ML20236H607
| ML20236H607 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1998 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20236H538 | List: |
| References | |
| SECY-98-028-C, SECY-98-28-C, NUDOCS 9807070284 | |
| Download: ML20236H607 (2) | |
Text
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NOT ATIO N VOTE RESPONSE SHEET -
l- TO: John C. Hoyle, Secretary FROM: COMMISSIONER DIAZ l
f
SUBJECT:
SECY-98-028 - REGOLATORY OPTIONS FOR SETTING STANDARDS ON CLEARANCE OF MATERIALS AND l EQUIPMENT HAVING RESIDUAL RADIOACTIVITY
, with comments Approved X Disapproved ' Abstain Not Participating Request Discussion l
- . COMMENTS:
f SIGNATUR'E G )
Release Vote / x / 5 '2.2- %
DATE Withhold Vote /- /
Entered on "AS" Yes x- No
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P # Poil* 4 ,%' n CORRESPONDENCE PDR y E-- ._ . __ i
Commissioner Diaz's Comments on SECY 98-016 i support Option 3 as outlined in SECY 98-028 directing the staff to proceed with a rulemaking and develop uniform, dose-based regulations for the clearance of materials and equipment having residual radioactivity, independent of EPA. This effort should begin no later than FY 1999. We should establish criteria for the solid waste effluents in a compatible manner with the gaseous and liquid effluent criteria in Part 20. The present use of Regulatory Guide 1.86 does a disservice to the industry and public by not establishing specific dose criteria for very low levels of radioactivity. I also believe that waiting for an EPA standard without any certainty that such a standard will be promulgated does not address this issue in a timely fashion for either NRC and Agreement State licensees.
This proposed rulemaking is a necessary part of the NRC mosaic of rules and regulations directly applicable to radiation protection, and an integral part of the processes by which we are establishing and promulgating how to best protect the worker, the public, and th environment.
Recent examples of our actions include the just promulgated final rule on radiological criteria for license termination, NRC comments on the EPA's Interim Version of Federal Guidance Report Number 13, entitled Health Risks from Low-Level Environmental Exposures to Radionuclides, and development of high level waste disposal regulations for Yucca Mountain. A.:! these efforts are consistent with the intemational standards recommended by scientific expert bodies such as ICRP and could be made consistent with the just published !AEA Interim Report, Clearance Levels for Radionuclides in Solid Materials - Application of Exemption Principics.
There have been previous attempts to establish a range of requirements to deal with various aspects of release of radioactive materials and licensee practices. At some point, the Commission must make an informed decision based on good science, cost benefit analysis, risk information and the protection of health and safety. This decision should not be based on technologicalimprovements on detectability of radiation at minuscule levels, but on an assessment that the doses are so low as to have no measurable impact on health and safety, and that disposal under prescriptive criteria could create unnecessary cost to ratepayers and taxpayers. There is a necessity to economically dispose of equipment and waste from nuclear power plants, industrial and fuel facilities, with minimal levels of radioactivity, as well as, facing the national problem of disposing large volume-very low activity wastes from DOE facilities. This is compounded by the diminishing low-level waste disposal space and its escalating costs.
Therefore, now is a good time to establish the criteria for disposal of radioactive material at J levels well below those doses that are considered to have potential health impacts. This should be protective levels basud on realistic scenarios of health effects from low doses that still allc.vs quantities of materials to be released. A preliminary t,oundary condition should be that these levels not result in doses exceeding those to the public from materials previously released by States and federal agencies and with consideration of the natural background radiation doses.
I I believe that NRC is obligated to establish a structured and credible process with stakeholder input, especially Agreement States, before any regulatory decisions are made on these standards.
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