ML20198H074

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Notation Vote Approving & Disapproving in Part W/Comments SECY-98-245, Rulemaking Plan - Protection Against Discrete Radioactive Particle (DRP) Exposures (10CFR20)
ML20198H074
Person / Time
Issue date: 11/20/1998
From: Dicus G
NRC COMMISSION (OCM)
To: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20198H003 List:
References
SECY-98-245-C, NUDOCS 9812290232
Download: ML20198H074 (2)


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NOTATION VOTE RESPONSE SHEET TO:

John C. Hoyle, Secretary FROM:

COMMISSIONER DICUS l

SUBJECT:

SECY-98-245 - RULEMAKING PLAN - PROTECTION AGAINST DISCRETE RADIOACTIVE PARTICLE (DRP)

EXPOSURES (10 CFR PART 20) in part in part f

j Approved x

Disapproved 4 Abstain Not Participating COMMENTS:

Please see attached comments.

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Entered on "AS" Yes X No

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Commissioner Dieus' comments on SECi'-98-245 I approyu staff's request to develop rulemaking to amend Part 20 to address DRPs. I agree that the rulemaking should include a constraint value of 300 rads and I support the staff's rationale for doing this. It addresses industry's concerns over unnecessary radiation exposures and costs resulting from contamination surveys that are now being made to meet the objectives I

of the present enforcement discretion policy. I do not support the staff's recommendation to propose a limit of 1,000 rads for a DRP dose to tha skin. While there may be scientific support for proposing this value,it is twice that recommended in the draft NCRP report. The NRC has frequently and forcefully made the point that National radiation protection standards should be consistent with the recommendations of the ICRP and NCRP. We should not do anything that erodes that position. Incorporating the draft report's recommendation of 500 rads will maintain this position. It will be consistent with the proposed constraint value. Since the NCRP report is in draf t, staff should continue to monitor its development and, if the final recommendations depart significantly from the present draft, the staff should inform the Commission.

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