ML20205R744
| ML20205R744 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1999 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20205R740 | List: |
| References | |
| REF-10CFR9.7 SECY-99-077-C, SECY-99-77-C, NUDOCS 9904230303 | |
| Download: ML20205R744 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
CHAIRMAN JACKSON 1
SUBJECT:
SECY-99-077 - TO REQUEST COMMISSION APPROVAL TO GRANT EXEMPTIONS FROM PORTIONS OF 10 CFR PART 20 Approved XX Disapproved Abstain w/ comments Not Participating
]
COMMENTS:
See attached comments.
k"h' SIGNATURE March 30, 1999 DATE Entered on "AS" Yes x No
- M*2ggag;;ggg21 CORRESPONDENCE PDR
QF. man Jackson's Comments on SECY 99-077 This issue is analogous to the EPA use of out dated methodology to derive its maximum concentration limits, which the Commission has publicly opposed; therefore, I approve the staff proposal to grant the exemption request by OSRAM and on a case by case basis to grant future exemption requests from licensees on this modeling issue. Generically, the staff should consider this issue in the development of future rulemakings related to the adoption of Industry Standards so as not to unnecessarily tie the agency and its licensees to industry methodologies that are static and quickly dated. Methodologies developed to show compliance with industry standards are dynamic in nature and continually evolving; therefore, rather than incorporating methodologies and protocols into the regulations themselves, the staff should instead incorporate the standards through reference in guidance documents which can be updated as needed to reflect the current state of the art. The final measure of the licensee's program should be compliance with the dose limits, not with a set of values that were meant to ease the calculational burden of the licensees.
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