ML20235V457
| ML20235V457 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/27/1989 |
| From: | Espenan G AFFILIATION NOT ASSIGNED |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 53FR49886-00193, 53FR49886-193, NUDOCS 8903100196 | |
| Download: ML20235V457 (2) | |
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'89 MAR -7 P3 :57 February 27, 1989 U '..'.
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$NahLM Mr. Samuel Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Proposed Policy Statement on Exemptions from Regulatory Control; Federal Register, Volume 53; December 12, 1988. Page 49866
Dear Mr. Chilk:
This letter is in response to the request made in the above mentioned Federal Register notice. As a professional health physicist, I fully support the Commission's efforts to place the appropriate emphasis on practices which are Below Regulatory Concern (BRC).
I agree with the recommendations and limits proposed by the Health Physics Society in Dr. Lauriston Taylor's letter to the. Commission as well as with the concurrent opinions expressed by both the Edison Electric Institute (EEI) and the Nuclear Management and Resources Council (NUMARC).
It is time to enact a BRC policy based on actual rather than perceived societal risks. The hypothetical risks posed to the general public from BRC based on a criterion of 10 mrem / year are incredibly insignificant when compared to the actual risks an individual faces every day. As such, BRC risks should be treated as insignificant. Since the EEI and NUMARC have amply responded in a straightforward fashion, I wish to add my personal thoughts to their endorsements. Listed below are general comments which summarily address the items which the NRC has requested Comments on.
For the purposes of regulation, a collective population dose criterion is illogical. If none of the individuals exceed the limits (i.e. are safe) then a community of individuals as a whole are safe.
For this reason, only an individual dose criterion is necessary. The use of a collective dose criterion becomes not only meaningless but detrimental to the public's understanding of the issues and significance of BRC.
It therefore fosters misunderstanding. These population collective doses are only useful when determining if exposure controls are effective (ALARA) or when used as a means to weigh alternative practices.
8903100196 890227 PDR PR CHP1 53FR49BB6 PDR
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Page 2 February 27, 1989 An individual's dose from each source or practice should be a fraction of his overall limit. This practice is sensible and consistent with previous regulatory guidance.
In order to insure compliance, the prospects of monitoring exempt practices, licensees sorting practices, and environmental monitoring were considered.
If practices are exempt, then we have deemed by their nature that they don't require monitoring. It does not then appear that monitoring them is logical or an appropriate use of manpower. Non-exempt licensae's sorting and segregation practices however will require close regulatory attention and complete documentation. This area will require the l
continued attention and emphasis which it is presently deemed.
As far as environmental monitoring is concerned, I believe that the inplace state and federal environmental monitoring system is capable of insuring continued regulatory compliance and providing an independent reassurance to the public of the effectiveness of the system.
In the area of exposure justification, practices which are presently licensable have been deemed justifiable.
The re-examining of these areas is not necessary or relevant.
However, simply because a process is justified does not mean that all resulting BRC exposure rates have been optimized.
The goal of optimization should be an attainable limit encompassing cost / benefit analyses and below this limit, further dose reductions are not necessary or practical. A measurable goal (i.e. 10-20 mrem /yr) fulfills this criterion.
Based on the extensive documentation and scientific opinion on BRC, it has been demonstrated that it is time for a cogent, consistent, and timely implementation of a BRC methodology.
I encourage the NRC to quickly move towards the implementation of this policy based upon the benefits which will be derived for society as a whole and the insignificant risks associated with these practices.
fe' Z) nan Grego
-. Esp nan, M.S., N.R.R.P.T.
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