ML20246F065
| ML20246F065 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1989 |
| From: | Moeller D NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| NACNUCLE, NUDOCS 8905120115 | |
| Download: ML20246F065 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION UNITED STATES n
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ADVISORY COMMITTEE ON NUCLEAR WASTE o%
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WASHINGTON, D.C. 20066 May 3, 1989 The Honorable Lando W. Zech, Jr.
Chairman U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Chairman Zech:
SUBJECT:
PROPOSED COMMISSION POLICY ON EXEMPTIONS FROM REGULATORY CONTROL During its ninth meeting, April 26-28, 1989, the Advisory Comittee on Nuclear Waste (ACNW) met with members of the NRC staff to discuss the proposed Comission Policy on Exemptions from Regulatory Control.
We also had the benefit of the document referenced. This matter was also a subject for discussion at several of our previous meetings.
We most recently comented to you on this matter on December 30, 1988.
As a result of our review, we believe the latest version of the proposed Policy Statement has successfully addressed a number of formerly unre-solved issues.
Areas that still need to be strengthened and/or clari-fied are listed below:
1.
The Policy Statement should state unequivocally that practices (including sources and devices) that are candidates for exemption should not, taking into consideration all such practices, result in mrem (about 0.1 mSv) greater than a small fraction [1.e., about 10 an annual dose rate per year] of the long-term annual dose limit
[100 mrem (1 mSv) per year] for individual members of the public.
Although this could mean that the dose rate from individual sources might approach 10 mrem (0.1 mSv) per year, suitable adjustments will need to be made where a given population group might be exposed to multiple sources.
2.
Another important consideration, particularly in terms of releases of radioactive materials into the environment which represent an irretrievable action, is the associated longer-term dose comitment to the affected population.
In essence, the proposed policy must take into consideration both the annual dose and the dose commit-ment.
3.
We continue to believe that the permissible annual collective dose limit should be reduced as the allowable dose rate to members of the public from individual practices increases. We urge that this approach be made a part of the Policy Statament.
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The: Honorable Lando W. Zech, Jr. -. 2 --
May 3,'1989 4.
Although differences, in - the dose rates to members of the public from natural background sources can be used to provide perspective,
.we believe that such differences.should not be-used as. a justi '
fication ' for. setting _ dose rate - limits for. practices being. con-'
sidered for exemation.
The Policy Statement should be modified to reflect this lim'tation.
Sincerely,.
Dade W. Moeller Chairman
Reference:
Memorandum dated April'13, 1989 from Bill M. Morris, Office of Nuclear.
Regulatory Research (RES), for Raymond F. Fraley, ACRS', transmitting Preliminary RES Draft of Proposed Commission Policy on Exemptions from Regulatory Control
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