ML20154E700
| ML20154E700 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1988 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8809190101 | |
| Download: ML20154E700 (2) | |
Text
- ,
- ' ',g. ce g UNITE D SYATES
[
,m{g NUCLEAR REGULATORY COMMISSION j
wasmoros,o c.rosss
,\\,*'..../
August 31, 1988 MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations FROM:
Edward L. Jordan, Chairman Comittee to Review Generic Requirements
SUBJECT:
UPDATE TO MINUTES OF CRGR MEETING NUM6ER 140 The CRGR met to review the proposed rule revision to 10 CFR Part 20 on June 22, 1988 (see Minutes of CRGR Meeting No. 140).
The Committee devoted a full meeting to the review of the proposed 10 CFR Part 20 Rule.
This extensive review resulted in coments on two levels.
A number of specific concerns regarding wording and some provisions of the proposed rule were raised for resolution by the sponsoring office.
Additionally, significant general concerns were raised concerning the regulatory basis for issuance of the proposed rule.
The specific coments and concerns raised by the CRGR have been satisfactorily t
resolved.
In that regard, the rule, we believa, is now in an acceptable form for issuance.
However, reservations of the Committee regarding the basis for l
justifying the rule have not been completely resolved.
The sponsoring office, l
RES with support of OGC, believe that the rule redefines the level of safety, and thus, it need not be justified on a cost-benefit basis (see Enclosure).
The sponsoring office further indicates that the rule revises methodology, as well as the specific levels associated with radiation protection.
- However, because of the improvements attained through adoption of ALARA and the exis-tanct-of other standards, the estimated doses for mest workers and most members of the public will not be significantly affected with the implementation of this rule.
Consequently, some parts of the rule do not meet, in the view of i
the CRGR, the normal test for confirming that it is essential for safety.
Accordingly, the CRGR recommended in favor of forwarding the final rule to the Commission on the basis that the CRGR believes that the rule:
(a) is a significant enhancement over present-day standards and methodologies, and (b)
I will confirm needed benefits in radiation protection methodology, practice and standards.
Thus, it has our support, and we believe that these qualitative L
factors provide sufficient justification for issuance.
l In accordance with the E00's July 18, 1983 directive concerning "Fecdback and Closure of CRGR Reviews," a written response is required from the cognizant I
office to report agreement or disagreement with the CRGR recommendations in i
these minutes.
The response, which is required within five working days af ter i
receipt of these minutes, is to be forwarded to the CRGR Chairman and if there t
is di5 agreement with CRGR recomendations, to the E00 for decisionmaking.
t l
nil ' y/)
i
?
I 8809190101 880831 PDR REVGP NRCCRGR NEETING140 PDC g,
m.
'*\\
2-Questions concern hg these meeting minutas should be referred to Cheryl Sakenas (492-4148).
Ortsiast stest tg /
& 4. entsamen, m [ < #
Edward L. Jordai, Cha rean Committee to Review Generic Requirements
Enclosure:
As stated cc w/ enclosures:
Commission (5)
SECY Office Directors Regional Administrators CRGR Members W. Parler B. Grimes B. Morris Distribution: (w/o ene.)
- Cetttral-File
- POR (NRC/CRGR)
S. Treby W. Little l
M. Lesar E. Rossi C. Berlinger B. Doolittle (w/ene.)
CRGR SF (w/ enc.)
M. Taylor (w/ enc.)
E. Jordan (w/ enc.)
l J. Heltemes (w/onc.)
l J. Conran (w/ enc.)
l C. Sakenas (w/ enc.)
AE0 R
A D
C/CR CS
- cg C
temes ELJ an s ##/88
/88 g /$V88
.-