ML20151S321
| ML20151S321 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1988 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| REF-10CFR9.7 M880314, NUDOCS 8804280281 | |
| Download: ML20151S321 (1) | |
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IN RESPONSE, PLEASE p e2 "o REFER TO: M880314 g g vg#o* UNITED STATES
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- j April 22, 1988 OFFICE OF THE SECRETARY MEMORANDUM FOR: Victor Stello, Jr.
Executive Director for O r,ations 1
FROM: Samuel J. Chilk, Secreta, O
SUBJECT:
STAFF REQUIREMENTS - BRI SFf.NG ON THE STATUS OF EFFORTS TO DEVELOP A DE hIWIMIS POLICY, 2:00 P.M., MONDAY, MARCH 14, 1988, COMMISSIONERS' CONFERENCE ROOM, D.C. OFFICE (OPEN TO PUBLIC ATTENDANCE)
The Commission has reconsidered the suspense date of September 9, 1988, for the staff's options paper on the de minimis policy requested in our previous SRM on the same subject (copy attached).
The staff is requested to submit by August 1, 1988, the options paper on a de minimis policy. This will assure the Commission reasonable time to review the proposed policy paper prior to the staff meeting with international groups on this subject. ;
(EDO) (SECY Suspense: 8/1/88) '
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Attachment:
As stated cc: Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr Commissioner Rogers OGC GPA K R - Advance WCS - 016 Phillips 8804280281 880422 PDR LOCFR PT9.7 PDR
IN RESPONSE, PLEASE REFER TO: M880314
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March 30, 1988 OFFICE OF THE SECRETARY Victor Stello, Jr.
MEMORANDUM FOR: ations Executive Director for O '
Samuel J. Chilk, Secretab FROM:
SUBJECT:
STAFF REQUIREMENTS -DIM BRI'CFING ON THE MIS POLICY, 2:00STATUS OF EFFORTS TO DEVELOP A DE .
P.M., MONDAY, MARCH 14, 1988, COMMISSIONERS' CONFERENCE ROOM, D.C. OFFICE (OPEN TO PUBLIC ATTENDANCE) l The Commission was briefed by the staff on the status of efforts to develop a Commission policy statement identifying a l level of radiation risk or dose below which government regu- ,
lation would be limited or unwarranted. )
i The Commission requested and the staff agreed to submit for i Commission consideration options for a Commission policy which establishes a generic number for exposures that are belowThe pap regulatory concern.
in our data base regarding radiation risk and should include the supporting scientific and legal rationale for all proposals.
Consideration should be given to the assumptions made in establishing de facto BRC levels that appear in current NRC regulations. The staff should also discuss the approach for l implementing such a number for multiple sources or licensed activities which does not require justification by individual licensees.
This options paper is to be acted upon by the ;
Commission prior to the staff meeting with international groups !
on this subject. 9/9/88)
(SECY Suspense:
(EDO)
Commissioner Bernthal requested the staff to provide him(ethe . g. ,
bases and analytical techniques used by other agencies EPA and FDA) in developing a de minimis policy / regulation on toxic waste (e.g., did they use a linear hypothesis?). 4/29/88)
(SECY Suspense (EDO) a n- , D L/ h r D O ' I'( a O g- iwa v ~RO }1T
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- b. Subr equent to the meeting, Commissioners Roberts and Bernthal regaested that the staff's options paper should explicitly identify the undergirding assumptions and projected risk estimates, both societal and individual, used in the establish-Specific ment of such BRC limits appearing in NRC regulations.
points staff should address include:
- In 1981, the Commission revised Part 20 to permit disposal ofscintillationcocktai}4and agimal H carcasses without containing regard for their trace concentrations of C or radioactivity. Also, specified curie amounts of both isotopes may be released annually into the sewerage system. Some regulatory control remains (e.g. record-keeping and limitation on use of contaminated carcasses) but in effect, once released to~the environment NRC exerts no further control, thereby setting a floor to ALARA for these specific isotopes and applications. What calcu-lations of societal and/or individual risk were employed in determination of these exempted levels? Were the models and assumptions the same as those used to arrive at tables of exempt quantities elsewhere in NRC regs?
- Staf f raises the question on page 4 of SECY-88-69 as to whether a definition of "radioactive" can be usefully established. Not mentioned in Eliclosure 2 is the fact that DOT regulations do precisely that (49 CPR 173. 403) .
For purposes of transportation, a radioactive material is defined as a material having a specific activity of 2 nCi/g or greater. This definition is incorporated in NRC regulations (10 CFR 71.10) not as a definition per se, but as an exempt quantity under NRC transportation regulations.
What is the origin of this 2 nCi/g limit? Given that a limit on total specific activity limit applies to any and all isotopes what assumptions were made regarding chemical form, pathways to the environment, critical organs, etc.?
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- For purposes of enforcing the many de facto BRC limits which exist in NRC regulation what explicit allowance is made for instrument and measurement uncertainties? (Recall, that the Commission only just recently promulgated require-ments for some measure of QA for dosimetry processors.)
- Acceptable levels of residual surface contamination are designed in Reg. Guide 1.86. Facilities with surface contamination levels below those specified may be released for unrestricted use. How many and what types of licensee facilities have been decommissioned using these criteria?
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- The Commission was recently made aware of some of the history behind the licensing of 3M static eliminator devices. The general license for these devices allowed up to 5 nCi of removal activity without any action being Do similar i required on the part of the general licensees.
What is the origin of provisions exist in other licenses?What assumptions of the 5 nCi allowable leakage rate?
risk were made to justify this number?
I cc: Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr Commissioner Rogers OGC (H Street)
GPA PDR - Advance DCS - 016 Phillips l
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