ML20203F268
| ML20203F268 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/1998 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20203F234 | List: |
| References | |
| REF-10CFR9.7 SECY-98-261-C, NUDOCS 9902180112 | |
| Download: ML20203F268 (2) | |
Text
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.t NOTATION VOTE RESPONSE SHEET i
TO: John C. Hoyle, Secretary FROM: COMMISSIONER DICUS '
i
SUBJECT:
SECY-98-261- POLICY CONCERNING BUNDLING OF EXEMPT QUANTITIES Approved x Disapproved Abstain Not Participating - I l COMMENTS: Please see attached comments.
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DATE Entered on "AS" Yes x No
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CORRESPONDENCE PDR
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l-f Comments of Commissioner Dicus' on SECY-98-261 l
I approve staff's proposed generic letter describing a revised NMSS decision regarding the bundling of exempt quantity byproduct material subject to the following changes. I believe that the last paragraph on page 2 should be revised because it focuses solely ,
on radiation safety and does not address protection of property which is a major !
concem of the scrap metal industry. In addition, the joint Agreement State-NRC working group went to great lengths to raise this issue to a level of Commission concem comparable to radiation safety. For these reasons, I suggest rewording the paragraph as follows (changes are in bold}.
l At this time, devices, already in use, having multiple exempt quantities of byproduct material not exceeding 10 in number per device, may continue to be used. NRC does not plan to take any action at this time regarding these devices or users unless a radiological safety hazard is identified. However, since, as explained below, NRC is reviewing this matter, persons possessing such devices should maintain control and accounting of these devices. To this end, it is good practice to clearly label the devices with radioactive materials warning labels bearing the standard radiation warning symbol and standard magenta (or purple) and yellow colors.
Additionally, it is preferable to not dispose of devices containing sources through ordinary commercial waste disposal or metal recycling channels because the presence of radioactive material is of concern to waste disposal facility operators and the metal recycling industry. If devices containing sources are no longer needed, the supplier should be consulted for advice regarding disposition. I NRC plans to further evaluate the risks associated with these devices.
Following this evaluation, NRC will consider appropriate steps, including rulemaking, to clarify the regulatory status of these devices consistent with the protection of the public health and safety and of property. It is anticipated that the evaluation and rulemaking process will take 2 to 3 years. l Staff should request distributors of these devices to provide copies of the generic letter to past and future customers. Copies of the generic letter should be provided to the appropriate scrap metal industry trade organizations.
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