ML20195H307
| ML20195H307 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1999 |
| From: | Merrifield J NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20195H262 | List: |
| References | |
| SECY-99-098-C, SECY-99-98-C, NUDOCS 9906160325 | |
| Download: ML20195H307 (2) | |
Text
{{#Wiki_filter:NOTATION VOTE-RESPONSE SHEET TO: . Annette Vietti-Cook, Secretary.. FROM: COMMISSIONER MERRIFIELD
SUBJECT:
SECY-99-098 - PUBLICATION OF AN ISSUES PAPER ON RELEASE OF SOLID MATERIALS (CLEARANCE), IN THE FEDERAL REGISTER. FOR PUBLIC COMMENT AND FOR USE AT PUBLIC MEETINGS Approved t. . Disapproved Abstain Not Participating __
. COMMENTS:
SEE /) 77/9 (t/CD /6menCA;73 i 1
.SIGNKT)fffE /#>
4-lMi n DATE Entered on "AS" Yes No CORRESPONDENCE PDR ' L_ Db/ Lo 3)s'
cc i,. p 1 L , , Commissioner Merrifield's comments:- l approve publication of an issues paper on release of solid materials (clearance), in the Federal ! Reaister for public comment and for use at public meetings. This will be a controversial action; and an issues paper to focus the discussions would be beneficial. The Commission directed ; that this rulemaking be conducted in an expedited manner. Accordingly, the staff has rescheduled several other rulemakings and development of regulatory guidance documents to accommodate the Commission's desires. I will support some refinements to the issues paper, as suggested by either the Chairman or My fellow Commissioners, as long as the requested changes do not unduly delay the start of the public meetings on this important issue.
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(*****/ June 15, 1999 l c, SECRETA RY MEMORANDUM TO: William D; Travers ' l Executive Director for Operations ) FROM: Annette Vietti-Cook, Secretary -
SUBJECT:
STAFF REQUIREMENTS - SECY-99-098 - PUBLICATION OF ' I AN ISSUES PAPER ON RELEASE OF SOLID MATERIALS
-(CLEARANCE), IN THE FEDERAL REGISTER, FOR I PUBLIC COMMENT AND FOR USE AT PUBLIC MEETINGS [)gM _ !
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c The Commission has approved publication in the Federal Reaister of an issues paper on the 4 release of solid materials from licensed facilities which will form the basis for discussion at public m'eetings as part of an enhanced participatory rulemaking process. ' The staff should incorporate the changes provided in the attachment prior to publication of the Federal Reaister notice (FRN) and issuance of the press release. The staff should publish the issues paper and announce the ;
-dates of the facilitated public meetings in the same FRN. '
(EDO) -(SECY Suspense: 6/25/99)
Attachment:
As stated I l cct Chairman Jackson l Commissioner Dieus Commissioner Diaz Commissioner McGaffigan Commissioner Mernfield OGC ClO CFO OCA
.OlG -
o ' OPA-Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail) PDR DCS a YM*. WP I g gly
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Attachment
; Changes to the Federal Reaister Notice i 1; ; On page 1, in the " Summary" section, add the following at the end of the paragraph: j
'*NRC also intends to conduct four public meetings beginning in August of this year. This I jdocument provides background and topics of discussion for those meetings.
- 12. L On pa'ge 1, next to the last line. correct the spelling of ' Regulatory.' l 3I . Oh page'2<under " Background", line 1, insert ' regulatory' after ' specific'so it reads ' )
- the Commission currently has no specific regulatory requirements . '
= 4; On page 2, under " Background";line 2, insert a new sentence after the period which l reads 'Even though the NRC does not have requirements in this area, it still receives 1 requests from licensees.for release'of solid materials which it must evaluate on a case-
. by-case basis using existing guLnca or case-specific criteria.
- 5. . On page 3, in the first full paragraph. line 2, delete the comma after ' activities.'
- 6. On page 3, insert a new sentence at the end of the first full paragraph: "The NRC will also utilize its website to disseminate'information and solicit input "
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- 7. . On page 5, paragraph 2, lines 3 and 4, replace a nuclear facility' with 'an NRC-licensed ;
activity'.so it reads ' .. and decommissioning of a nucl car fac;hty an NRC-licensed ' activity and'also require ,,' :
- 8. On page 6, paragraph 2, line 5, insert 'otherwise' after 'not'so it reads ' . but does not
'otherwise aoaress release of solid material.
l # ~ 9. . On page 6, add the following to the footnote: 'In addition,10 CFR 40.51 and 40.13 contain transfer or unimportant quantities provisions, respectively, which are the subject
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1of a separate Commission-directed initiative on Part 40 and are outside the scope of this ! effort.' ' ' '
> 10. . . On page 6, in footnote 1, verify section 36.58(e) is the procer example since there is no '
'section 36.58.
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- 11. l On page 7, paragraph a), revise line 3 to read ' . research and development facilities. :
peoplc vehe use licca;;d gauges in thek bus lnces, etc. and industrial use of various !
? devices including gauges, meas'uring devices, and r adiography.'
; 12.' : On page 7, paragraph b), line 2, replace ' hospital'. with ! health care facilities including'so it reads 'w larger educational or hosp lt;l health care facilities including laboratories . '
- 13. ' l On 'page '7, paragraph 1), line 1, insert ' solid' before ' material' so it reads 'the solid
. materials in these areasf. !
g '14/ O_n page_8, paragraph A.1.3 Iine 6 delete ' complies with the requirements of Part 20 by' and replace ' evaluating' with ' evaluates'so it reads 'The NRC cornpl:cs vedh the t p i 'n ;
O > p ' requ;rernent, cf re-t 20 by cv;;u; Sag evaTu3tes requests for release .. '
- 15. - On page'8; paragraph A.1.3, 'line 8, insert before the period 'for compliance ivith Part 20
~ requirements'so it reads * . or other case-specific criteria for compliance with Part 20
' requirements.' -
51 6.. On page 8, paragraph (a), line 6, insert ' detection' before ' capabilities'so it reads '
. which were based principally on the detection capabilit,'as of readily available ....'
11 7. On page 8, paragraph (a), line 7, insert a new sentence after the period which reads 'The
. surface contamination levels were not based on the potential dose to an individual that (may result from coming in contact with the released materials although such exposure is estimated to be low.'
- 18. On page 9, paragraph (b), line 6; delete the first two commas.
- 19. - '.On page 9, paragraph (c), line 5, revise the next to last sentence so it reads ' . and evaluation of the ^ituation, which in the past has been used to autflorize various releases of contaminatet material.
- 20. ~ On page 9, paragraph (c), delete the last sentence.
.21. 'On page 10, paragraph A.2.1, delete the first 3 anes and revise the beginning of the 4*
line as follows ' Based on the issues and concerns described in Section A.1, the Commission, on June 30,1998, directed Ws the staff to consider . . '
- 22. _ On page 10, Paragraph A.2.1 lines'5 and 6, delete 'of,' after ' considerations' and replace the' comma after ' review of' with 'the'so it reads ' . . so that licensee considerations-of, and NRC review of; the disposition of slightly contaminated . .'
2i On page 11', paragraph (1), last line, insert ' release for' prior to ' unrestricted'so it reads
. this issues paper, the term " release for unrestricted use" is generally used.'
24; On'page 12, paragraph 2,line 3, spell out Environmental Protection Agency and Department of Energy.
- 25. On page 12, paragraph 2, line 4 insert 'on behalf of the U.S.' after ' review'so it reads '
provide input and review on behalf of the U.S. In development . ' 26.; _On page 12, paragraph 3, lines 8 and 9 should be revised to read * . constraint of 0.01 b _ millisievert (mSv) per year (1 millirem [ mrem] per year) (mremlyr) of exposure-ef to an individual members of the public from likely' exposure scenarios and 0.1 mSv/yr (10 mrem /yr) from 'unlikely' scenarios.'
- 27. - On page 12, paragraph 4, the staff should mention other international and individual country' efforts (e.g., CEC draft standard and France, Germany, Sweden, Taiwan, and U.K.).
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- 28. ' On page 13, paragraph 2, l'ine 1, the staff should provide additional information to aid in a m
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iocating' Section B;1 . ; i i29c .. On page 13, paragraph 2, the staff should include a reference to ISCORS. i
- 30. On page 13, revise the end of paragraph 2 to read . throughout the rulemaking
; process and has invited EPA to be a member of the NRC working group.' 1 l
31c ion page 13, paragraph 3, line 2 replace 'those' with 'some'so it reads ' . range of materials', including these some which contain . , '
- 32. On page 13, paragraph 3lline 4, revise the.end of the sentence to read ' . has j concentrated levels of radioactive materials (e.g. uranium, radium, thorium).
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- 33. On page 13, paragraph 3, line 5, replace ' concentrated uranium' with ' radioactive
, material'so it reads ' ... used in building materials; the concentrated uranium radioactive i materialin the coal ash can result ., '
j 34? On page 13, paragraph 3, the staff should define what EPA standard is being referred to j in the last sentence.
- 35.' On page 14, paragraph 1, line 1, replace ' standards' with ' screening guidelines'so it reads ' , active in the development of standards screening guidelines for import into the U.S. of . .'
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- 36. On page 14, paragraph 1, revise the 2" sentence to read ' EPA has been working with l
; the NRC and other Federal and international agencies the international-Atomic Encrgy
' Agency (!AEA) and the U.S. Department of State in thcsc cfforts.
37f ' On page 14, add a new sentence at the end of paragraph 1 as follows 'The importing of - contaminated materials cleared by other countries into the U.S. which does not have in place generally applicable standards for this purpose, raises questions about the regulatory status of such materials after they enter the U.S.' i
- 38. ' On page 14, paragraph 2, line 2, insert
- generally' after 'Although'so it reads ' ..
Although generally not licensed by the NRC, the DOE , '
- 39. On'page 14, paragraph 4 line 2, insert 'by DOE' after 'made'so it reads ' . would have to be made by DOE as to whether DOE . '
40'/ On page 14, paragraph.4, fine 2 revise the sentence to read L as to whether DOE would in the interest of consistency adopt the standards . , : 41. On page 14, paragraph 4, the staff should address whether there is a corollary such that i if DOE decides to release RAM into general commerce, would the NRC be required to authorize distribution of that material. i 42. . On page.14, paragraph 5, the staff should insert a new first paragraph under ' State Governments' as follows: o s
F l-States face the came issues and needs th'at the NRC does and must also consider issues associated with release of naturally-occurring and accelerator produced materials f (NARM). The Conference of Radiation Control Program Directors (CRCPD), an organization of state radiation agencies that develops suggested regulations, has i estabhshed a committee to look into issues associated with release of solid materials
. The staff should add a new subsection as follows:
Other star,dards settina bodies - Various other organizations are involved in setting !' standards which can impact decisions related to alternative courses of action for release ! l- of solid materia's. j i One of those organizations is the National Council on Radiation Protection and Measurements (NCRP). The NCRP is a nonprofit corporation chartered by the U.S. Congress to review current significant studies made by other health research bodies, to develop and disseminate information and recommendations about protection against radiation, and to cooperate with national and international organizations with regard to these recommendations. The NCRP has made recommendations in its report NCRP No.116 regarding acceptable levels of radiation exposure to the public, including levels considered to present trivial health risk. In addition various industry groups (e.g., the American National Standards , Institute) set standards regarding a vaaety of areas including equipment design and operation, facility maintenance, and contamination levels in radioactive effluents. NRC must be cognizant of activities in these areas because Public Law 104-113 (passed by Congress in 1995) requires Federal agencies to use technical standards that are developed or adopted by voluntary consensus I standards bodies unless the use of such a standard is inconsistent with applicable law or otherwise impractical. 43.- On page 15, paragraph 2, line 3, insert a new sentence after the period as follows: 'BRC was an approach proposed by NRC to address a Congressional directive in the Low-Level Radioactive Waste Policy Amendments Act of 1985.'
- 44. On page 16, paragraph 1, lines 5 through 8, delete the sentence 'Also, un!ike the BRC Policy . . Procedures Act (APA).'
- 45. On page 16, paragraph 1, lines 10 ano 11, delete 'as a supplement to the normal APA process,'so it reads ' . addition, as a supplement to the ncima: APA process, the NRC would enhance .
- 46. On page 1' 6, paragraph 1, last line, insert 'and' after 'rulemaking'so it reads ' . made through rulemaking and not through a policy .
- 47. On page 16 paragraph 2, revise the 1 sentence to read ' . in rulemaking is-fer the NRC staff to development of a proposed rule,for Commission consideration . . preparation of a final rule, for Commission review and approval 9
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, ' 48. .On page 18, paragraph 2, revise the 1ife'nfence to read * ... NRC generally uses the cderle en public dose limits ... ' !
- 49. ' On page 20,1 full paragraph, line 5, replace ' evaluation with ' analyses'so it reads *
. an environmental cvekaSen analyses under NEPA and an . . '
l50 On page 21, insert a new item 3 as follows (and renumber items 3 and 4): (3) To what extent would such a rule contribute to maintaining public safety, enhancing
. the effectiveness and efficiency of the NRC, building public confidence, and reducing unnecessary regulatory burden?
'51, On page 22, last paragraph, revise line 5 to read * . use of this material could include
. doses of 0.1 mSv/yr (10 mrem /yr),0.01 mSv/yr (1 rnrem/yr), Md 0.001 mSv/yr (0.1 mrem /yr) above background .. .'
- 52. On page 22, last paragraph, revise lines 8 - 11 to read ' . country where people live, lifestyle, and other factors, andhHm averages about 3 mSv/yr (300 mrem /yr) but may
- vary from 1 to 10 mSv/yr (100 to 1,000 mrem /yr); (b) NRC's public dose limit is 1 mSv/yr (100 mrem /yr) (c) the dose from . . natural background (about 0.1 mSv/yr or 10 mremlyr), (d) a person receives 0.1 mSv (10 mrem) on a round-trip .
The staff should verify the value in (d) to determine if it should be 4-5 mrem.
- 53. On page 23. line 1, insert 'and Measure.=.ts after ' Protection so it reads * . Council on j Radiation Protection and Measurements (NCRP) considers . '
54.- .On page 23. line 2, insert 'for release for' after ' considered'so it reads ' . the level being .
. considered for release for unrestricted use .
- 55. On page 23, paragraph (3), in lines 1 - 2, replace 'had radioactive service in the facility' with more common terms to' clarify the meaning.
- 56.- On page 23, paragraph (4), add an *(s)' to ' alternative'.
- 57. On page 23, add a new paragraph (5) as follows:
(5) Other decision making factors, i.e., non-dose based criteria.
- 58. - On page 23, in the section on "Facters in decision-making:", line 1, 'in'should start with a lower case letter and delete 'could'.
- 59. On page,23,'in the section on " Factors in decision-making:", lir,e 2 after ' considerations' insert ' impacts on'other industries, resource conservation,'so it reads ' . cost benefit considerations, impacts on other industries, resource conservation, the capability to .
60- On page 24, line 1 at the top of the page, revise the sentence to read * . processing and disposal impacts, impacts on biota, land use impacts, impacts on radiation ser:sitive industries, and . / < ~
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- 61. . On page'24, paragraph 1, line 6,, revise (Fe' sentence to read ' ., example the thosc non-redescel impacts associated with mining, fabricat;on, and transport .
(62.o On'page 24, as'p3rt of the factors NRC will use in deci.sion-making, insert 2 riew g l paragraphs as follows: . NRC recenhy published a draft' report for comment on radiological assessments for clearance of. equipment and materials from nuclear facilities, NUREG-1640 (2 volumes). The report lirovides' dose factors for both surficial and volumetric radioactivity and '
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compares them with results from Regulatory Guide 1.86 and from EPA values, European
. ! Community recommended clearance levels and IAEA draft clearance levels'.
Most of the aforementioned policies, guidelines, recommendations and standards are
- dose based and thus are intended to be protective of public health and safety. In addition to protection of public health and safety, the U.S. Atomic Energy Act, as
. amended,'also charges the NRC with protection of property. Some industries may be -
adversely affected by materials that are cleared based upon dose based standards becausebf sensitivity to radiation effects from the cleared material, e.g., the film and electronic industries and the metal recycling industry which performs radiation monitoring .
. of metal scrap to detect and protect itself from radioactive sources accidentally mixed -
with the scrap.'
- 63. On page 24, last paragraph, lines 2 - 3 fro,a the bottom. insert 'and' after ' analysis' and replace 'of' with 'in'so it reads ? . some of the analysis and approaches in-of the EPA report are . ' '
- 64. On page 25, paragraph 1, revise sines 7 .9 to read ' courses c' action, including sui .sys at licensed the eueleer facilityles, as well as surveys at non-licensed facilities that may use or receive released solid materials, to verify . . for having to respond to and verify radiation detection or contamination "fa's; positives" alarms'aterap facilities handling released materials (3) .
- 65c On page 25, paragraph 2, insert a new sentence after the 1" sentence as follows: 'The ability to measure radioactivity depends on both the amount and type of radioactive material.' '
- 66. On page 25, paragraph 2, line 5, insert ', if not impossible,' after ' difficult'so it reads '
1could be extremely difficult, if not imp ssible, to implement .
- 67. . 'On page 25, paragraph 2, lines 5 and 6, insert ' limited' before ' capability' and insert ' field' before ' survey'so it reads ' natural background and the limited capability of field survey instruments . *
- 68. - On page 25,' paragraph 3, line 2, insert ' requirements, guidelines,' after consider and add a comma'after ' policies'so it reads ' . the NRC would also consider requirements,
~ guidelines, policies, and precedents set by . .'
[ (69.- . On page 26, paragraph (A)(1), line 1. insert 'individuar after 'What'so it reads 'What individual dose level is . ..' s
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- 70. ' On page 26,' paragraph (A)(1), revise line 3 to read ' . . dose level (for example, 0.1,
{ i 0.01,'or 0.001 mSv/yr [10,1.0, or 0.1 mrem /yr], or no dose .. .'
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L71.~ On page 2'6,' paragraph (A)(1), revise lines 5'and 6 to read ' . . solid materials not be l permitted if they are potentially contaminated from the use of had b;ca uscd for red!cecnic scrs;ce or b;;n in arcas 'vehora licensed radioactive material ' vias used or stored?-- l L72; ,On page 26, paragraph (A)(2)(i), line'2c replace 'in addition to' with 'such as'so it reads
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; . exposure to people,'such as in addWon tc those already co.7sidered . .
- 73.~ $On page 27, top paragraph;line 2,' delete ' expect to'.so it reads * .. member of the public .
;- could re sonably expect tc be exposed.'
174. On page 27, paragraph (3),: add a new sentence at the end as follows: 'To what extent is - there a potpntial that a single scrap facility would handle inputs of released solid
' materials from several different licensed facilities?'
275. On page 27, add a new paragraph after paragral'1 (4) as follows:
. (5) How should the impacts upon industries that have special concerns about the presence of radioactivity in materials, e.g. him.. electronic, and metal recycling, be considered and factored into decision making?
- 76. = On page 28, paragraph (B)(1)lline 1, correct the Executive Order number to '12291'.
-77 La page 2d,~ paragraph (B)(4), line 3. insert radiation' before ' survey'so it reads ' . or
. scrap yard based on a radiation survey at that point?'-
- 78. On page 29, paragraph (C)(1), revise line 1 to read 'What is the capability-to of surveying
. materials ., '
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. 79,; ;On page 29, paragraph (C)(1), after the 15 sentence, add two new sentences as follows:
'Are these survey capabilities readily available to licensees? Should there also be provisions for survey capability at receiving facilities and what should be the nature of
- those provisions?'
- 80. On page 29, after paragraph (C)(2), add a new paragraph as follows:
(3)'.How should criteria for release of solid material be incorporated into NRC's regulations, i.e., should they be expressed as a dose criteria and/or be expressed as
' concentration values in'different media based on specified dose objectives and standard models for exposure?'
- 81. On page 30, paragraph (D)(1)(a), revise the last sentence to read 'How should efforts by the U.S.' Ocpedment of State and the EPA to set import screening guidelines standards be considered?
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- 82. On page'30, paragraph (D)(1)(b), revise'tfi[2'* sentence to read 'To what degree-How l s - should standards set by the NRC be. consistent with other genera lly app : cab le EPA standards, such as for cxemp's as rcleted ic those for recycled , ' In line 4, insert
'could occur
- after ' problems
- so it reads ' . l what potential problems could occur if EPA later issues . '
83< On page 30, paragraph'(D)(1)(d),' add a new sentence to the end as follows: 'Are
' industry standards currently available, or anticipated during the time frame for this 1 rulemaking, that could be adopted in lieu of or in addition to NRC requirements on i release of solid materials?
~ 84. ..On page 31, paragraph (f), insert 'and other' after ' economic'so it reads * ,, are the economic and other impacts of . .'
- 85. On page 31, paragraph (g), line 5, replace 'that' with 'to which'so it reads ' , the extent that to which Agreement State i '
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- 86. On page 31, paragraph'(g), revise line 6 to read ' . to ensure that an adequate and I coherent .. .'
- 87. On page 31, paragraph (2), revise line 1 to read * .. public dose limit of 100 mrem /yr (1 mSv/yr)in 10 CFR . .' j
- 38. On page 31,; paragraph (2), revise line 2 to read ' . a dose criterion of 25 mrem /yr (0.25
-mSv/yr) for release of .
- 89. ^n page 21, paragraph (2), revise line 6 to read * . and land at a site to 25 mrem /yr 0.25
. mSv/yr).' '
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- 90. - On page 32, paragraph (1), line 3, replace 'for some' with 'in an'so it reads ' . could be
. recycled for use for some in an industrial product . '
- 91. On page 33, paragraph 2), line 1, insert 'slightly contaminated' before ' solid'so it reads '
. restrict the release of slightly contaminated solid material from . '
On page 33, paragraph 2), insert a new sentence after the 1 sentence as follows: ' Solid 92( ;
. material with higher. levels of radioactive contamination would continue to be handled as radioactive waste and be disposed of at licensed facilities.'
93', On page 33, last paragraph, line 4, insert 'and local governments' after ' States'so it > reads.'Several States and local governments currently have . ' f.
'947 On page 33, last paragraph, revise line 7 to read ' . landfill under a use restrictedion use, but thet it could be removed . '
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- 95. On page 33, last paragraph, add 'or reused' at the end so it reads ' . from the landfill and sold as scrap or reused.
- 96. On page 34, paragraph (1), line 2, delete 'that which was done for'so it reads ' .use i
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u p; - (similar to that which it was dons for thely..%.=icense termination . ' I 97J . On page 34,' paragraph (2), revise the sentence to _ read 'If soder what types of restricted i j4 uses should could the metenal be considered?' . t :c
- 98. : On page'34, paragrapb (3), revise the 1" sentence to read ' . controls could reasonably be pl aced on the procds of restricting use to . '
- 99. : On page.34, paragraph (3), add a new sentence efter the 1" sentence as follows: 'Would these controls be reasonable?'
i I 1100., On page 34, paragraph (4), revise the 1" sentence to read 'How long would the use metenal bc ablc to be restricted?' q 101. On page 34, paragraph (5), line 2, insert 'or tracking' after ' regulation' so it reads ' continued in regulation or tracking of the material?' 102. On page 35, paragraph (6), revise the 1" sentence to read 'What type of public involvement should there be in decisio'ns concerning restricted use of materials should
' therebe?
103. On page 35, paragraph (6), revise the 2"d sentence to read ' . affected parties when { proposing pleetng a site inte for restricted use? 104. 1 _On page 35, paragraph (6), line 9, add 'and uses' before the period so it reads ' . fo, ; restricted use in different areas and uses.
.105. L On page 35J uaragraph (6), revise the last sentence to read 'Can this potentia l problem ;
be addicssed 30 as to ;nclude a meaningful public involvement process be developed for setting restrictions ... ' 106. On page 35, revise paragraph (7) to read 'How should considerations and predictions of future public uses usages 'of materials and the restrictions on those materials, which could bc d;"; cult to mahc, be developedso-es [SAJ deletion) to provide credible
- approaches for restricted use?'-
107. On page 35, add to the end of paragraph (8) 'provided the controls remain effective'so it reads ' . same as for unrestricted use, provided the controls remain effective.' 108. . On page 36, paragraph (1), revise lines 4 and 5 to read ' ' become available and also to-
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sise represent most of the volume of slightly contaminated material available for release from NRC-licensed facilities into the public sector, other than soil.' 109. ion page_37, revise the if paragraph (3) to read * . completed for other slightly
. contaminated materials nccd;ng dlspositen and potentially avaiiable for release.'
110.- On page 37, revise the .last paragraph to read ' . at a later time for certairreHhe [SAJ deletion) materials if the impact to all affected parties including the regulators is too great or the analyses too complicated or time consuming?
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r a 111. I On page 38, revise paragraph (1) i) to r ad: $ .i). Is it appropriate to proceed withiust certain materials, including steel, aluminum, s copper, concrete, and soil,'so that rulemaking can be done in a timely manner using the ,, 'information developed for these materials in NUREG-1640, and associated analyses as
, described above, as input to the environmental analyses and regulatory analyses, acdd to supper: a rulctna'ddg? Would experience gained with the rule on steel,.
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c aluminum, copper, concrete, and soih be useful in evaluating requirements for release of dc;llng velth other materials later? ] 112T -On page 38, paragraph (1) ii),' revise the last sentence to read ' . actually requesting
> release for today or are anticipated over the next decade?'
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- - 113. - 3On page 38/ paragraph (2), revise the last sentence to read * . these materials currently {
exist or are they under development?'. 114 On page 39, top paragraph, add a new sentence at the end as follows: 'If the rulemaking ; establishes dose objectives for release and implements these objectives through tables' i of values fo,r specific materials, should the dose objective also be used to guide case-specific release of other materials through licensing actions or exemptions?' ( 115. On page 39, revise paragraph (4) to read 'Whatetc the irnpiicaucas for Altcrnatives 1,2. and 3, l.c., vshot would be the associated costs - effective survey methods for ddferent j matertels, and dose impacts'of the alternatives?' 116.. ~ On page 39,pragraph (5), revise the first sentence to read ' . extended b cover _ materials et that may be released from. nuclear facilities operated by the DOE fac l;ucs?'
' Delete the last question (If so, how should that be done?).
Changes to the Press Release 117. At the end of the 1" paragraph, add 'from licensed facilities'so it reads ' . amounts of residual radioactivity from licensed facilities
- 1'18. In paragraph 2. revise line 1 to read ' . revising its regulations in 10 CFR Part 20 to
' establish requirements '
c119. Lin paragraph 2, revise the 2" sentence to read 'The NRC currently decidcs on evaluates licensee requests for release of solid materials on a case-by-case basis using existing guidance. Although it ;lrdedy NRC has release limits inpleee Part 20 for air and liquid emissions from licensed facilities.' =}}