ML20199C736
| ML20199C736 | |
| Person / Time | |
|---|---|
| Issue date: | 11/12/1998 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199C723 | List: |
| References | |
| SECY-98-225-C, NUDOCS 9901190097 | |
| Download: ML20199C736 (3) | |
Text
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NOTATION VOTE l
l RESPONSE SHEET l
TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DICUS
SUBJECT:
SECY-98-225 - PROPOSED RULE: 10 CFR PART 63 --
" DISPOSAL OF HIGH-LEVEL RADIOACTIVE WASTES IN A PROPOSED GEOLOGIC REPOSITORY AT YUCCA MOUNTAIN, NEVADA" Approved X
Disapproved Abstain l
Not Participating i
COMMENTS:
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Entered on "AS" Yes N No 9901190097 990112 PDR COMMS NRCC CORRESPONDENCE PDR S O ll 00
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Commissioner Dicus' comments on SECY-98-225:
. I approve publication of the proposed rulemaking. I concur with Cmr. Diaz' comments commending the staff for its work in this matter and the staff's initiative to include risk-informed, performance based criteria for pre-closure operations (alternative 1). I also approve the proposed rulemaking's approach with respect to its equivalent to 10 CFR 50.59. With respect to the nature of the licensing proceeding, I would prefer that the FRN be limited to noting that the matter is under Commission review as part of its broader efforts to improve the effectiveness of NRC programs and processes.
It is important to strive for uniformity in the regulatory process and this is a factor in my decision to approve the adoption of an equivalent to 50.59 cordingent on possible future revisions to conform it to revisions to 50.59. The need for uniformity is also a factor in my supporting the proposed radiation protection standards. The FRN should note that the standards are also consistent with those adopted by the NRC for termination of licenses. While the FRN recognizes NRC's statutory mandate to use EPA standards when they are issued, the FRN should make clear the Commission's position that the proposed radiation dose standards (1) are protective of the public health and safety and environment and (2) are consistent with national and international recommendations for radiation protection standards. The FRC should be revised accordingly and a markup is attached.
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l l-4 equivalent of (TEDE) 1 mSv (100 mrem) per year. In addition, pnor to permanent closure,-
reDository operations would need to be conducted such that public exposures be maintained as low as reasonabfy achievable. When the repository is closed, surface facilities must be d" commissioned in accordance with 10 CFR Part 20. Subpart E. Finally, during normal 1
oporations and anticipated operaticinal occurrences, the annual dose to any real member of the
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Pnt>lic, located beyond the boundary of the site, shall not exceed a TEDE of 0.25 mSv s
Ph mrem). This final dose limit, used in this regulation, is adapted from the dose tir:its specified in 10 CFR Part 72, for effluents and direct radiation dunng normal operations and anticipated operational occurrences, associated with a monitored retrievable storage installation (MRS). Like an MRS facility, the operations area at Yucca Mountain is expected to be a large J
Hutustnal facility equipped to handle the loading, unloading. and decontamination of spen'. fuel
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and HLW shipping casks; the removal and packaging or repackaging of spent fuel assemblies and HLW canisters; and the sealing, handling, transport. stowage and periodic monitonng of canisters to contain the spent fuel and HLW during operations. Because the activities
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contemplated for the operations area prior to repository closure pose similar radiological hazards, during normal operations and anticipated operational occurrences, to those posed at an operating MRS, the Commission is proposing that the dose limits for the operations area be linose applicable for the MRS, from planneo discharges and from direct radiation during Ol>erations. (Radiation from other fuel cycle operations, anticipated for an MRS or independent Mpent fuel installation (ISFSI) that might be co-located with other operating nuclear facilities, is
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not anticipated at the operations area, because fuel cycle operations are not likely to be located th the region).. The 0.25 mSv (25 mrem) limii also provides consistency with requirements for l
l Other waste management facilities (e.g.,40 CFR 191.03(a),10 CFR 72.104 and 10 CFR 6140) t,, t.),
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