ML20210U335
| ML20210U335 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1999 |
| From: | Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | J. J. Barton, Inhofe J HOUSE OF REP., ENERGY & COMMERCE, SENATE, ENVIRONMENT & PUBLIC WORKS |
| References | |
| RULE-PRM-40-27 CCS, NUDOCS 9908200061 | |
| Download: ML20210U335 (2) | |
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- UNITED STATES y
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30ealHm01
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The Honorable James M. Inhofe, Chairman Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety Committee on Environment and Public Works United States Senate Washington, DC 20510
Dear Mr. Chairman:
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Enclosed for your information is a copy of a petition for rulemaking (PRM-40-27) requesting that the Nuclear Regulatory Commission (NRC) amend 10 CFR Part 40. The petition was filed with the NRC by Officers of the Organization of Agreement States and the State of Colorado.
l The petition requests that the NRC amend its regulations governing small quantities of source l material to eliminate the exemption for source material general licensees from the requirements that specify standards of protection against radiation and notification and j instruction of individuals who participate in licensed activities.
Also enclosed is a copy of the Federal Register notice that contains additionalinformation concerning the petition. The notice will be published requesting public comment for a 75-day' j period. 4 Sincerely, y I Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosures:
l 1.' PRM-40-27 j
h y t UNITED STATES f
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2 NUCLEAR REGULATORY COMMISSION WABMINGToN, D.C. 30886 0001 R .. ,,*/ July 14, 1999 i
The Honorable Joe Barton, Chairman i l Subcommittee on Energy and Power
- Committee on Commerce Unlied States House of Representatives l Washington, DC 20515
Dear Mr. Chairman:
Enclosed for your information is a copy of a petition for rulemaking (PRM-40-27) requesting that the Nuclear Regulatory Commission (NRC) amend 10 CFR Part 40. The petition was filed with the NRC by Officers of the Organization of Agreement States and the State of Colorado.
l The petition requests that the NRC amend its regulations goveming small quantities of source ;
material to eliminate the exemption for source material general licensees from the requirements that specify standards of protection against radiation and notification and l instruction of individuals who participate in licensed activities.
Also enclosed is a copy of the Federal Register notice that contains additional information conceming the petition. The notice will be published requesting public comment for a 75-day ,
period. ]
l Sincerely, Dennis K. Rathbun, Director l Office of Congressional Affairs
Enclosures:
- 1. PRM-40-27
- 2. Federal Register notice cc: Representative Ralph Hall i
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000 Cher Creek Dr. S. Laboratory and Radiation Services Drvision . .
Denver, CoIorado eo246-1530 8100 Lowry Bkd. RULES & D.H. e.m.cs . , , .
Phone 003) 692 2000 Denver CO 8022o.6928 US NRC Located in Glendale, Colorado 0 03)692 309o Gorado ent http://www.cdphe. state.co.us den nme t May 10, 1999 The Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 0001 Attention: Rulemakings and Adjudications Staff RE: Petition for Rulemaking The Officers of the Organization of Agreement States and the State of Colorado petition the U.S. Nuclear Regulatory Commission to climinate the blanket exemption for source material general licensees from the requirements of 10 CFR Parts 19 snd 20. This petition requests that the exemption in 10 CFR 40.22(b) be revoked for any source material general licensee that: 1) could exceed public dose limits; 2) could exceed the dose equivalent limits for an embryo / fetus; 3) would require personnel monitoring; or 4) would require posting of a radiation area.
This petition addresses significant safety issues that impact protection of public health and safety, and the environment.
Enclosed is the petition that sets forth the proposed regulation that is to be modified; the petitioner's grounds for and interest in the action requested; and the specific issues and facts that support the petition.
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SAEley R. Marshall, Chairman Robert Qudfin, Dircctor Organization of Agreement States Laboratory and Radiation Senices Disision, Colorado Department of Public Health And Emironment
Enclosure:
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i PETITION FOR RULE MAKING 4 Modification of Exemptions to Parts 19 and 20 in 10 CFR 40.22(b) by the j Officers of the Organization of Agreement States and {'
the State of Colorado l
Proposed Regulatory Text NRC should restrict the exemption from 10 CFR 19 and 20 for general licensees, Any licensee that los the potential to exceed any dose limits c ? release limits. or w hich generates a radiation area as defined in Part 20 should be required to meet requits ments in both Pans 19 and 20.
10 CFR 40.22 states:
(b) Persons who receive. possess. use, or transfer source material pursuant to the general license issued in paragraph (a) of tius section are exempt from the provisions of parts 19,20. and 21. of this chapter to the extent that such receipt.
possession, use or transfer are within the terms of such general license: Provided.
however, that this exemption shall not be deemed to apply to any such person u ho is also in possession of source material under a specific license issued pursuant to this pan.
As proposed. this section would read:
(b) Persons who receive. possess. use. or transfer source matenal pursuant to the general license issaed in paragraph (a) of this section are exempt from the provisions of part 19,20. and 21. of this chapter to the extent that such receipt, possession, use or transfer are within 6e terms of such general heense: Provided.
however, that this exemption shall not be deemed to apply to any such person:
(1) who is also in possession of source material under a specific license issued pursuant to this pan; (2) whose use of source matenal could esceed the occupational dose imuts in
{20.1201 through J20.1208.
(3) whose use of source matenal would require the use of personnel monitoring under l211502(a),(b) or (c); or (4) whose operation requires posting under f 20.1902 I
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Statement of Considerations Background l In 10 CFR Pan 20. the NRC established basic radiation standards that apply to specific and most general
! licensees. These standards are consistent with national and international guidance. They are necessary to i provide a fiame work in wluch a hcensee can conduct safe operations, prevent radiation workers and the ;
public from exceeding dose limits. and to maintain all radiation esposures As Low As Reasonably j Achievable (ALARA).
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., The NRC has also promulgated provisions in 10 CFR 19 to protect and inform indisiduals participating in licensed activities. The requirements in Part 19 are not restricted to certain licensees. g19.2 states:
"The regulations in this pan apply to all persons who receive, possess, use, or transfer material licensed by the Nuclear Regulatory Commission pursuant to the regulations in parts 30 through 36,39,40,60,61,70, or part 72 of this chaper..."
[ emphasis added}
While the NRC has established these basic standards and protections, it has exemped one class oflicensee from meeting the requirements of both Parts 19' and 20.
Perhaps when this exemption was granted, generally licensed quantities of source material were not thought to be a health and safety hazard. Since this exemption was promulgated, that idea has been shown to be false, and the basic radiation standards have changed. These licensees can :
e expose workers to levels of radiation that require monitoring, e dispose of radioactive materials in a manner that would not be acceptable for other licensees, e produce contammation that exceeds release limits, and e potentially exceed public dose limits to individuals other than those working at their facilities 2, it is the petitioners' contention that there is no basis for exempting licensees from complying with basic health and safety standards if the licensee can exceed any of Pan 20 dose limits, or can produce " radiation areas"' as defined in Part 20.
If a radiation hazard exists that would require most licensees to implement corrective procedures, all licensees who create similar hazards should be required to eliminate the hazard. All individuals using radioactive matenals, as well as the general public, should be protected from unsafe and unnecessary exposures to radiation resulting from a licensed operation. The petitioners funher contend that individuals panicipating in licensed activities, and w ho may receive exposures in excess of the public dose limits in Pan 20, should be insuucted in both their rights as radiation workers and the procedures necessary to use radioactive materials safely.
The Officers of the Organization of Agreement States and the State of Colorado are impacted by the NRC exemption in two ways. First, because of the exemption, radioactive materials that are potentially hazardous can be transponed into our states without the knowledge or control of the Radiation Control Programs. Secondly, experience has already shown that in at least two cases, state and/or local health departments have had to become involved in remediation effons.
Discussion of problem I
On January 28,1999, Colorado Radiation Control Program received notice that a roll off Dumpster had set off a radiation alarm at a landfill. The Dumpster had been used for construction debris resulting from a remodeling project after a source material general licensee vacated the structure. Exposure levels exterior to the Dumpster were 4.9 mR/hr. An investigation determined that the generator of the radioactive material was indeed a source material general licensee, who ensured his procurement did not exceed the 150 pounds per year limit in f40.22(a). Funher investigation reveled that this licensee vacated the building with levels of contamination that exceeded limits for release for uncontrolled use, and that the licensee had ,
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' It is noted that the exempion in 540.22(b) is inconsistent with S 19.2 2
Because Part 20 defines " Radiation Worker", and source material general licensees are exempt from pan 20, these licensees technically do not have ." Radiation Workers"
' Because " Radiation arca" is defined in Pan 20, and these licensees are exempt from Pan 20, a source material general licensee could technically have a " radiation area" regardless of the exposure rate.
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a L significant levels of exposure at its new facility. Under the exemption in s40 22(b) (and equivalent requirements in Colorado's Regulations). this licensee, and others u ho use similar quantities of source j material, is exempt from the basic health and safety critena of Part 20. l To demonstrate the significance of this problem. the following is a smnmary of the measurements, analyses. and calculations of exposure that are associated with the Colorado incident. All exposures resulted from Thorium and its daughters.
- Effective dose equivalent to workers estimated to be up to I rem per ycar based on measurements made at the cunent facility's u orkstations.
i e Residual contamination at the vacated facility in excess of current standards. Using NRC's computer code DandD version 1. the Maximum Annual Total Effective Dose Equivalent was calculated at 734 mrem, and compared to NRC's standard for unrestricted release - 25 mrem.
The Colorado incident is not the first one involving a source material general licensee. An Intemet search identified a 1994 EPA crforcement against Broomer Research. Inc. of Islip. Long Island. New York. The plant manufactured optical lenses and used Thorium Fluoride. EPA identified " appreciable levels of radionuclides, assumed to be thorium, in the sludge discharged"' It is unlikely that these facihties are unique. A brief search on the Internet identified muldple suppliers of Thorium Fluoride, and at least one other optical coating company in California. Colorado has contacted manufacturers of Dorium Fluoride and attempted to obtain a list of their Colorado customers How ever, to date. only one has supplied the requested information.
The exemption in s40 22(b) pennits licensecs to esceed the dose hmits and ignore the safety issues in Part
- 20. It has been demonstrated that source material pencral licensees use materials in quantities tlut cause i hazards and uould regmre a specific licensee to adhere to the following requirements:
i e Develop radiation and ALARA programs e Limit occupational esposures - adults, embry offelus and mmors
. Limit public dose j e Release limits e Survey and monitoring requirements j e Storage and control of radioactive materials e Posting storage areas. contamers and radiation areas e Procedures for receiving and opening packages ,
- Waste disposal requirements - this may also impact uaste brokers and pennitted sanitary landfills (see issues below) e Waste manifests
.- Worker training e Posting of the " Notice to Workers" There is no logical basis for exempting these licensees from general safety provisions, and allowing them to expose radiation workers and the public at levels greater than is allowed for specific licensees. The exemption should be modified so that it applies to any licensee that might exceed dose limits. release limits or whose operations involve working in a radiation area as defined in 10 CFR Pan 20.
In addition to the exposure problems identified above. the " radiation uorkers" training protections and nghts that apply to all other licensees are esempted by (40 22(b)- es en though they work in "a radiauon area
- EPA FY 1994 Enforcement and Compliance Assurance Accomphshments Repon - Section 3: Regional and State Enforcement and Compliance Assurance Acuutics. http //es epa gos/ comply /occa/section3 html Page 3
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, Waste disposal is another item that slips through the cracks because of the exemption. The requirements for the disposal of radioactive waste are also included in 10 CFR Part 20. Disposal is controlled for ,
specific licensees. Unless specifically authorized by regulation or license condition, they must properly _
dispose of radioactive waste. They are not allowed to dispose ofit as common trash. They are not allowed to dilute the waste so it can pass through gate monitors at landfills, if the radioactive waste from source material smeral licensees is transferred to a broker, that broker may be unaware of the hazard and '
potentially exposed, and may transfer the hazard to another waste handler for processing, who is likewise unaware of the problem. General licensees w ho posses source material believe that waste disposal is not an issue because it is only " Generally Licensed"5 How the regulatory revisions will solve the problem.
Restricting the exemption in 140.22(b) will ensure that there is a uniform standard of radiation safety for all that nood it. All radiation workers will be protected. All licensees will limit public exposures to safe levels. All radioactive waste will be disposed ofin accordance with Part 20 requirements.
Proposed Regulatory Action & Alternative Approaches
. In addition to modifying the exemptions in g40.22(b) as requested. three other regulatory approaches wcre considered - no action, issuing a license to each general licensee w ho uses source material and could q exceed any of the limits in Part 20, and removing the exemption for ah source material general licensees.
The no action altemative is not acceptabic because it permits licensees to exceed basic radiation standards and does not provide rights and protections to radiation workers.
Issuing a licensing document to each source matenal general licensees would be more expensive than changing the regulations inappropriate, and unuorkable. It is less expensive to modify the regulations once, than to issue licensing documents to each source material licensee; especially when companies come into and go out of business. Secondly, it is inappropriate to apply conditions to every such licensee rather than to go through a rule making process. Further, the NRC would not be able to easily determine the scope activity for each source material general licensee.
The third attemative, removing the exemption for all source material general licenses, is not appropriate in relation to the potential risks. There are many licensees that use only small amounts of source material and pose only minimal risks to workers and the public. For example, a laboratory that uses only gram amounts of urany! nitrates poses little risk, and trace amounts are pernutted to be disposed as c'her than radioactive waste.
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' The disposal of Low Level Radioactive Waste tLLRW) is also an issue for LLRW compacts, but this issue is not part of the petition.
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NUCLEAR REGULATORY COMMISSION -
[ Docket No. PRM-40-27]
State of Colorado and Organization of Agreement States; Receipt of Petition for Rulemaking AGENCY: Nuclear Regulatory Commission.
ACTION: Petition for rulemaking; Notice of receipt.
SUMMARY
- The Nuclear Regulatory Commission (NRC) has received and requests public comment on a petition for rulemaking dated May 10,1999, filed by the Officers of the Organization of Agreement States and the State of Colorado (petitioners). The petition has been docketed by the Commission and has been assigned Docket No.
PRM-40-27. The petitioners are requesting that the NRC regulations governing small quantities of source material be amended to eliminate the exemption for source material general licensees from the requirements that specify standards of protection against radiation and notification and instruction of individuals who participate in licensed activities. Current NRC regulations exempt source material general licensees from these requirements. The petitioners believe that no basis exists for exempting
- these licensees from compliance with radiation safety standards if a licensee can exceed currently specified dose limits or create areas where individuals may be exposed to significant levels of radiation.
DATE: Submit comments by (75 days following publication in the Federal Reoister).
L Coniments received after this date will be considered if it is practical to do so, but i
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2 assurance of consideration cannot be given except as to comments received on or before this date.
ADDRESSES: Submit comments to: Secretary, U.S. Nuclear Regulatory Commission, 1 l
Washington, DC 20555. Attention: Rulemakings and Adjudications Staff. i Deliver comments to 11555 Rockville Pike, Rockville, Maryland, between 7:30 am and 4:15 pm on Federal workdays. f For a copy of the petition, write: David L. Meyer, Chief, Rules and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear i Regulatory Commission, Washington, DC 20555-0001.
You may also provide comments via the NRC's interactive rulemaking website through the NRC home page (http //www.nrc. gov). This site provides the availability to upload comments as files (any format), if your web browser supports that function. For information about the interactive rulemaking website, contact Ms. Carol Gallagher, (301) 415-5905 (e-mail: CAG @nrc. gov).
FOR FURTHER INFORMATION CONTACT: David L. Meyer, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555. Telephone: 301-415-7162 or Toll Free: 1-800-368-5642 or E-mail: DLM1 @ NRC. GOV.
SUPPLEMENTAFiY INFORMATION:
Background
On May 13,1999, the Nuclear Regulatory Commission received a petition for
- rulemaking submitted by the Officers of the Organization of Agreement States and the State of Colorado (petitioners). The petitioners believe that the NRC should restrict the
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j exemption from 10 CFR Parts 19 and 20 for general licensees that appears at 10 CFR l 40.22(b). ;
l The petitioners contend that any licensee who has the potential to exceed any dose limits or who generates a radiation area as defined in 10 CFR Par + 20 should be required to meet the radiation protection and worker notification requirements in both Parts 19 and 20. To do this, NRC would have to amend its regulations pertaining to source material general licensees in 10 CFR Part 40. Specifically,10 CFR 40.22(b) I would have to be amended tu r evoke the exemption from 10 CFR Parts 19 and 20 for i
source material general licensees who could exceed public dose limits or dose !
equivalent limits for an embryo / fetus, would require personnel monitoring, or would require posting of a radiation area. The NRC has determined that the petition meets j the threshold sufficiency requirements for a petition for rulemaking under 10 CFR 2.802. The petition has been docketed as PRM-40-27. The NRC is soliciting public comment on the petition for rulemaking.
Discussion of the Petition I
The petitioners believe that the NRC regulations codified at 10 CFR 40.22(b) provide a blanket exemption for source material general licensees from the radiation protection and associated worker protection requirements codified at 10 CFR Parts 19 and 20. Currently,10 CFR 40.22(b) reads as follows:
. (b) Persons who receive, possess, use, or transfer source material pursuant to the general license issued in paragraph (a) of this section are exempt from the provisions of parts 19,20, and 21, of this chapter to the l
l l
4 extent that such receipt, possession, use or transfer are within the terms of such general license: Provided, however, That this exemption shall not be deemed to apply to any such person who is also in pos, session of source material under a specific license issued pursuant to this part.
As proposed by the petitioners,10 CFR 40.22(b) would read:
(b) Persons who receive, possess, use, or transfer source material pursuant to the general license issued in paragraph (a) of this section are exempt from the provisions of parts 19,20, and 21, of this chapter to the extent that such receipt, possession, use or transfer are within the terms of such general license: Provided, however, that this exemption shall not be deemed to apply to any such person:
(1) Who is also in possession of source material under a specific license issued pursuant to this part; (2) Whose use of source material could exceed the occupational dose limits in @20.1201 through @20.1208; (3) Whose use of source material would require the use of personnel monitoring under @20.1502(a), (b), or (c); or (4) Whose operation requires posting under @20.1902.
The petitioners note that 10 CFR Part 20 specifies basic radiation standards, consistent with national and international guidance, that apply to specific and most general licensees to provide the framework in which a licensee can perform safe operations, prevent employees and the public from exceeding dose limits, and maintain
5 al! radiation exposures As Low As Reasonably Achievable (ALARA). The petitioners also note that 10 CFR Part 19 contains provisions to protect and inform individuals who participate in licensed activities that " apply to allpersons who receive, possess, use, or transfer material licensed by the Nuclear Regulatory Commission pursuant to the regulations in parts 30 through 36,39,40,60,61,70, or part 72 of this chapter * * * "
(Emphasis added.)
The petitioners believe that generally licensed quantities of source material may not have been regarded as a health and safety hazard when the exemption for source material licensees was enacted. However, the petitioners contend that after the exemption became effective, industry experience has revealed that source material general licensees can expose workers to levels of radiation that require monitoring, dispose of radioactive materials in a manner that would not be acceptable for other licensees, produce contamination that exceeds release limits, and potentially exceed public dose limits to individuals other than those working at their facilities.
The petitioners further contend that no basis exists for exempting source material general licensees from compliance with Part 20 requirements pertaining to dose limits or posting of radiation areas. The petitioners believe that if a radiation hazard exists that would require most licensees to implement corrective measures, all licensees who create similar hazards should be required to eliminate the hazard. The petitioners also state that any individual who uses radioactive materials and the general public should be protected from unsafe and unnecessary exposure to radiation resulting from licensed activities. The petitioners believe that individuals who l..... . . , . . .. .
e 6
participate in licensed activities who may receive exposures that exceed the public dose limits in 10 CFR Part 20 should be instructed as to their tights as radiation workers and the necessary procedures for safe usage of radioactive materials.
The petitioners believe the NRC exemption for source material general licensees permits potentially hazardous radioactive materials to be transported into States without the knowledge or control of State radiation control programs. The petitioners cite two cases that they believe illustrate the problem with the blanket exemption in 10 CFR 40.22(b) granted for source material general licensees. In January 1999, the Colorado Radiation Control Program was notified that a dumpster had activated a radiation alarm at a landfill. The dumpster had been used for construction debris resulting from a remodeling project after a source material general licensee had vacated the facility.
After exposure levels on the dumpster exterior measured 4.9 mR/hr (1.3uC/kg-hr), an investigation revealed that it was a source material general licensee who was responsible for the radioactive material. According to the petitioners, further investigation found the licensee ensured that its procurement did not exceed the 150-pound (68kg) per year limit specified in 10 CFR 40.22(a), had vacated the building with contamination [ calculated at 734 mrem / year (7.34mSv/yr)] that exceeded the 25 mrem (250 uSv) annual limit for release for uncontrolled use, and had significant levels of exposure to thorium and its daughters at its current facility. The petitioners state that under the exemption in 10 CFR 40.22(b), this and all other licensees who use similar quantities of source material are exempt from the health and safety requirements 1
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7 contained in Part 20.
The petitioners also cite a 1994 Environmental Protection Agency (EPA) enforcement action against Broomer Research, Inc., of Islip, Long Island, New York found as a result of an Internet search. EPA identified significant levels of radionuclides in the sludge from a plant where thorium fluoride was used in the manufacture of optical lenses. The petitioners do not believe that these cited cases are unique and are concerned that only one of the suppliers of thorium fluoride identified in an Internet search has provided a list of its Colorado customers as requested.
The petitioners also contend that waste disposal by these general licensees creates exposure hazards and believe that general licensees who possess source material do not view waste disposal as an issue because this waste is only " Generally Licensed" and can be disposed of as common trash. Disposal of radioactive waste is controlled for specific licensees by the requirements in 10 CFR Part 20 that prohibit disposal as common trash or dilution of waste in order for it to pass undetected through monitoring alarms at landfills, unless specifically authorized by regulation or license condition. The petitioners are concerned that when radioactive waste from source i
material licensees is transferred, those who receive the waste may be unaware of any i hazard and subject to potential exposure, and may pass the hazard to another waste
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l handler who is also unaware of the potential exposure.
l The petitioners considered three other regulatory alternatives to restricting the exemption for source material general licensees that included taking no action, separately licensing each entity who uses source material and could exceed Part 20 1
8 exposure limits, and removing the exemption for all source material general licensees.
The petitioners determined that taking no action is unacceptable because it allows general licensees to ignore basic radiation protection standards and provides no protections to radiation workers.
The petitioners also determined that issuing a license to each source material general licensee would involve more expense than amending the regulations and would be unworkable because these types of licensees often go in and out of business. Also, the petitioners believe it would be inappropria.a to apply conditions to each source material general licensee absent a rulemaking process and that the NRC wou!d not be able to easily determine the scope of activities for each licensee. Lastly, the petitioners determined that removing the exemption in 10 CFR 40.22(b) for all source material general licensees would be inappropriate because many of these licensees use only small quantities of source material and pose very minimal risks to employees and the public.
The Petitioner's Conclusions The petitioners conclude that 10 CFR 40.22(b) provides a blanket exemption for source material general licensees from the radiation protection and worker notification and instruction requirements contained in 10 CFR Parts 19 and 20. The petitioners also conclude that no basis for this exemption exists because it allows these licensees to exceed currently specified dose limits, create areas where individuals may be exposed to significant levels of radiation, and dispose of radioactive waste in ways that are not permitted for other licensees. The petitioners request that the exemption in
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.9 1dCFR 40.22(b) be restricted as detailed in their petition for rulomaking to exclude source material general licensees who could exceed public dose limits or dose equivalent limits for an embryo / fetus or would require personnel monitoring or posting of a radiation area.
Dated at Rockville, Maryland, this 29 day of June,1999.
For the Nuclear Regulatory Commission.
Ned-V nnette L. Vietti-Cook,-
Secretary of the Commission.
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