ML20236K568
| ML20236K568 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1998 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Ringenberg J NEBRASKA, STATE OF |
| Shared Package | |
| ML20236K570 | List: |
| References | |
| NUDOCS 9807100001 | |
| Download: ML20236K568 (4) | |
Text
____ - _ ___-_-__ --_______ -
, Mr. Jay D. Ring:nbsrg LLRW Program Manager Department of Environmental Quality MN30 2 P.O. Box 98922 Lincoln, NE 68509
Dear Mr. Ringenberg:
This letter is in reply to your May 13,1998 request for technical assistance pertaining to
- performance objectives outlined in Subpart C of 10 CFR Part 61. A conference call was held May 26,1998 between NRC staff and your technical team members. The minutes from this
- meeting are enclosed (Enclosure 1).
. NRC staff advised the State of Nebraska that:
- 1. 10 CFR Part 20 and compatible Agreement State regulations incorporate ICRP 30 dose methodology with a 1mSv (100 mrem) per year dose limit for members of the public. No existing U.S. Federal or State Guidance adopts ICRP 60.
- 2. 10 CFR Part 20 Appendix B values were' adjusted by a factor of two to adjust for )
' different age groups. Calculations used by the commentor in calculating child I doses appeared to assume adult intake factors, therefore, this approach would lead to unrealistically high doses to children.
i- )
l .3. The commentor's approach to calculating the chlorine-36 component of the !
inventory appeared incorrect.
1 As promised, I have enclosed a copy of the May 26,1998 fax, from Cynthia G. Jones, Office of ;
L Nuclear Material Safety and Safeguards, to Gary Butterfield (Enclosure 2) which includes. !
- j. sections of 56 FR 23387 for your information.
l- .
l If you have any other questions on this matter, please contact me, or Lance Rakovan of my staff at (301) 251-2589, LJR2@NRC. GOV. _
i Sincerely,
! /S/ Richard L. Blanton l 60 Paul H. Lohaus, Deputy D; rector Office of State Programs J
j,
Enclosures:
' l' As stated.
{
. cc: . Gerald Allen, NE I E
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- See previous concurrence.
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%.... # June 30, 1998 Mr. Jay D. Ringenberg LLRW Program Manager Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509
Dear Mr. Ringenberg:
1 This letter is in reply to your May 13,1998 request for technical assistance pertaining to performance objectives outlined in Subpart C of 10 CFR Part 61. A conference call was held ]
May 26,1998 between NRC staff and your technical team members. The minutes from this meeting are enclosed (Enclosure 1).
NRC staff advised the State of Nebraska that: i l'
- 1. 10 CFR Part 20 and compatible Agreement State regulations incorporate ICRP 30 dose methodology with a 1mSv (100 mrem) per year dose limit for members !
of the public. No existing U.S. Federal or State Guidance adopts ICRP 60.
- 2. 10 CFR Part 20 Appendix B values were adjusted by a factor of two to adjust for !
different age groups. Calculations used by the commentor in calculating child I doses appeared to assume adult intake factors, therefore, this approach would l lead to unrealistically high doses to children.
- 3. The commentor's approach to calculating the chlorine-36 component of the 1 inventory appeared incorrect. l As promised, I have enclosed a copy of the May 26,1998 fax, from Cynthia G. Jones, Office of i Nuclear Material Safety and Safeguards, to Gary Butterfield (Enclosure 2) which includes sections of 56 FR 23387 for your information, if you have any other questions on this matter, please contact me, or Lance Rakovan of my staff at (301) 251-2589, LJR2@NRC. GOV.
Sincerely,
- s ,
1 Paul H. Lohaus, Deputy Director Office of State Programs
Enclosures:
As stated cc: Gerald Allen, NE
MINUTES FOR THE MAY 26,1998 TELECONFERENCE
SUBJECT:
Assistance to the State of Nebraska on Their Independent Performance Assessment Accompanying the Draft Safety Evaluation Report for the Proposed Low-level Waste Disposal Facility On May 26,1998, a telephone conference was held between NRC staff and representatives from the State of Nebraska in response to the May 13,1998, written request from Jay D.
.Ringenberg to Paul H. Lohaus, Deputy Director, Office of State Programs.
Attendees on the call were:
NRC: NMSS - Joe DeCicco (IMNS); Cynthia Jones (IMNS); Tim McCartin (DWM); Keith McConnell (DWM); Chris McKenney (DWM); OSP - Lance Rakovan.
State of Nebraska: Gerry Allen (NDEO); Dick Arnold (HGR); Dan Bullen (lowa State);
Barry Butterfield (HGR); John Fasselli (NDEO).
Dick Arnold noted that the purpose of the call was to assist the State in responding to several issues that were raised during a public hearing in February related to the State's Disposal Safety Evaluation Report (DSER) for its low level waste (LLW) disposal facility.
The first issue was related to whether ICRP 30 or ICRP 60 should be used for dose assessments and. In addition. whether the comoliance calculation should use doses for a 5 vear old child rather than an adult.
NRC Response: Existing Presidential Federal Guidance to doses to members of the general public references the ICRP 2 cbse methodology with a 500 mrem /yr dose limit.10 CFR Part 20 and compatible Agreement State regulations incorporate ICRP 30 dose methodology with a 100 mrem /yr dose limit. No existing U.S. Federal or State Guidance adopts ICRP 60.
Representatives from the State noted the existence of a draft Federal Guidance Report 13 (FGR 13) report on Health Risks from Low-Level Environmental Exposure to Radionuclides.
NRC responded that it had recently met with EPA's Science Advisory Board Federal Guidance Report Review Subcommittee, noted several major technical concerns with FGR 13, referenced Hugh Thompson's letters to EPA Acting Administrator Wilson dated February 4 and 6,1998, (that outlined NRC's five major technical concerns) and stated that it was the Commission's recommendation that the draft should not be issued as Federal Guidance Report. NRC also noted that its views and a copy of these concerns had been sent to Agreement States on April l 22,1998,in All Agreement States Letter SP-98-033.
For the consideration of children in the compliance calculation, NRC staff indicated that 10 CFR Part 20 and Nebraska's equivalent regulations already incorporate a dose reduction factor of 2 to assure that the regulations adequately protect children as well as adults. Specifically, Part 20 references that the 10 CFR Part 20 Appendix B values were adjusted by a factor of two to adjust for different age groups. Cynthia Jones provided the Statement of Considerations sections for Part 20 that relate to this approach to the State of Nebraska. A final observation by NRC was that calculations used by the commentor in calculating child doses used adult intake factors, an approach that would lead to unrealistically high doses to children.
ENCLOSURE 1 L________-_--___-
0 ,
A concluding recommendation, by NRC staff was that the State should note the consistency of the State's approach and the use of ICRP 30 with 10 CFR Part 20.
Ibe second issue was related to the inventory of chlorine-36 and a commentor's statements that the inventories of chlorine-36 should be calculated usina a ratio of Cl-36 to Cs-137.
The State noted that the ratio used by the commentor did not appear to be a valid way to calculate inventories because the UK's NIREX fuel process was unlike that in the U.S. NRC noted that in the test case evaluated to support the draft Branch Technical Position (BTP) on Performance Assessment for LLW Disposal Facilities, the inventory was based on material .
disposed at the Richland, Washington facility, and that chlorine-36 was primarily derived from l industrial sources and not from nuclear reactors as the commentor had suggested. Several hundred mci of chlorine-36 was disposed of in the Richland facility. Dan Bullen (lowa State) also indicated that the commentor's reference to the NIREX report as a reference for the contribution of nuclear reactors to the chlorine-36 inventory was inappropriate because of the differences in approach to the U.S. fuel manufacturing process. In addition, Bullen noted that i the Manifest information Management System showed no chlorine-36 being disposed of in the years from 1986-1994 for the Central Compact. The bottom line from this discussion was that the State believed they had a strong argument that the commentor's approach to calculating the chlorine-36 component of the inventory was incorrect, and that little to no chlorine-36 wa7 likely to be disposed of in the Nebraska facility.
At this point the discussion ended. Nebraska indicated that they were satisfied with NRC's assistance and thanked the staff.
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