ML20236V619
| ML20236V619 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/1998 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Shirley Ann Jackson, Mcgaffigan E, The Chairman NRC COMMISSION (OCM) |
| References | |
| COMNJD-98-004, COMNJD-98-4, SECY-98-028-C, SECY-98-28-C, NUDOCS 9808040085 | |
| Download: ML20236V619 (2) | |
Text
-- - - --
i
\
uno STms
\ sucuynEjy[$.$$37 RELEASED TO THE POR . i W
[' uf,,i q q g E 3_g l.,........
i ,
. r-. u[ [inw ate :
i OOMMIS31CNER COMNJD-98-004 Julv 9,1998 MEMORANDUM TO: Chairman Jackson Commissioner McGaffigan ;
I FROM: Nils J. Diaz
SUBJECT:
CLEARANCE RULE - SECY-98-028 As I noted in my vote on SECY-98-028, " Clearance of Materials and Equipment Having Residual Radioactivity," I believe now is the time to establish solid radioactive material clearance levels that are protective of public health and safety. Our present regulatory framework, which allows clearance of detectable solid waste only in a piecemeal I fashion, is an archaic construct that has been rendered inconsistent and obsolete by j advances in risk assessment methods ~and in detection technology. Gases, liquids and ]
solids are the three phases for processing, using and releasing radioactive materials. j Their different properties do require different treatments and regulatory attention. It I appears that quantities of vary low-level radioactive or radioactively contaminated {
materials are increasing, piling-up and showing-up both expectedly and randomly.
Regardless of the way in which radioactive materials enter the public domain, they become issues of health and safety and should be dealt with as such. Clearance levels have been established for gaseous and liquid phases, they should also be established for solids.
O Because of the lack of consistent clearance levels for solid radioactive materials, i
radioactive materials are being released by some licensees through license conditions or exemptions on a case by case basis, and with significant variations contingent on the NRC organization with the regulatory responsibility,i.e., NMSS or NRR. Some of these same materials are also treated differently depending on the nature of the licensee and the perception of danger given the source of the material. For example, cobalt 60 l
waste can be found in both solid and liquid forms. Although such releases by licensees 9gi g i are based on prudent assessment of risk to the population, it follows that a better, more consistent framework should be provided. Part 20 has established concentration limits for the release of cobalt 60 for water effluents, and commensurate levels that are as protective as the limits for liquid effluents can be established for the solid forms.
9808040085 980709 PDR SECY l, - P / t4 o1 b 98-028 C PDR f O4M (' ( 0 l l
J
e Clearance levels are essential in a global environment where recently there has been low-level ccbalt 60 contamination discovered in pots, low-level cobalt 60 contamination in steel from Brazil, and cesium 137 releases from a factory in Spain. These instances had in common that there was no credible hazard to public health and safety.
However, undue fear was created; the resources expended and public backlash from these types of occurrences could be reduced if clearance levels are established from a health and safety perspective and these materials regulated accordingly. Clearance levels for solid materials can be established at levels well below those doses that are considered to have potential health impacts and still allow quantities of materials to be released based on realistic scenarios of health effects.
In developing clearance levels, it should be noted that the reasonableness notion incorporated in the "as low as reasonably achievable" concept can be quantified and should not be exceeded by regulatory requirements. Risk information is a tool to accomplish this. In this regard, the staff should develop and implement a graded safety value scale to allow licensees to better apply resources and procedures to areas of greater safety significance.
Public health and safety is a many-pronged issue where benefits and costs are to be balanced if no consistent clearance levels are established or are arbitcary (whether too conservative or too permissive), the ad hoc (or de facto) levels can divert resources, both public and private, that should be used for valid health and safety concerns. We have an obligation to address this issue now, even though the agency is resource constrained and it may be controversial.
cc: SECY please track 1
l 2
c 1
i