ML20154D720
| ML20154D720 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1988 |
| From: | Steindler M Advisory Committee on Reactor Safeguards |
| To: | Moeller D NRC |
| Shared Package | |
| ML19306H915 | List: |
| References | |
| REF-WM-1 ACRS-GENERAL, NUDOCS 8805190314 | |
| Download: ML20154D720 (3) | |
Text
________-_ _
- pMaev9'o UNITED STATES g
8' U
o NUCLEAR REGULATORY COMMISSION
- E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20656
"% , , ;*'[
May 6, 1988 i
MEMORANDUM FOR: D. W. Moeller 1
FROM: M. J. Steindler '
SUBJECT:
DECISION MAKING FOR "BELOW REGULATORY CONCERN" The meeting of the Waste Management Subcomittee on May 4,1988 on the subject topic uncovered, somewhat as expected, a tangle of issues, existing numerical values, past practices, and uncertain basic data about Below Regulatory Concern (BRC). It may well be that the indi-vidual Comissioners have not had the time to study in-depth this convoluted topic. It might be noted, however, that the question posed by ther, and reflected in SECY 88-69, the transcript of the briefings by the staff, and the questions posed by Comissioner Bernthal are all pointedly directed at important aspects of the BRC controversy. Fur-ther, the basic decision identifying a policy base for the NRC may well be made on non-technical considerations, but the need to identify conse-quences of such decisions falls on the technical comunity.
If the Comission desires to participate in the October international meeting on BRC and there put forth a thoughtfully developed U.S. posi-tion, we as advisors should aim to provide them with a comunication that, together with the transcript of the subcomittee meeting, could clarify the issue. In that connection, it may be that the following could be of use:
i I. Some basic principles for evaluating BRC levels.
l l I believe that there were a number of basic principles enunciated in masked fashion during our meeting. Some appear mutually contra-dictory and very likely no two or more could be applied simulta-neously. These include:
A. If an analysis shows that, for a given level (concentration)
- of radioactive material, regulation of that material will not reduce the risk from it, then that level is BRC; B. If regulation requires expenditure of more than $1000 per man-rem avoided, that level is BRC; C. If the risk from a source is comparable to that from natural background (or some fraction thareof), that source level is BRC;
$ 9hk)(8 ENCLOSURE 2
- D W. Moeller, ACRS Member 2 D. If the risk from a source cannot be experimentally measured, then that source is BRC; E. If the risk from a source is less than that from known sources now not regulated, then the source is BRC; F. If the risk from a source is equivalent to the reactor safety goal, currently believed to be in the range of 12 - 20 mrem /y, then that source is BRC; G. If the risk from a source is 0.1% of other risks accepted in society, then the source is BRC; H. If the risk from a source is calculated to be less than the risk used by other agencies to define their BRC, then the source is BRC for the Nuclear Regulatory Comission; I. If a source is arbitrarily determined to represent a low risk, declare this to be BRC but agree to examine the evidence periodically to evaluate the need for modification of the BRC level; J. If ALARA practices no longer yield a reduction in risk, that level is BRC.
Clearly, each one of these "principles" can be applied to scenarios that will yield a number, generally a source strength, that can be translated into an absorbed whole body equivalent dose and a risk level. This listing contains "principles" that would likely not be acceptable by a society that does not treat relative risks on a rational basis, i.e.
risks from sone sources are more acceptable than the same risk from other sources.
II. Average value of the BRC risk It seems likely that some of the items I. A-J are unsuited for further consideration based on the likely magnitude of the con-tained risk. Eliminating these (e.g., I.G., I.D.) reduces the list of potentially applicable bases for setting the BRC to those whose calculated alues may fall into a relatively narrow range.
. I believe this range could be defined and may well be close to the 1-10 mrem /y that was mentioned as seeming reasonable on the basis of what we heard. While the process of "expert opinion" is j
. acceptable in some quarters, the Comission may require something I different. It may be useful, therefo"e, to urge the staff to J provide numerical values for the estimated risk based on the selected "principles" noted in Section I. l 1
III. Conclusion I believe we can conclude and transmit to the Comission two coments pertinent to the BRC matter before it.
l l
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i o D. W. Moeller, ACRS Member 3 A. The levels of BRC in tenns of curies or curies per unit mass, i.e., a measurable value, no matter how derived, should use
.; individualhealthrisk(cancerdeaths)asitsbasis.
B. While it is difficult to rationalize a narrow (single) basis for determination of the risk that is derived from sources that are BRC, it appears that there is a good chance that an acceptable risk will result from a BRC source that yields an annual effective dose equivalent in the neighborhood of 10 mren. Therefore, if many pertinent principles" result in this value, this would point to the rationalization of such a risk.
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