ML20204F983
| ML20204F983 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/1999 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Hirschler B CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS |
| Shared Package | |
| ML20204F997 | List: |
| References | |
| NUDOCS 9903260059 | |
| Download: ML20204F983 (21) | |
Text
f t
Mr. Bruca Hirschl:r Technical Assist nt, SSRCR's MAR ;51999 4 Conference of Radiation Control Program Directors, Inc.
205 Capital Avenue Frankfort, KY 40601
Dear Mr. Hirschler:
-l am responding to your letter of November 13,1998, requesting NRC concurrence in the Suggested State Regulation (SSR), Part N - Regulation and Licensing of Technologically Enhanced Naturally Occurring Materials (TENORM). We believe that Part N represents a significant accomplishment by the CRCPD to establish a model regulation for use by States in '
developing individual State rules for TENORM. Although it is not possible for NRC to provide concurrence, since TENORM is outside of NRC's regulatory jurisdiction, NRC supports the rule methodology, particularly the State's adoption of an all pathway standard and the use of a source specific limit for TENORM set at a fraction of the 100 mrem per year dose limit.
Based on NRC staff revew of Part N, staff has identified a number of specific and general comments (enclosed) in areas such as developing guidance for dose modeling and institutional controls, use of dose modeling to derive release levels, and suggestions for changes to definitions. The review considered 10 CFR requirements applicable to AEA materials (e.g., the recent rulemaking on radiological criteria for license termination) and staff experience in dealing with the types of areas covered by Part N. Please note that our comments are for your use in either considering possible revision to the current text of Part N or for subsequent revisions of Part N.
After you have had the opportunity to review our comments, if you believe it would be helpful, NRC staff is prepared to discuss and review the comments with CRCPD staff.
If you have any questions, or would like to arrange for discussion with NRC staff, please contact me or Cynthia G. Jones, Office of Nuclear Material Safety and Safeguards, at ,
(301) 415 7853, or INTERNET: CGJ@ NRC. GOV. )
l Sincerely, OdginalSigned By:
PAULH.LOHAUS Paul H. Lohaus, Director Office of State Programs
Enclosure:
As stated Distribution: ,
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CRCPD File SSR File pjgg% @ M NY I
- E-Mail Concurrence.
DOCUMENT NAME: G:\TJO\PARTNSGR *SEE PR5VMUS CONCURRENCE. ,
,. Ta receiwo e copr of this document, Indicate ,n tha box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enc /o6llg 1N' = No copy OFFICE OSP g l NMSS l OGC l OSP: #Mf NAME TO'Brien:nbiklI: lib CPaperiello FCameron PLohaus4 I
DATE 01/28/99* 02/22/99* 02/24/99* 02/'0/99*
03/4 /99 03/15/99 ** 0309/99** 03/ , f/99 h
OSP FILE CODE: SP-C-7, SP-S-13 9903260059 990315 ^
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+ y UNITED STATES j j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30e86-4001 g* March 15, 1999 Mr. Bruce Hirschler Technical Assistant, SSRCR's Conference of Radiation Control Program Directors, Inc.
205 Capital Avenue Frar,kfort, KY 40601
Dear Mr. Hirschler:
I am responding to your letter of November 13,1998, requesting NRC concurrence in the Suggested State Regulation (SSR), Part N - Regulation and Licensing of Technologically Enhanced Naturally Occurring Materials (TENORM). We believe that Part N represents a significant accomplishment by the CRCPD to establish a model regulation for use by States in developing individual State rules for TENORM. Although it is not possible for NRC to provide concurrence, since TENORM is outside of NRC's regulatory jurisdiction, NRC supports the rule methodology, particularly the State's adoption of an all pathway standard and the use of a source specific limit for TENORM set at a fraction of the 100 mrem per year dose limit.
Based on NRC staff review of Part N, staff has identified a number of specific and general comments (enclosed) in areas such as developing guidance for dose modeling and institutional controls, use of dose modeling to derive release levels, and suggestions for changes to definitions. The review considered 10 CFR requirements applicable to AEA materials (e.g., the recent rulemaking on radiological criteria for license termination) and staff experience in dealing with the types of areas covered by Part N. Please note that our comments are for your use in either considering possible revision to the current text of Part N or for subsequent revisions of Part N.
After you have had the apportunity to review our comments, if you believe it wouid be helpful, NRC staff is prepare'. .u discuss ar?d review the comments with CRCPD staff.
If you have any que' Jons, or would like to arrange for discussion with NRC staff, please contact me or Cynth a G. Jones, Office of Nuclear Material Safety and Safeguards, at (301) 415-7853, or INTERNET: CGJ @ NRC. GOV.
erely
' C6 1 SV lbaul H. Lohaus, Director Office of State Programs
Enclosure:
As stated
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NRC Comments on the Suggested State Regulation (SSR), Part N - Regulation and Licensing of Technologically Enhanced Naturally Occurring Materials (TENORM)
General Comments
- 1. The Nuclear Regulatory Commission (NRC) agrees with statements in the Rationale that the Conference of Radiation Control Program Directors, Inc., (CRCPD), develop guidance for dose modeling and institutional controls and that this guidance be distributed with the SSR.
- 2. We suggest that a restricted release provision, including a discussion of institutional controls, be included in the SSR. Among the issues the restricted release option will need to consider are the dose limit when institutional controls fail, whether or not to assume the controls fail, and the type of institutional controls that can be used.
- 3. The "1998 Rationale" for Part N discusses institutional controls and restricted land use; however, there is no discussion of the dose consequences from the potential failure of the institutional controls and subsequent unrestricted use of the land. A possible implied assumption that the risk of institutional control failure is essentially zero for all types of controls does not appear to be defensible. For example, the probability of a simple deed restriction failing is much greater than the probability of a control falling if the property is owned by the State or Federal Government. NRC's 10 CFR 20 Subpart E provides separate dose limits that apply under the assumption that the institutional controls fail. The limit depends on the type of controls put in place. We suggest that Part N either: (1) provide separate dose limits assuming that the institutional controls fail and the land is available for unrestricted use; or (2) provide an explicit rationale for assuming that institutional controls will not fail.
- 4. Section N.7a states that facilities and equipment will be released for unrestricted use if levels are below the values listed in Appendix A of Part N. Appendix A contains surface contamination values that are identical to those provided in NRC Regulatory Guide (RG) 1.CS. These values have been commonly used by industry in the past, and we understand that Appendix A was based on RG 1.86. Note that these values were developed prir,1arily through consideration of detection sensitivity. Since the RG 1.86 values are not dose-based, NRC does not use these values for the release of facilities (i.e., buildings) under 10 CFR 20 Subpart E. Dose modeling is used to determine the !
surface contamination levels on building surfaces that correspond to NRC's 0.25 !
millisievert (25 millirem) per year unrestricted use limit. However, note that NRC will ;
continue to use the RG 1.86 values for the release of equipment and materials during operation, to the extent allowed under the specific licenses, until the new " Clearance" Rulemaking is completed. The Clearance Rulemaking will provide release criteria for l equipment and materials that are dose-based (see specific comment #26 below).
NRC maintains that the use of RG 1.86 contamination levels for the unrestricted release of facilities and buildings is inconsistent with a dose-based rule, and that dose modeling should be used to derive the appropriate levels. In addition, CRCPD should consider
.. ~)
j I adding a statement to Part N indicating that the release levels ultimately developed j
through the Clearance Rulemaking should be evaluated for application to the release of I equipment and materials after the final rule is published.
i Enclosures 1 and 2 provide additional information on NRC's regulatory guidance on !
license termination (November 18,1998, Federal Reaister (FR) Notice and Draft I
- Regulatory Guide DG-4006).
- 5. We commend CRCPD for using an all-pathway standard approach in providing
! adequate protection of public health and safety. NRC concluded in its recent.
rulemaking on radiological criteria for license termination that there is no reason, from
, the standpoint of protection of public health and safety, to have a separate, lower dose )
4 criterion for one of the pathways (such as the groundwater pathway), as long as, when i combined, the dose from all pathways is within the total dose standard (see 62 FR 39058, 39074-75,1997). !
4 i 6. Since this regulation addresses only radium, is there a TENORM exemption level for
l Soecific Comments
- 1. Page N1, Section N.3. In the definition of " beneficial attribute," the word "necessary" is ambiguous and should be clarified.
- 2. Page N1, Section N.3. The definition of " institutional controls"is provided in Section N.3, but is not used elsewhere in the standard. As noted in our general comment above, NRC suggests that CRCPD consider the addition of a section to the SSR that allows for restricted release of properties with residual TENORM. Institutional controls are an essential feature of restricted release of property. If this recommendation is adopted and a section added to the SSR, then institutional controls will be addressed in that section. If such a section is not added, the definition can be deleted, because it is not used elsewhere in the SSR.
- 3. In the definition of institutional controls, change "govemment ownership and regulations regarding land or resource use, and" to "govemment ownership or regulations regarding land or resource use, or..."
- 4. The term " disposal system," which is used in the CRCPD definition of institutional controls should be defined.
- 5. The standard's definition of institutional controls allows for only passive institutional controls, and we note that it is identical to the Environmental Protection Agency (EPA) definition of passive institutional controls. There are other definitions of institutional controls that allow for active controls, and, if CRCPD adds a section on restricted release, it may want to consider these broader definitions. These include an EPA 2
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' J definition for active controls that is the companion to that now in the standard for passive controls. NRC has defined institutional controls, in general, as the following:
Institutional controls mean the actions taken by an " institution" for management l and control of a site after closure. It includes activities such as: physical security; surveillance; environmental monitoring; access control; site utilization; maintenance operations; site marking and preservation of records; govemment land ownership; and other activities as determined by the responsible regulatory authority. Certain of these activities are related to protection against human intrusion and habitation of the site, whereas others are directed at maintenance and monitoring to ensure proper control of disposal systems.
- 6. Page N2, Section N.4e. It is unclear from reading this section if transport and storage are exempt or govemed by Parts D and T. We suggest this section be clarified and 3
moved to Section N.2 (Scope). j
- 7. Page N3, Section N.Sc. Change to "... Indoor radon and its short-lived progeny..."
because one would want to consider doses from lead-210.
- 8. Page N3, Section N.5d and page 8, lines 10-13. NRC suggests that t'he definition,
" reasonably maximally exposed individual," be changed to " average member of the critical group." NRC, in its projections of future human activities, as well as many other organizations, uses the " average member of the critical group" approach recommended by ICRP, most recently in ICAP-77, to help ensure reasonableness in decisionmaking.
This critical group approad required in NRC's July 1997 license termination rule.
- 9. Page N3, Section N.7b. Aod the *" footnote for the State screening level, or delete Section b because it is 'ncluded in Section N.7.a.
- 10. Page N4, Section N.10a. Delete " distribute" because it is already covered by the definition of a specific license. Clarify " dispose of TENORM" by changing to " dispose of an entity's own TENORM."
- 11. Page N4, Section N.10b. This section refers to Section N4a, which addresses only radium. NRC suggests that CRCPD consider adding concentration limits for uranium and thorium as well.
- 12. Page N7, Section N.22a.lii. Change " inimical" (hostile) to " detrimental."
- 13. Page N7, Section N.22a.vi(3) and page N8, Section N.22bii(3). Change " waste reduction" to " waste minimization." Be more explicit about quality assurance (QA), and explain " quality assurance of items released for unrestricted use." NRC suggests that the SSR either provide more specific requirements for QA in the regulation or that guidance should be developed for QA.
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- 14. Page N8, Section N.22c.li. Add " routine" before " ingestion" because this concept applies to normal use.
- 15. Page N9, Section N.23a. To the definition section (Section N.3), add the definition of
" exempt item." Add "[Each State will need to determine which TENORM products are j exempt.)."
- 16. Page N11, Section N.26a.lii. After " possession" add "and distribution."
- 17. Rationale, page 1. Define TENORM in the first paragraph. Review the rationale to ensure that the terms TENORM and NORM are used appropriately. For example, on j page 8, line 10, change " NORM" to "TENORM." Also, on page 12, Section N.40,
^
change " NORM" to "TENORM."
- 19. Page 2, line 9. Be more specific about which materials have radium concentrations up j to 100,000 pCi/gm. Change "These materials ..." to "Some of these materials ..." l l
- 20. Page 4, second paragraph. Add the dates of the two stakeholder meetings. I
- 21. Page 6 (Section N.4c). We suggest that the technical explanation for exempting fertilizers be strengthened.
- 22. Page 8, Section N.7b. Consider an analysis of the failure of institutional controls. Also consider whether doses should be calculated with and without institutional controls.
(Reference earlier general comments above.)
- 23. Page 10, second line. Add "or disposal of waste from other persons" to the discussion !
in Section N.20. I
- 24. Page 10, Section N.10a, last sentence. Clarify the phrase "most TENORM materials."
l
- 25. Page 13, item 2. We suggest that CRCPD insert the following statement: l On February 19,1998, NRC staff presented a paper to the Commission (SECY-98-028) proposing a rulemaking activity to set a dose-based standard on the clearance of materials and equipment having residual activity. In a Staff Requirements Memorandum (SRM) dated June 30,1998, the Commission directed the staff to promulgate this dose-based regulation for clearance of materials and equipment having residual activity. The SRM includes direction conceming the conduct of the rulemaking process, and the nature and scope of the standard.
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Copies of SECY-98-028," Regulatory Options for Setting Standards on Clearance of Radioactive Materials and Equipment Having Residual Activity," and the June 30,1998, SRM are provided as Enclosures 3 and 4 to this letter and :T;ay be referenced in the bibliography section.
! 26. In the bibliography, change "Nureg" to "NUREG."
1
Enclosures:
- 1. November 18,1998, Federal Reaister Notice
- 2. Draft Regulatory Guide DG-4006
- 3. SECY-98-028," Regulatory Options for Setting Standards on Clearance of Radioactive Materials and Equipment Having Residual Activity l l 4. June 30,1998, Staff Requirements Memorandum i
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64132 Fedzrzl Register / Vol 63. No. 222/ Wednesday. November 18.1998 / Notices 1
=
W.. -
, requirements with respect to at least one Public comments :equested as to contention will not be permitted to criteria in the LTR do not apply to sites proposed no significant har.ards k- participa)eis a party, consideration: No.
that submit a sufficient
- decommissioning plan (DP) or license Those permitted to intervene become The Commission's related evaluation termination plan (LTP) before August -
parties to the proceeding, subject to any of the amendments, finding of limitations in the order granting leave to emergency circumstances, and final 20.1998, provided the NRC approves the DP or the LTP before August 20, intervene, and have the opportunity to determination of no significant hazards 1999, and the plan is in accordance with participate fully in the conduct of the consideration are contained in a Safety the criteria identified in the Site hearing, including the opportunity to Evaluation dated October 30,1998. Decommissioning Management Plan present evidence and cross-examine Attorneyforlicensee:J E. Silberg, Esquire, Shaw, Pittman, Potts, and (SDMP) Action Plan (57 FR 13389: April witnesses. Since the Commission has 16,1992). The period from the effective made a final determination that the Trowbridge,2300 N Street, NW, date of the LTR, August 20,1997 amendment involves no significant Washington, DC 20037 through August 20,1998,is referred to hazards consideration,if a hearing is local Public Document Room requested,it will not stay the as the "grandfathering period," during location: Minneapolis Public Library, which (fie criteria in the SDMP Action effectiveness of the amendment. Any Technology and Science Department, Plan could continue to be proposed.
hearing b-M would Ske place while the 300 Nicollet Mall, Minneapolis, This notice reminds licensees that the ame .dment is in effect. Minnesota 55401. grandfathering period has ended, and A request for a hearing er a petition NRC Project Director: Cynthia A. that all future requests to terminate a for leave to intervene must be filed with Carpenter.
license must be in accordance with the the Secretary of the Commission, U.S. Dated at Rockville, Maryland. this 10th day Provisions in Part 20, Subpart E. Note Nuclear Regulatory Commission, of November 1998. that the NRC review of the licensee Washington, DC 20555-0001, Attention: ,
For the Nuclear Regulatory Commission. Pl ans submitted in accordance with to '
Rulemakings and Adjudications Staff or william H. Bateman, CFR 20.1401(b)(3), incorporating the may be delivered to the Commission's Acting Director. Division of ficactor Protects--- SDMP Action Plan criteria, will Public Document Room, the Gelman Ill/IV, Office of Nuclear Reactor Regulation. continue through August 20,1999.
Building,2120 L Street, NW., IFR Doc. 98-30691 Filed 11-17-98; 8 45 anil Washington, DC, by the above date. A 2. DraA Regulatory Guide an.uwo coos vs o.eu.
copy of the Ietition should also be sent The NRC has issued Draft Regulatory to the Office of the General Counsel, Guide DG-4006,"Demonstratin8 U.S. Nuclear Regulatory Commission, Cornpliance with the Radiological NUCLEAR REGULATORY Washington, DC 20555-0001, and to the COMMISSION Criteria For License Termination,, for a attorney for the licensee, two-year mtenm use penod (i.e., July 8, Nontimely filings of petitions for Supplementalinformation on the 1998 through July 7,2000). NRC has leave to intervene, amended petitions' implementation of the Final Rule on also issued draft NUREG reports in suPPl ementalPetitions and/or requests Radiological Critoria for License support of DG-4006 (the applicable for a hearing will not be entertained Termination draft NUREG reports are referenced in l absent a determination by the
SUMMARY
- This notice provides DG-4006). A notice of availability of the I Draft Regulatory Guide was published Commission, the presiding officer or thev supplemental information regarding Atomic Safety and Licensing Board that implementation of the Nuclear in the Federal Register en August 4 the petition and/or request should be 1998 (63 FR 41604).
Regulatory Commission's (NRC's) Final granted based upon a balancing of the Rule on Radiological Criteria for License 3. Availability of NRC DandD Screening factors speci6ed in to CFR Termination (License Termination Rule, Code 2.714(a)(1)(i}-(v) and 2.714(d). LTR) which was issued on July 21,1997 On August 20,1998.NRCissued a Northern States Power Company, (62 FR 39058). The information screening computer code DandD, Docket Nos. 50-282 and 50-306, Prairie provided in this notice pertains to: (1) Version 1. The DandD code, when used Island Nuclear Cenerati.sg Plant. Units The end of the "grandfathering period" with default parameters,is an 1 and 2, Goodhue County, Minnesota on August 20,1998;(2) issuance of the acceptable method for licensees to draft regulatory guide on the LTR for calculate screening values to Date of application for amendments:
October 23,1998, as supplemented intenm use;(3) availability of the NRC's demonstrate compliance with the October 26,1998. screening computer code (DandD, unrestricted use dose limit in the LTR.
Version 1) for calculating screening The DandD code can be instelled by Brief description of amendments:The values to demonstrate compliance with downloading the self extracting program amendments clarify the conditions that constitute operable Individual Rod the dose limits in the LTR;(4) screening file, setup.exe, accessed through the values for building surface web site: "http:/techconf.llnl. gov /radcri/
Position Indication (IRPI) system contamination for beta / gamma radiation java.html," clicking on " dose channels, provide for an allowed out of emitters; (5) NRC plans to hold public assessment," and then on service time for inoperable IRPI workshops to discuss issues related to indicator channels, and provide " decontamination and the draft guidance and implementation decommissioning software." The compensatory measures to be taken when any channelis determined to be of the LTR;(6) staff plans to develop a installation lastruction file "readme.txt" standard review plan (SRP) for can also be downloaded, using the inoperable.
Date ofissuance: October 30,1998. decommissioning; and (7) status of NRC above web site, to help users installing Effective date: October 30,1998, decommissioning guidance documents. the code. Important support documents suPPuMpffARY MFORMADON: (e.g., NUREG-1549, " Decision Methods Amendment Nos.:139 and 130. for Dose Asseaament to Comply With Facility Operating License Nos. DPR- 1* End of the Grandfathering Period Radiological Criteria for License 42 and DPR-60. Amendments revised Subpart E to 10 CFR Part 20 contains Termination" and NUREG/CR-5512, the Technical Specifications. a provision,20.1401(b)(3), that the Vol. #3, " Residual Radioactive ENCLOSURE 1
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$ Federal Register /Vol. 63. No. 222/ Wednesday, November 18,1998 / Notices 64133 k
.~ Contamination From Decommissioning, radionuclides contamination that would licensees in a timely, efficient, and be deemed in compliance with the consistent manner, and to determine if (
Parameter Analysis) can also be the dscommissioning will be conducted i accessed through the above web site. As unrestricted use dose limit in 10 CFR 20.1402 (i.e. 0.25 mSv/yr.(25 mrem / such that the public health and safety is discussed in DCM006, use of DandD with the default parameters is intended yr)). The values correspond to screening protected and the facility can be
" derived concentration guidelines" released in accordance with NRC's for screening calculations only,If (DCGL) for each specific radionuclide requirements. The development of the screening results indicate that remediation might be needed, a site- based on the methodology described in SRP will be coordinated with the effort i i
DG-4006. Sites with building surface to revise and finalize DCA006. The web specific dose assessment is i recommended before deciding on contamination levels below those listed site "http://techconf.lini. gov /cgi-bin /
remedial actions. NRC expects pathway in Table I would be deemed acceptable topics" provides updated information for release for unrestricted use in on the status of the guidance and the analysis / dose assessment codes other SRP, and a mechanism for the public to i than DandD to be more appropriate for accordance with the dose criteria in 10 i some conditions. Regulatory Guide DC- CFR 20.1402, provided that residual provide comments on the draft 4006 contains guidance regarding the radioactivity has been reduced to "as guidance.
Information required to support the ese low as reasonably achievable"(ALARA) 7. Status of Decommissioning Guidance of other codes and models. In the levels. The table is intended for use as Documents interim period, NRC will review all dose criteria to facilitate license termination assessment results on a case-by-case for many simple routine Guidance materialin DG-4006 and basis, decommissioning cases without a site- the SRP will incorporate or supersede The DandD code, when used with the specific dose assessment. For facilities most existing NRC decommissioning default parameter set, provides a with contamination levels above those guidance documents. Guidance .
I method for calculating screening in Table 1, additional site-specific dose documents will be revised to be concentrations for radionuclides in soil, assessments may be necessary, and consistent with the LTR, or they will be ,
and screening levels for surface licensees should refer to DG-4006 phased out. Table 2 lists the status of contamination on building surfaces, it regarding acceptable methods for existing NRC guidance documents l conducting the appropriate dose affected by the LTR and associated new l should be noted that the screening '
values, based on DandD, differ from the assessment. guidance.
Table 1 does not include screening Under the SDMP Action Plan criteria.
criteria listed in the SDMP Action Plan.
In most cases, the screening values for values for radionuclides that emit alpha the tables of surface contamination beta / gamma emitters are higher than the particles, or for soil contamination. The values contained in Regulatory Guide SDMP Action Plan criteria, while the NRC staff is assessing current screemng 1.86, " Termination of Operating values for alpha emitters are much approaches for sites with alpha emitters Licenses for Nuclear Reactors," and :
lower. and for soil contamination. For such Policy and Guidance Directive FC 83-During the two year interim use sites, licensees are encouraged to use, in 23," Guidelines for Decontamination of l Penod for the draft guidance (DG4006). the interim period, site-specific dose Facilities and Equipment Prior to NRC plans to continue to refine the assessments based on actual site Release for Unrestricted Use or screening approach and to evaluate the conditions. Termination of Byproduct Source, or 8"
- 5. Future Public Workahops Special Nuclear Material Licenses," {
$ $]t y ore NRC will hold a series of public
- wem used as the decommissioning appropriate to develop a different criteria for building surfaces.The values screening method or approach for alpha workshops over the two year interim in Table 1 are intended to replace the emitters. NRC will assess the results of period to describe the status of the tables in the above two documents for the DandD screening method, ongoing development of both DG-4006 license termination purposes, particularly the low screening values for and the SRP, to provide industry and The surface contamination criteria in alpha emitters, during the workshops to other interested parties an opportunity Regulatory Guide 1.86 have been be held on the LTR guidance to provide comments, and to discuss applied by reactor licensees for license development. Note that DG-4006 clearly users' experiences with implementing termination only. However, for ,
encourages the use of site-specific dose the guidance. The future dates for the materials licenses (under 10 CFR Parts l assessments, whenever needed, and workshops are: December 1-2,1998; 30,40, and 70), the guidelines in Policy '
recognizes that the screening values will January 21-22,1999; March 18-19, and Guidance Directive FC 83-23 have not be appropriate in all cases. 1999; June 16-17,1999: August 18-19, been used by licensees for two 1999; and October 20-21,1999. All
- 4. Screening Values for Building Purposea:(a) As criteria for license workshops willbe conducted in the termination, and (b) as criteria for Surface Contamination Auditorium locate:. at NRC's unrestricted release of equipment and The staff has developed, as a tool to Headquarters (Two White Flint North other materials during operations. On facilitate the efficient implementation of Building,11545 Rockville Pike, June 30,1998, the Commission directed the LTR, a screening table (Table 11 of Rockville, MD 20852-2738). For further the NRC staff to develop a dose-based unrestricted release values for building details on workshops, see the Federaj regulation for clearance of equipment surface contamination of common betal Register notice published on October and materials having residual gamma emitting radionuclides. The 21,1998 (63 FR 56237),
radioactivity.The criteria that screening table was derived using the .
- 6. Standard Review Plan eventually emerge from this rulemaking DandD screening code. Version 1, and effort are intended to replace the surface its default input parameters. Table 1 The NRC staffis developing an SRP provides criteria which permit licensees for the evaluation oflicensee Guidance submittals contamination values in P Directive FC 83-23. Until that to demonstrate compliance with the related to compliance with the unrestricted release dose criterion in the radiological criteria in the LTR. Thecriteria goal time, licensees may continue to u in Policy and Guidance LTR. The values in Table 1 correspond of the SRP is to enable NRC staff to evaluate information submitted by Directive FC 83-23 for unrestricted ,
to surface concentrations of 1
i 1
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- i. 64134 Fed:ral Register /Vol 63, No. 222 / Wednesday. November 18,1998 / Notices k
- i. ' release of equipment and material, to For the Nuclear Regulatory Commission.
TABLE 1-ACCEPTABLE LICENSE TER-the extent authorized by their licenses. John W.N. Hickey, MINATION SCREENING VALUES Or FOR FURTHER INFORMATION CONTACT: Mr. Chief, Iow level waste and ikcomrmssiomng COMMON RADIONUCLIDES FOR David N. Fauver, Low-Lovel Waste and
- 1" 8""'h. Emi n / W S
BUILDING SURFACE Decomrnissioning Projects Branch, at *"8'm'n' O!/k'"I ' ' M8" I CONTAMINATION-Continued 1
(301) 415-6625, or Dr. Rateb (Boby) Abu Efd, Performance Assessment and High- TABLE 1-ACCEPTABLE LICENSE TER-
)
Level Waste Integration Branch, at (301) 8 "* scree ng levels '
MINATION SCREENaNG VALUES OF Radionucide for unrestncted 415-5811, both of the Division of Waste tiol Management, Office of Nuclear Material COMMON RADIONUCUDES FOR cn Safety and Safeguards, U.S. Nuclear BUILDING SURFACE CONTAMINATION Regulatory Commission, Washington, Irdnunw192 . *lt 7.4E@
DC 20555-0001- ' Screening Ms are based on me as-Sym. screemng yeis ,
Deted at Rockville, Maryland, this 12th day Radionucide for unrestncted sumption that the frachon of removable sur.
boi face cor:tarnenaton is equal to 0.1. For cases of November 1998. release p)
W when the fraction of removable contamination is undetermined or higher than 0.1, users may assume, for screeneng purposes, that 100% of Hydrogerw3 (Trit- 3H 1.2E+08 surface contaminanon e, removable, and ium). therefore the screeneng levels should be de-Cart) ore 14 .. ' *C 3.7E+06 creased by a factor of 10. Attemebvely, users Sodium-22 22Na 9.5E +03 serspeedic data on me frachon of re.
Sulfur mov contaminston (e.g., withen the 10% 4 38S 1.3E+07 to 100% ) may emarmaste sde-specdic Chionne-36 . 3*Cl 5.0E+05 acreening usang DandD version 1.
Manganese-54 , 6*Mn 3.2E +04 aUmts are doentegrahone per trunute per IrotwSS : iSFe 4.5E +06 100 square centmeters (dprW100 cm2). I dpm Cobalt-60 *oCo 71 E+03 is equrvaient to 0.0167 becquerei (84). The '
scr ' values represent surface concentra- 1 NeckeL63 83Ni 1.8E +06 none of sndivdual radionuchdes that would be l Stronnum 00 soSr 8.7E+03 deemed in corryshance with the 0.25 mSvtyr Technetum-99 **Tc 1.3E +06 (25 mromtyr) unresencted release dose lirrwt in lodine 129 ' 2*l 3'SE+04 10 CFR 20.1402. For radionuclides in a mix-Cesium 137 . *Cs 2.8E+04 ture, the " sum of fractons" rule apphes; see 10 CFR Part 20, Appends B. Note 4. Refer to NRC Draft Guidance DG-4006 for further in- t formahon on apphcanon of the voiues in this table.
TABLE 2-EXISTING GUIDANCE DOCUMENTS APPLICABLE TO DECOMMISSIONING THAT WILL REQUIRE REVISION OR DISCONTINUATION IN ORDER TO lMPLEMENT THE LICENSE TERMINATION RULE (LTR)
Deconmassorung gudence document Stakas wtth respect to LTR Decommessorung Cntene in Action Plan to Ensure Timely Cleanup of Sagnerseded by LTR and DG-4036 (Note: Sen arparaham to artes Site Decommessoning Management Plan Sees (SDMP Achon Plan) "grandfatherecf* in accordance wth 10 CFR 20.1401(b)).
(57 FR 13380).
Potey and Guidance Dweceve FC 83-23, "Guidehnes for the Decord S44:orseded by DGM006 for Lscense Temunaban (Note: This docu-taminston of Facshtas and Eqtapment Pnor to Release for Unre. mont may contnue to be used as cntaria for unroeMcted release of eMcled Use or Temuneton of Byproduct Source, or Specnol Nuclear equipment and motonal from heensed matonal lectlhos dunng oper.
Motenal Licenses" abonal activstes pnor to bcense temuneton, to the extent authorized by the hconeses).
Drtt Branch Techrscal Possbon on "Screerung Methodology for As- Superseded by LTR and DG-4006.
seesing Pnor Land Bunale of Ramoactrwe Wastes Authonzed Under Former 10 CFR 20.304 and 20.302* (96 FR 28223).
"Preimnary Hazards Analyse for Contamnated Buddings at Formerty S44:erseded by DG-4006 Uoenned Sitas".
NUREG/BR-G41, "NMSS Harw*w=* for Decommissiorung Fuel Cycle References to decommsesoning cnteria are signerseded by the LTR and Matensis Licensees" and DG-4006. The Handscok wlO be apremaart as appropriate to be conssetent wem the LTR and ctarent gisdehnes-Regidatory Guide 1.86. " Termination of Operaeng Lacenses for Womar Supermartart by DG-400F Reacsors".
DreR NUREG/CR-5849, " Manual for Conducang Radiologcal Surveys Superseded by DG-4006 in Support of Ucense Temenskon"
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[FR Doc. 98-30e67 Filed 11-17-98; 8:45 aml RAILROAD RETIREMENT BOARD Rush Street, Chicago, Illir201s 60611, has eiussa coes ress et-e been canceled.
t Sunshine Act Mooting The person to contact for more The meeting of the Railroad information is Beatrice Ezerski, 4
Retirement Board which was to be held Secretary to the Board. Phone No. 312-l on November 18,1998,9:00 a.m., at the 751-4920.
Board's meeting room on the 8th floor ofits headquarters building,844 North i
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U.S. NUCLEAR REGULATORY COMMISSION 8 a August 1998
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f OFFICE OF NUCLEAR REGULATORY RESEARCH Division 4 Draft DG-4006 i
\ e.e.+ / DRAFT REGULATORY GUIDE
Contact:
S. McGuire (301)415-6204 1
l DRAFT REGULATORY G IDE DG-4006
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l DEMONSTRATING OMPLIANCE WITH THE RADIOL GlCAL CRITERIA :
i FOR LICE E TEliMINATION l j ,,
itThee hos notregulatory guide received complete staffisrevie being issued in dr ft form to involve the public in the early steges of the development o and does not represent en officief NRC staff position.
Public value/ commente impact statement. are being solic;ted on the draft gu;de (encludmg any implementation schedste) and its associ and Directives Bronch, Office of Administration, U.S. Nudeer Regulatory Commission, Washin 20555 000). Copies of comments received may be examined at the NRC Public Document Room, 2120 L Street NW., Washington, DC. Comments will by August 31,1999.
Requeste for eingle copies of draft or active regulatory guides (which may be reproduced) or for placement on en auto single copies 20555-0001, of future draft guides in specific divisione should be made in writing to the U.S. Nuclear Attention: Regulatory Reproduction and Dietribution Services Section, or by for to (3011415-2289, or email to GRW1@NRC. GOV.
ENCLOSURE 2
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POLICY ISSUE February 19, 1998 (Notation Vote) SECY-98-028 EQB: The Commissioners FROM L Joseph Callan, Executive Director for Operati s
SUBJECT:
REGULATORY OPTIONS FOR SETTING S ND'ARDS ON CLEARANCE OF MATERIALS AND EQUlPMENT HAVING SIDUAL RADIOACTIVITY ,l PURPOSE:
To request Commission direction on regulatory op ons for setting standards on clearance' of materials and equipment having residual radioac vity.
.;i CATEGORY: !
i This paper covers policy issues requiring Co mission consideration.
BACKGROUND:
In a Staff Requirements Memorandum ted March 10,1994 (COMFR-94-001), the Commission directed the staff to devel p a plan and schedule for a rulemaking that would estab!)sh r:diological criteria for the re ease of slightly contaminated equipment and material from licensed nuclear facilities. In re ly, the staff provided an action plan in SECY-94 221 (August 19,1994). The staff recent updated the Commission on the status of the plan in '
SECY-97-119 (June 5,1997). Tha update noted that the staff's contractor planned to complete its draft analyses of do modeling by August 1997, and that when final, the dose .
modeling report would serve asjt e technical basis for evaluation of regulatory attematives in a Generic Environmentalimpact Statement (GEIS) and a Regulatory Analysis. In addition,
'Cle arance is a term used by th i te n ema'ional community and is defined as the release of radiation sources from all nuclear regulatory control (see IAEA-TECDOC-855, Interim report for comment, pg.1). Note that clearance of materials and equipment may result in their release for reuse or recycling in commerce or disposal.
CONTACT: NOTE TO BE MADE PUBLICLY AVAILABLE Robert A. Meck, DRA/RES WHEN THE FINAL SRM IS MADE AVAILABLE (301) 415-6205 ENCLOSURE 3 I
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NUCLE AR PEGULATORv Z i".' 5 5 : '.
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%, ,o OF8tCE OF THE i SECRETAnv MEMORANDUM TO: L. Joseph Callan ector for Operations l Executivy Clir J.r d L-FROM: John C. Hoy&e, l Secretary
SUBJECT:
S'TAFF REQUIREMENTS - SECY 98-028 - REGULATORY OPTIONS FOR SETTING STANDARDS ON CLEARANCE OF
- MATERIALS AND EQUIPMENT HAVING RESIDUAL RADIOACT VITY l The Commission has approved Option 310 proceed independently to promulgate a dose-based l
regulation for clearance of matenals and a quipment having residual radioactivity. The staff l
should notify EPA of the planned actions il this regard. This effort should begin in FY 1999.
The staff should pursue an enhanced part crpatory rufemaking process similar to the Part 35 revision process, including use of the Interiet home page to solicit commer.ts pnor to start of the formal rulemaking process with particu ar emphasis on enhanced early Agreement State input. The proposed standard for clearance should not be a detectability standard, but should draw from the IAEA's intenm report and the SAIC analysis. It should also draw from ongoing practice with regard to NORM and NARM ( mc! as the encouragement for coal ash to be recycled in buading matenals). The rulemasing should focus on the codified clearance levels above background for unrestncted use that are adequately protective of public health and safety. This level should be based on realit tic scenarios of health effects from low doses that still allows quantities of materials to be rele; sed. The rule should be comprehensive and apply to all metals, equipment, and materials, including soil. If problems that would delay completing the rulemaking anse in certain categones of solid materials, then a decision can be made to narrow the scope of the rule.
SECY NOTE: THIS SRM. SECY-98 028. AND THE COMMISSION VOTING RECO CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS WILL B PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS ENCLOSURE 4
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cc: Chairman Jackson Commissioner Dieus i Commissioner Diaz Commissioner McGaffigan OGC CIO .
CFO OCA OlG Office Directors, Regions. ACRS, ACNW. ASLBP (via E-Mail)
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y aul Lohaus - .J: R 2: REVISED LETTER TO BRUCE HlRSCHLER /_ P ge 1]
.t From: Cyndi Jones To: Paullohaus Date: Mon, Mar 15,1999 8:04 AM
Subject:
Fwd: Re: REVISED LETTER TO BRUCE HI SCHLER You have NMSS concurrence. Both Carl & 1 thought he had concurred.
Cyndi /
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] Pr.ul Lohaus_- Fwd: R:: REVISED LETTER T_O BRUCE HIRSCHLER Pzg3_1l 1l ht-
- 4 From: Carl Paperiello To: CyndiJones, Joyce Collins
. Dete: Fri, Mar 12,1999 5:25 PM
Subject:
Fwd: Re: REVISED LETTER TO BRUCE HIRSCHLER I thought I had already concurred.
>>> Cyndi Jones 03/112:37 PM >>> i Joyce- I Can you ask Carl to take a look at the OSP revisions to the CRCP on TENORM7 They are awaiting his concurrence 1
' I think the revisions are OK, but he needs to acknowledge thi THanks, Cyndi i
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Mr. Bruce Hirschler Technical Assistant, SSRCR's Conf;r nce of Radiation Control
@ Program Directors, Inc.
205 Capital Avenue Frankfort, KY 40601 l
Dear Mr. Hirschier:
I 1
I am responding to your letter of November 13,1998, requesting N concurrence in the 1 Suggested State Regulation (SSR), Part N - Regulation and Lice ing of Technologically Enhanced Naturally Occurring Materials (TENORM). We believ that Part N represents a significant accomplishment by the CRCPD to establish a mod regulation for use by States in developing individual State rules for TENORM. Although T ORM represents materials that are not subject to NRC regulatory jurisdiction under the A mic Energy Act of 1954, as amended, we support and agree with the methodology ed to support these SSRs.
i Based on NRC staff review of Part N, staff has iden ' ied a number of specific and general comments (enclosed) in areas such as developing uidance for dose modeling and institutional controls, use of dose modeling to derive releasopvels, and suggestions for changes to definitions. The review considered 10 CFR re irements applicable to AEA materials (e.g., the recent rulemaking on radiological criteria for ense termination) and staff experience in dealing l with the types of areas covered by Part N. lease nota that our comments are for your use in either considering possible revision to th current text of Part N or for subsequent revisions of Part N.
After you have had the opportunity review our comments, if you believe it would be helpful, NRC staff is prepared to discuss d review the comments with CRCPD staff.
If you have any questions, or ould like to arrange for discussion w:th NRC staff, please contact myself, or Cynthia G. Jones ffice of Nuclear Material Safety and Safeguards, at 301-415-7853, or via inter t: cgj@nrc. gov.
Sincerely, I Paul H. Lohaus, Director Office of State Programs
Enclosure:
As stated /
Distribution:
DIR RF DCD (SP02)
SDroggitis PDR (YES_f_ NO )
CRCPD File CJones, NMSS SSR File L DOCUMENT NAME: G:\TJO\PARTNSSR *SEE PREVIOUS CONCURRENCE.
i Ta receive a copy of this document, Indicate in the box: "C" = Copy Mthout attachment / enclosure "E" = Copy we attachment /enclost re "N" = No copy OFFICE OSP* l - OSP:D* NMSfp g/ l OGC l l l NAME TO'Brien:nb:kk:nb PHLohaus CPaperiM6 4 FCameron DATE 01/28/99* 02/10/99 02fph9 02/ /99 ,
OSP FILE CODE: SP-C-7, SP-S-13
' [Kathaleen Kerr- RM REVISED LETTER TO BRUCE HIRSCHLER I P:.ge 11 ;
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From: Francis Cameron j To: Carl Paperiello,: Cyndi Jones, Kathaleen Kerr, ..
Date: Tue, Mar 9,1999 2:42 PM
Subject:
Re: REVISED LETTER TO BRUCE HIRSCHLEP'
- it's fine with OGC _ )
CC: Joyce Collins, Paul Lohaus, Thomas O'Brien 1
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Mr. Bruca Hirschi:r ,
- Y ' Technical Assistant, SSRCR's Conference of Radiation Control f ,
Program Directors, Inc. -
205 Capital Avenue i Frankfort, KY 40601
Dear Mr. Hirschler:
I am responding to your letter of November 13,1998, requesting NRC concurrence in the j Suggested State Regulation (SSR), Part N - Regulation and Licensing of Je'chnologically
- i. Enhanced Naturally Occurring Materials (TENORM). We believe that Part N represents a
' l' significant accomplishment by the CRCPD to establish a model regulation for use by States in developing individual State rules for TENORM. However, given thatKNORM represents ,
materials that are not subject to NRC regulatory jurisdiction under pt e Atomic Energy Act of I 1954, as amended, (AEA), it is not appropriate for NRC to provide concurrence in Part N.
Based on NRC staff review of Part N, staff has identified a nu er of specific and general
! comments (enclosed) in areas such as develcping guidance or dose modeling and institutional controls, use of dose modeling to derive release levels, an suggestions for changes to l definitions. The review considered 10 CFR requirement applicable to AEA materials (e.g., the l recent rulemaking on radiological criteria for license te ination) and staff experience in dealing l with the types of areas covered by Part N. Please n , that our comments are for your use in l either considering possible revision to the current text of Part N or for subsequent revisions of
! Part N.
After you have had the opportunity to review o comments, if you believe it would be helpful, 1 NRC staff is prepared to discuss and review e comments with CRCPD staff. '
If you have any questions, or would like to errange for discussion wD NRC staff, please contact me or Phyllis Sobel, Office of NucIsar Material Safety and Safeguards, at
- 301-415-6714, or INTERNET
- PASONAC. GOV.
Sincerely, Paul H. Lohaus, Director
[ Office of State Programs 1
Enclosure:
l As stated 4
. Distribution:
DIR RF DCD (SP02)
SDroggitis PDR (YES_f_ NO )
CRCPD File /
SSR File
, DOCUMENT NAME: :\TJO\PARTNSSR *SEE PREVIOUS CONCURRENCE.
n, .m. w - e .c v .c m . v.m.m nd T - o,. n T.n
[ OFFICE OSP l Q 3PM l NMSS l 1 0G'C 5 l l 7
NAME TO'Brien:nb:kk:nb PHLohaq#) CPaperiello FCameron L DATE 01/28/99* 02/@/99 02/ /99 02/7/99 OSP FILE CODE: SP-C-7, SP-S-13 i
.. ' faca L n a y Mr. Bruca Hirschl:r 1 Technic:l Assist:nt, SSRCR's h /V/M5 lY l -
Conference of Radiation Control Program Directors, Inc.
205 Capital Avenue Frankfort, KY 40601
Dear Mr. Hirschier:
I am responding to your letter of November 13,1998, requesting RC concurrence in the Suggested State Regulation (SSR), Part N - Regulation and Lic sing of Technologically Enhanced Naturally Occurring Materials (TENORM). We belie that Part N represents a significant accomplishment by the CRCPD to establish a mod regulation for use by States in developing individual State rules for TENORM. However, giv n that TENORM represents materials that are not subject to NRC regulatory jurisdiction nder the Atomic Energy Act of 1954, as amended, (AEA), it is not appropriate for NRC to ovide concurrence in Part N.
Based on NRC staff review of Part N, staff has identified number of specific and general comments (enclosed) in areas such as developing guida ce for dose modeling and institutional controls, use of dose modeling to derive release levels, nd suggestions for changes to definitions. The review cons,idered 10 CFR requiremen o applicable to AEA materials (e.g.. the recent rulemaking on radiological criteria for license ter ination) and staff experience in dealing with the types of areas covered by Part N. Please not that our comments are for your use in either considering possible revision to the current tex of Part N or for subsequent revisions of Part N.
Af ter you have had the opportunity to review our c ments, if you believe it would be helpful, NRC staff is prepared to discuss and review the c mments with CRCPD staff, if you have any questions, or would like to arra e for discussion with NRC staff, please contact me or Phyllis Sobel, Office of Nuclear aterial Safety and Safeguards, at 301-415-6714, or INTERNET: PAS @NRC.G V.
Sincerely, Paul H. Lohaus, Director Office of State Programs
Enclosure:
As stated DistribJ,on: '
DIR RF DCD (SP02)
SDroggitis PDR (YES_f_ NO )
CRCPD File SSR File DOCUMENT NAME: G:\TJO\PARTN R *SEE PREVIOUS CONCURRENCE.
T4 receive a copy of this document, indicate in the box: "C" = Copy wip attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OM/
OFFICE OSP l / @)Qd l / NMSS l l OGC l NAME TO'Brien:nb:kk:nb pHLohads* I CPaperiello FCameron i DATE 01/28/99* / 02//0/99 02/22/99* 02/24/99*
OSP FILE CODE: SP-C-7, SP-S-13
'r
'Y
.- Mr. Bruce Hirschler Technical Assistant, SSRCR's Conference of Radiation Control
- Program Directors, Inc.
205 Capital Avenue l
Frankfort, KY 40601
Dear Mr. Hirschler:
I l am responding to your letter of November 10,1998, re uesting NRC concurrence in the .
Suggested State Regulation (SSR), Part N - Regulatiokand Licensing of Technologically I Enhanced Naturally Occurring Materials (TENORM). We believe that Part N represents a '
significant accomplishment by the CRCPD to establis a model regulation for use by States in developing individual State rules for TENORM. Howe er, given that TENORM is not subject to NRC regulatory jurisdiction under the Atomic Energy ct of 1954 (AEA), we do not plan to provide agency concurrence in Part N.
NRC staff has conducted a review of Part N based n 10 CFR requirements applicable to AEA materials (e.g., the recent ruiemaking on radiologic I criteria for license termination) and staff ,
experience in dealing with the areas covered by P N. Based on the review, staff has identified I a number of specific and general comments (enci sed) in areas such as developing guidance for dose modeling and institutional controls, use dose modeling to derive release levels, and suggestions for changes to definitions. Please ndte that our comments are for your j consideration and use in either the current or su sequent revisions of Part N. I After you have had the opportunity to review ou comments, if you believe it would be helpful, NRC staff is prepared to discuss and review th comments with CRCPD staff. Such discussion could help clarify and provide the basis for our omments and help NRC staff better understand the CRCPD's intent and purpose for certain a pects of the rule.
If you have any questions or would like to arr nge for an open discussion with NRC staff, please contact me or Phyllis Sobel, Office of Nucle Materials Safety and Safeguards, at 301-415-6714, or INTERNET: PAS @NRC. GOV.
Sincerely, Paul H. Lohaus, Acting Director Office of State Programs
Enclosure:
As stated Distribution:
DlR RF DCD (SP02) ,
SDroggitis PDR (YES__( NO ) l CRCPD File 1
DOCUMENT NAME: G:\TJO\PARTNSSR n r.c.sv. a copy or ini. oocum.nt, inow.i. in in. box: c copy w attacnmenuwnciou. e = copy witn attachment /enciosure N No copy OFFICE OSP OSP:AQ NAME TO'Brien:nb PHLohaus/
DATE 01/2%/99 01/ //99 l
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