ML20202E412
| ML20202E412 | |
| Person / Time | |
|---|---|
| Issue date: | 12/01/1997 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Knapp M NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20202E418 | List: |
| References | |
| REF-WM-2 NUDOCS 9712080033 | |
| Download: ML20202E412 (10) | |
Text
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~g 4* UNITED STATES NUCLEAR REGULATORY COMMISSION
'f WAf HINGToN, D.C. 20565 0001 k...../ December 1, 1997 MEMORANDUM TO: Malcolm R. Knapp, Acting Director Offics of Nuclear Regulatory Research FROM: Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
REGULATORY OPTIONS FOR SETTING STANDARDS FOR CLEARANCE OF MATERIALS AND EQUIPMENT HAVING RESIDUAL RADIOACTIVITY in a memorandum dated November 14,1997, you requested concurrence from the Office of Nuclear Material Safety and Safeguards (NMSS) on the subject Commission paper. We concur on the Commission paper, but recommend modification to specific sections, to address our comments, which are provided below.
! 1. During the briefing for Chairman Jackson and Commissioner McGaffigan on September 2,1997, the Chairman requested that the Commission paper provide the status of the U.S. Environmental Protection Agency's (EPA's) schedule and intent for proceeding with
, its own rulemaking for clearance of materials. However, the Commission paper did not
! address this request. Also. the Commission paper and attachment contain inconsistencies concerning the schedule for the rulemaking. For example, page 3 of the Commission peper states that EPA * ..has not developed a formal schedule for proceeding with rulemaking." However, page 8 of the attachment states that *...the staff J
)
is not aware of wheiher EPA has developed a formal schedule for an EPA rulemaking on clearance," and on page 9 of the attachment it states, "...at present, their [ EPA's) schedule is unknown to NRC staff." It is our understanding that EPA recently decided to delay its recycle / reuse rulemaking, which may require changes in the options discussed in the Commission paper.
- 2. During the September 2,1997 briefing, the C.hairman also requested a cost-benefit analysis to support a Commission decision concerning a recycle / reuse rulemaking. The Commission paper should discuss the status of the development of such an analysis and the schedule for completing it.
- 3. It is our understanding that the Commission expects this paper to address volumetric soil contamination. The paper should state that such contamination is covered by the Radiological Criteria for License Termination rule and that the guidance being developed in support of this rule will address the release of volumetrically contaminated soil.
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Contact:
Anthony Huffert, NMSS/DWM %
(301) 415-6416
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M. Knapp 4. The Commission paper and its attachment should be co tsistent in the explanation of the technical bases for the surface. contamination limits contained in Regulatory Guide (RG) 1.86. Page 2 of the Commission paper states that "the values used in Table 1 of RG 1.86 were dose-based,' but page 5 of the attachment states that "...The values ... were based on the capabilities of readily available instrumentation at the time the guide was published in 1974." Similarly, on page 13 of the attachment it describes RG 1.86 surface contamination limits as "... internally inconsistent from a dose or risk basis." .
1 1
It is the staff's understanding that health and safety was a guiding principle for the ;
development of RG 1.86, but measurability concerns and precedence were also taken l into account in establishing surface contamination limits. Surface contamination limits ,
were established using the environmental background level for (Sr 90) in the 1960s (1000 dpm/100 sq cm) and then normalizing the limits for other radionuclides to Sr-90 based on the relative values of their MPCs. This method provided a measure of relative risk from each radionuclido. However, nuclide-specific limits were not incorporated into RG 1.86 because nuclide-group limits afforded measurement convenience.
The Commission paper and attachment should be changed to provide a consistent description of the technical bases for the surface contamination limits in RG 1.86 and its NMSS equivalent," Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Ucenses for Byproduct, Source, or Special Nuclear Material" (Fuel Cycle (FC) Management Directive 83-23).
- 5. The Commission paper and attachment should mention the as low as is reasonably achievable provisions in RG 1.86 and FC 83-23. These documents contain statements that direct licensees to: (1) make a reasonable effort to further minimize contamination below the surface contamination limits before painting or covering contaminated surfacec; and (2) demonstrate that a reasonable effort has been made to reduce residual contamination to as low as practicable levels.
- 6. The Inst paragraph on page 5 of the attachment summarizes a discussion from lE Circular No. 81-07, concerning the patential dose from surface contamination. The dose assessment contained in the Circular is based on information contained in NUREG-0613 and NUREG-0701. A more recent assessment of the potential dose from surface contamination was discussed in SECY-94-145, entitled " Increase of Tritium and Iron-55 Unrestricted Use Lirnits for Surface Contamination at Shoreham and Fort Saint Vrain." Using dose factors for surface contamination that were develope 1 for the
- building occupancy scenario in NUREG/CR-5512, the staff calculated an average dose of 10 mremly. It is recognized that tb surface contamination dose scenario from recycle and reuse may differ from the scenarios assumed in NUREG/CR-5512, NUREG-0613 and NUREG 0707. Nevertheless, it is recommended that the Commission paper provide information on the dose assessment contained in SECY-94-145.
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M.- Knapp
- 7. In the Commicslon Paper, the staff recommends that the Commission provide direction on certain rulemaking issues if the Commission selects either a major revision to RG 1.06 that would provide dose based volume and surface contamination limits *
(suboption ib) or an independent rulemaking to develop dose based regulations for c clearance (option 3). One related issue the staff has requested Co.' qission direction ,
i on is the selection of either clearance or restricted release of contaminated materials - ;
and equipment. Because this is an important decision that would significantly affect future NRC efforts on recycle / reuse, it is recommended that the advantages and disadvantages of each approach be articulated in the body of the Commission paper,
. t
- 8. The issue of implementation challenges, such as the measurability of low concentrations '
of contaminated material against natural background, is not specifically discussed in the Commission paper or attachment. Clearance limits based on measurability are implied
- in Section 4.1 of the enclosure, but not specifically add,assed as a potentially significant
, implementation issue. As noted in Comment 4 of this memorandum, measurability
- played an influential role in the development of RG 186 and continues to be a practical
- consideration when determining compliance with RG 1.86 surface contamination limits. '
Therefore, it is recommended that the staff's plans to address measurabihty be provided b the body of the Commission paper or Section 4.1 of the attachment.
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M. Knapp 3 December 1. 1997
- 7. In the Commission Paper, the staff recommends that the Commission proviue direction on certain rulemaking issues if the Commission selects either a major revision to RG 1.86 that would provide dose-based volume and surface contamination limits (suboption ib) or an independent rulemaking to develop dose based regulations for clearance (option 3). One related issue the staff has requested Commission direction t on is the selection of either clearance or restricted release of contaminated materials - )
and equipment. Bscause this is an important decision that would significantly affect future NRC efforts on recycle / reuse, it is recommended that the advantages and disadvantages of each approach be articulated in the body of the Commission paper.
- 8. The issue of implementation challenges, such as the measurability of low concentrations of contaminated material against natural background, is not specifically discussed in the Commission paper or attachment. Clesrance limits based on measurability are implied in Section 4.1 of the enclosure, but not specifically addressed as a potentially significant i implementation issue. As noted in Comment 4 of this memorandum, measurabilit'r ,
played an influential role in the development of RG 1.86 and continues to l'e a practical consideration wtan determining compliance with RG 1.86 surface contamination limits.
Therefore, it is r > commended that the staffs plans to address measurability be provided in the body e'ine Commission paper or Section 4.1 of the attachment, t
RISIRIBQRQlt N9700552 TCthwalFile d LLDP r/f NMSS r/f DWM r/f t/f PUBLIC RJohnson ACNW LBell TCJohnson MFeder4no . CJones RMeck NMSS D.O.r/f CPoland FCardile (Original signed by W. Kane for Carl Paperiello)
To receive a copy of this document in small box on "OFC;" hne entec "C" = Copy wrthout attachment / enclosure; "E" = Copy with l tttachment/ enclosure;"N" = No copy op/PnooPED/NoVEa4BEM as,1997 P:th & File Name: S:\DWM\LLDPWMHi\ RECYCLE.N21
- See previous concurrence l
OFC LLDP LLDP TEd. LLDP DWM NWAS/,
NAME AHuffert/bg* RNelson* EKraus* JHickey hilo
,DATE 11/20/97 11/20/97 11/21/97 11/ /97 ill /97 1s/ l /97 OFFICIAL RECORD COPY ACNW: YES 2L NO _ Category: Proprietary _ or CF Only _
IG : YES _ NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
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M. Knapp i and equipment. Because this is an important decision that would significantly affect future NRC efforts on recycle / reuse, it is recommended that the advantages and disadvantages of each approach be articulated in the body of the Commission paper.
- 8. The issue of implementation challenges, such as the measurability of low concentrations of contaminated material against natural background, is not specifically di= cussed in the Commission papers or enclosure. Clearance limits based on measurability are implied in Section 4.1 of the enclosure, but not specifically addressed as a potentially significant implementation issue. As noted in Comment 1 of this memorandum,' measurability played an influential role in the development of RG 1.86 and continues to be a practical consideration when determining compliance with RG 1.86 surface contamination limits.
Therefore, it is recommended that the staff's plans to address measurability be provided in the body of the Commission paper or Sec .14.1 of the enclosure.
DISTRIBUTION: N9700552 Tntral File LLDP r/f NMSS r/f DWM r/f t/f PUDLIC RJohnson AONW LBell TCJohnson MFederline CJones RMeck l NN'SS D.O.r/f CPoland FCardile i
To receive a copy of this document in small box on "OFC:"line enter: "C" = Copy without attachment / enclosure; "E" = Copy with j attachment / enclosure, "N" = No copy i
/
I CP/ PROOFED / NOVEMBER 28,1997 Path & File Name: S:\DWM\LLDP\AMH1\ RECYCLE.N21 __
- See previous concurrence OFC LLDP LLDP TEd. LLDP DWM NMSS NAME AHuffert/bg* RNelson* EKraus*/ JHickey CPaperiello DATE 11/20 /97 11/20/97 11/21/97 11/ /97 11/ /97 11/ /97 OFFICIAL RECORD COPY ACNW: YES 2L NO _ Category: Proprietary _ or CF Only _
IG : YES _ NO _
LSS:YES _ NO _ Delete file after distribution: Yes _ No _ j i
M.Knapp 3-and equipment. Because this !s an important decision that would significantly affect future NRC efforts on recycle / reuse, it is recommended that the advantage's and disadvantages of each approach be articulated in the body of the,Corhmission paper.
8.
/
The issue of implementation challenges, such as the meas 6rability of low concentrations of contaminated material against natural background, is not specifically discussed in the Commission papers or enclosure. Clearance limits based on measurability are implied <
3 '
in Section 4.1 of the enclosure, but not specifically addressed as a potentially significant ,
implementation issue. As noted in Comment 1 of this memorandum, measurability
~
, played an influential role in the development of RG 1.86 and continues to be a practical ,.
consideration when determ_ining compliance with RG 'i.86 surface contamination limite f Therefore, it is recommended that the staffs plans to address measurability be proiw in the body of the Commission paper or Section 4.1 of the enclosure.
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. TICKET: N9700552 /
DISTRIBUTION: Centril File LLDP r/f NMSS r/f DWM r/f-t/f PUBLIC 'RJohnson
.ACNW LBell TCJohnson MFederline CJones RMeck -
s .
NMSS D.O.r/f/ CPoland FCardite i
^ iTo receive a copiy of this document in small box on "OFC:" hne enter; "C" = Copy without attachment / enclosure;"E" = Copy'withL ,
attachment / enclosure;"N"= No copy '
- y ' Path'k File Name: S:\DWM\LLDP\AMH1\ RECYCLE.N21
- See previous concurrence OFC' LLDP LLDPM[l/ TEd. LLlP b DWM T NMSS
[ickey NAME ' AHuffert/bg* RNelsh EKraus*
f(<M CPaperiello l DATE - 11/20/97 11/20/97 11/21/97 11/% /97 11/Ji/97 11/ /97 OFFICIAL RECORD COPY ACNW: YES 2L NO _ Category: Proprietary _ or CF Only _
4 IG : YES _ NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
4 j
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.M.Knapp F i
7;- In the Commission Paper, the staff recommends that the Commission provid irection f ; on ce;1ain rulemaking issues if the Commission sects either a major revi n to RG 1.86 that would provide dose-based volume and surface contamin ' n limits i
- 1 (suboption ib) or an independent rulemaking to develop dese-base egulations for i g
' clearance (option 3). One related issue the staff has requested mmission direction -
r , on is the selection of either clearance or restricted release of c taminated mater:als s','4. .
. and _ equipment. Because this is an important decision that uld significantly affect 3 ,f 4,
4 future NRC efforts on recycle / reuse, it is recommended t the advantages and '
X disadvantages of each approach be articulated in the y of the Commission paper, 'ic ,
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' ' ' 8.
~
.g the issue of implementation challenges. such as measurability of low concentrati$ns $
,". ~ of contaminated material against natural backgr nd, is not specifically discussed in the #
,, ! ? Commission papers or enclosure Clearance ' its based on measurability are implied ,
' in Section 4.1 of the enclosure, but not spe ' ically addressed as a potentially significant > .
, y .
implementation issue. As noted in Com nt 1 of this memorandum, measurability .
- playad an influential role in the developr ent of RG 1.86 and continues to be a practical' consideration when determining com ance with RG 1.86 surface contamination limits. ,"
Therefore, it is recommended that t staff's plans to address measurability be provided in.'.he body of the Commission pa r or Section 4.1 of the enclosure.
TlCKET: N970055'2 DISTRIBUTION: Central File LLDP r/f NMSS r/f DWM r/f-t/f PUBLIC - RJohnson ,
ACNW LBell TCJohn n MFederline CJones RMeck NMSS D.O.r/f CPolano FCardi To receive a copy of this document in small box o "OFC;"line enter "C" = Copy withoui attachment / enclosure; *E" = Copy with attachment / enclosure; *N" = No copy Pctb & File Name: S:\DWM\LLDP Hi\ RECYCLE.N21
- See previous concurrence OFC LLDP LLDP)M/h TNn O/ LLDP DWM NMSS _
NAMF AHuffert/bg* RNe$n Obs JHickey CPaperiel!o DATE 11/20/97 11/20/97 11/'M/97 11/ /97 11/ /97 11/ /97 OFFICIAL RECORD COPY ACNW: YES 2L NO _ Category: Proprietary ,_. or CF Only _
IG : YES _ NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
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M. Knapp 6. The issue of implementation d Snges, such as the measurability of low concentrations of contaminated material a ' ,. natural background, is not specifically discussed in the Commission paper or enclo. e. Clearance limits based on measurability is implied in section 4.1 of the enclosure, b ' not specifically addressed as a potentially significant implementation issue. As note. in comment 1 cf this memorandum, measurability played an influential role in the development of RG 1.8C and continues to be a practical consideration when determining compliance with RG 1.86 surface contamination limits.
Therefore, it is recommended that the staff's plans to address measurability be provided in the body of the Commission paper or section 4.1 of the enclosure.
TICKET:
DISTRIBUTION: Central File LLDP r/f NMSS r/t DWM r/f t/f PUBLIC RJohnson ACNW LBell TCJohnson MFederline CJones RMeck NMSS D.O.r/f CPoland FCardile To receive a copy of this document in small box on "OFC:" hne enter: "C" = Copy without attachment / enclosure; *E" = Copy with attachment / enclosure;"N" = No cooy PEth & File Name: S:\DWM\LLDP\AMHi\ RECYCLE.N21
- See previous concurrence OFC LLDP g/J/LLDP/)h/ TEM //jd LLDP DWM NMSS NAME AHuffert/bf RNe[orf Ekraus Y JHickey CPaperiello
'~
DATE 11/20 /97 11120/97 iir) /97 11/ /97 11/ /97 11/ /97 OFFICIAL RECORD COPY ACNW: YES X_ NO _ Category: Proprietary _ or CF Only _
IG : YES _ NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
t M. Knapp 6. The issue of implementation challenges, such as the measurability of w concentrations of contaminated material against natural background, is not specifi lly discussed in the Commission paper or enclosure. Clearance limits based on me urability is implied in section 4.1 of the enclosure, but not specifically addressed as potentially significant implementation issue. As noted in comment 1 of this memo ndum, measurability played an influential role in the development of RG 1.86 a continues to be a practical consideration when determining compliance with RG 1. surface contamination limits.
Therefore, it is recommended that the staff's plans to dress measurability be provided in the body of the Commission paper or section 4.1 the enclosure.
TICKET:
DISTRE EN: Central File- LLDP r/f NMSS r/f DWM r/f-t/f PUBLIC RJohnson ACNW LBell TCJohnson MFederf e NMSS D.O.r/f CPoland To receivs a copy of this document in small box on *0FC:"line enter; "C" Copy without attachment / enclosure; *E" = Copy we attachment / enclosure; "N = No copy Path & File Name: S:\DWM\LLDP\AMHi\ RECYCLE.NJ1 OFC LLDP .v LLDP///h TE LLDP DWM NMSS NAME AHufferth RNefs$n [Kraus ~ JHickey CPaperiello
( DATE' 11/#/97 1146/97 [11/ /97 - 11/ -/97 11/ /97 11/ /97 l OFFICIAL RECORo j COPY ACNW: YES 2L NO _ Category: Pro netary _ or CF Only _
IG : YES _ NO LSS:YES _ NO De;ete file after distribution: Yes _ No _
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TICKET DATE RECEIVED: _11/19/97- _ ORIGINAL DUE DT:- 12/01/97 CONTROL NO: 9700522 DIVISION ,DATE _11/28/97- DOC DT _11/14/97
'FROM: TIME: : COMP DT -/ /
Malcolm R. Knapp
, Acting Dir., RES-
. TO V l Paperiello FOR SIGNATURE OF : ** BLUE ** SECY NO:
ASSIGNED TO:~ CONTACT:
DWM Huffert JDESC:
ROUTING:Wfo(LifntbmMS REGULATORY OPTIONS FOR SETTING STANDARDS ON- , ;Paperiello' CLEARANCE OF-MATERIALS-AND EQUIPMENT'HAVING Kane-RESIDUAL RADIOACTIVITY Linchan-
-Poland SPECIAL-INSTRUCTIONS OR-REMARKS:
DWM - Please prepare a response for Paperiello's
.nignature try21000Ni"T172'8/975 Final response is due
.to-RES by 12/1/97.
, . ADTiONL
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