduction and Executive Session D. Moeller, Chairman 9:30 - 9:40 a.m. Welcome and Opening Remarks D. Moeller 9:40 - 10:30 a.m. BRC Policy Statement

- Introduction R. Bernero, NMSS

- Background K. Dragonette, NMSS i - Policy Statement

- Expected Petition / Status 10:30 - 10:45 a.m. BREAK Release and Decommissioning Criteria L. Rouse, NMSS, and 10:45 - 11:30 a.m. S. Neuder, RES

- Residual Activity Standards

- Residual Activity in Soils Genstones D. Cool, NLMSS 11:30 - 12:15

          • LUNCH 12:15 - 1:15 p.m.

Current NEA/lAEA Activities R. Cunnirgham, NMSS 1:15 - 1:45 p.m.

Integral Approach to Issues W. Labs, RES 1:45 - 2:45 p.m.

- Reprise of Commission Briefing

- International Conference Status

- Initial Ideas 2:45 - 3:00 p.m. BREAK 3:00 - 4:00 p.m. Executive Session 4:00 p.m. ADJOURN

, ENCLOSURE B

DOCUMENTS PROVIDED FOR THE ACRS SUBCOMMITTEE ON WASTE MANAGEMEH1,

-' WASHINGTON, D.C. -

MAY 4, 1988 Subject of Meeting: De minimis and Below Regulatory Concern

1. Memorandum from 0. Merrill to D. Moeller, et al,

Subject:

Addition-al Articles and Documents on the De Minimis Issue, (with .

Attachments), dated May 3, 1988

2. Low-level Radioactive Waste Policy Amendments Act, Section 10:

Radioactive Waste Below Regulatory Concern (no date)

3. Overview of NRC's Response to Section 10 of the low-level Radioactive Waste Policy Amendments Act of 1985, July 1987
4. An update of the EPRI Below Regulatory Concern Research Program Sa. Release and Decommissioning Criteria -- Current Practices for Residual Activity (and) Surface Contamination Soils (no date)

S b', Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material USNRC, August 1987 Sc. Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors, June 1974 Sd. Disposal of Onsite Storage of Thorium or Uranium Wastes from Past Operations, 46 FR 52061, October 23, 1981.

6. Residual Radioactivity
7. Irradiated Gems
8. International Activitics
9. ACRS (ACNW) Briefing, De Minimis and Below Regulatory Concern Policy Development, May 4, 1988 l
10. Memorandum from V. Stello, EDO, to Commissioner Bernthal,

Subject:

Bases for De Minimis Policy Development by Other Agencies (Refd:

l M880314), dated April 29, 1988.

ENCLOSURE C

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0.MERRILL

' WASTE MANAGEMENT

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.. ACPS SUBCOMMITTEE MEETING ON LOCATION Room 1167,1717 H St. NW., Washington, D.C.

DATE May 4,1988 ,

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0. MERRILL ACRS SUBCOMMITTEE MEETlHG ON WASTF MANAGFMFNT ._

LOCAT,10.'i Rton 1167,1717 H St. NW., Hashington. 0.C.

.DATE: May 4,1988 ATTENDANCE LIST PLEASE PRINT: ,

NAME BADGE NO. AFFILIATION .

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