ML20210B572

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Comments Supporting Proposed Rule 10CFR2 Re Designating Radwastes as Below Regulatory Concern.Dose Equivalent Limit to Individual Members of Public So Low That Successful Application of Criteria May Prove Rare
ML20210B572
Person / Time
Issue date: 08/08/1986
From:
Advisory Committee on Reactor Safeguards
To:
NRC
References
FRN-51FR30839, RULE-PR-2 NUDOCS 8609180115
Download: ML20210B572 (2)


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C0ldEIEP AugustY1986 Report No. 6 ACRS Waste Management Subconaittee Coments On NRCof NRCStaff Policy Policy Statement on Radioacti'e WastesAnd Implementa ggly g p ;p; a.g j Below Regulatory Concern July 21-23, 1986

1. In general, we believe the decision criteria being developed by the NRC Staff for judging whether to gran,t a petition for designating radioac-tive wastes as "below regulatory concern" (BRC), thus permitting them to be disposed of by conventional means, are good. However, we have the following suggestions and coments:
a. Before the criteria are confirmed, it would be useful to use them to evaluate a range of potential waste candidates to determine if any would be found to be "below regulatory concern." We are '

concerned that the dose equivalent limit to an individual member of the public is so low that successful application of the criteria may prove to be rare.

b. We believe that the models to be used for calculating doses to individual members of the public resulting from the disposal of-radioactive wastes should be specified. Included should be a statement relative to the uncertainties acceptable in such models.
c. The computer code proposed for use in judging the impact of handling wastes containing radioactive materials in quantities or concentrations *below regulatory concern" is said to be conserva-tive. The amount of conservatism, however, is unknown. Because of -

the small dose equivalent that will be acceptable, and because the inclusion of conservatism in modeling will produce unidentifiable distortions of the calculated results, we recomend that the calculational methods be designed.to give best estimate results insofar as is feasible,

d. Although we endorse the efforts of the NRC Staff to develop suit-able dose estimation models for evaluation of proposals submitted by petitioners, we believe that greater use might have been made of the methodology described in earlier ret orts on this general subject prepared by Ford, Bacon, Davis, tJtah, Inc.
2. The Policy Statement (Reference 1) recomends that evaluations be based on effective dose equivalents. We suggest that this same system be used in comparing doses from various radiation sources. For example, the effective dose equivalent from the natural radiation background should include the lung dose contribution from radon.

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3. One of the examples cited as providing perspective is the EPA limit for radionuclides in drinking water, which permits members of the public to receive a maximum dose of 4 mrem per year to an individual organ. This is a dose limit and we believe it is incorrect to cite it as representa- ,

tive of a dose considered to be "below regulatory concern."

4. We are encouraged to note the use by the NRC Staff, in the development of this Policy Statement, of several publications of the International Commission on Radiological Protection.

References:

1. SECY-86-204, Policy Issue (Affirmation), Policy Statement on Radioactive Waste Below Regulatory Concern, V. Stello, E00, to the Commissioners, dated July 11, 1986 e

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