ML20247N389
| ML20247N389 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8908020382 | |
| Download: ML20247N389 (87) | |
Text
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Document Control Desk, 016 Phillips ADVANCED COPY TO:
The Public Document Rocm 3/ff DATE:
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Attached are copies of a Commission meeting transcript and related meeting
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION ff(}$'
BRIEFING ON POLICY STATEMENT ON RULES FOR EXEMPTION FROM REGULATORY CONTROL LOCatiOL:
ROCKVILLE, MARYLAND h&[6l JULY 11, 1989 l
l PagGS:
65 PAGES NEALR.GROSSANDC0.,INC.
COURT REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest l
Washington, D.C.
20005
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(202) 234-4433 t
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, i _.,;.,1 DISCLAIMER This is an unofficial transcript f a meeting of the United States Nuclear Regulatory Commission held on Julv 11, 1989, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open-to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general 1
informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination 1
1 or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained ' herein, except as the Commission may authorize.
I NEAL R. GROSS court REPORTERS AND TRANSCRIBER 5 1323 RHoDE ISLAND AVENUE. N.W.
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. UNITED STATES ~OF AMERICA-4 t-
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NUCLEAR. REGULATORY COMMISSION 1
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-BRIEFING ON POLICY STATEMENT ON RULES FOR EXEMPTION FROM REGULATORY CONTROL-i i
PUBLIC MEETING L
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Nitclear Regulatory Commission
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One White Flint North
{i Rockville, Maryland i-
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i j\\i Tuesday, July II, 1989' b
i, The Commission met in open session, pursuant l
l to notics, at 1:30 p.m.,
Kenneth M.
Carr, Chairman, presiding.
COMMISSIONS.RS PRESENT:
KENNETH M.
CARR, Chairman of the Commission THOMAS M. ROBERTS, Commissioner KENNETH C. ROGERS, Commissioner JAMES R.
CURTISS, Commissioner
.(
4 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 23u433 WASHINGTON, D C. 2000$
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2 e.TAFF Af;D PRESENTERS SEATED AT THE COMMISSION TABLE:
SAMUEL J.
CHILE, Secretary o
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WILLIAM C.
PARLER, General Counsel I
i ll FRAf;K CONGEL, NRR
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ROBERT BERf;ERO, NMee JAMES TAYLOR, Deputy Executive Director for Operations i
l THEMIS SPETS, RES l
E I LI, LAHS, EEE i:r' i
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.I P-R-O-C-E-E-L-I-N-G-S f{
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CHAIRMAN CARR:
Good afternoon, ladies and 9
4 gentlemen.
i 5i The purpose of today's meeting is for the 6
NRC staff to brief the Commission on the revised 7
policy statement on exemptions from regulatory F
contro], which is the subject of SECY-89-184.
O The staff has revised the polscy statement t
'r based on information gained from an international l
l 11 workshop on exemption for regulatory control held in 12 Ort abe r 19FF.
Public comments on an advanced notice 13 h of the proposed policy statement issued in December n
3 t.
'88 and a public meeting held in January 1989.
35 h Copies of the presentation slides should be e
16 h avai]ab]e at the entrance to the meeting room.
l 17 Do my fellow Commissioners have any opening 18 ;
comment?
If not, you may proceed, Mr. Taylor.
t i
19 ;
MR.. TAYLOR:
Good afternoon, Mr. Chairman.
I 20 h The policy statement discussed today can l
21 have a significant and positive impact on the way the 22 resources of both licensees and the agency are used.
specifically the staff believes that the policy 23 I
24 ji estab ishes a basis for assuring that these limited 25 resources are not directed toward elimination of small 1
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risks from low levels of radioactivity when they could 1
1 bo better spent in reducing risks for larger
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quantities of naterial, of radioactive material, or in 4
otherwise enhancing public health and safety.
S There's been significant public interest in 6
the proposed policy and a range of views on what the 7
policy should say in its specific elements.
This is P
demonstrated by the large number of comments you will 9j hear about today and the diversity of views expressed u
10 by the commentors.
There have been numbers of letters 11h from state and county officials and from Congressmen a
3?
relaying questions or concerns from constituents.
13 With that introduction, I'll now turn it g
t n
3 4 !!
over to Dr. Speis to commence the detailed briefing.
hI DR.
SPEIS:
Thank you, Mr.
- Chairman, 15 l 36 Commissioners.
17 Before I turn it over to Billy Morris who 18 will do the main part of the presentation, I would 19 like to say that the challenge to us has been to 20 assess this divergent views discussed by Mr. Taylor, 21 taking into account the relevant technical information 22 and develop a policy which achieves the resource 23 ut il i rat ion goal mentioned earlier but also assures that the health and safety of the public is protected.
t
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The staff has now proposed resolutions to NEAL R. GROSS j
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Ag *',
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1 the significant issues related to this policy 1
li 7"
statement in the Commission paper SECY-89-184, which ll d
1 ll is in front of you for your consideration, of course.
4h The presentation today will provide an F
1 5
opportunity to focus on these issues; issues such as i
1.
6 whether justification of practice and a collective f
7 dose criteria should be part of the policy, and the i
8 different views of EPA on some key elements of the i
9j po: icy such as the individual dose criteria.
30 As I said already, Billy Morris of the 11 h offier of Resource will make the presentation.
He L
'?
w; 1 be assisted by Bil] Lahs, sitting next to him.
il il lI Mr has been the task leader for the policy i
h la h dove]opment.
1 25 li A3so we have with us Don Cool sitting back I
16 here, who has recently been appointed as Chief of the 37 j
Radiation Protection and Health Effects Branch and he i
18 l
will also be available to answer some of your l
19 l
questions.
i I
I l
I would a]so like to recognize others who 20 21 h a v r-played a significant role in the development of 22 t hi s policy from the other offices, especially Mr.
23 Bernero from NMSS and Frank Congel from the Office of 24 NEP And a3ro sitting back here Dick Cunningham from 1
26 th.
Office of NMSS.
NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W j
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T will now turn the presentation over to
't 2"
S1 3 Matris, Mr. Chairman.
3d VF MOFETF?
During the presentation this l
4p
.afterncen T will be generally following the outline U
I 50 shown on the first page of the handout.
We'll briefly 6'
sunmarize thc
.n e t i vi t i e s which culminated in itsuance 7,
of the advanced notice of policy development last 8
December nnd the rore recent milestones which led to 9
4 staff's r9 cent proposal for a revised policy.
10 j w!]1 on]y briefly review the objective of the prile>
staterent and examples of practices for 11 ij 1
17 i, w:
w: M irvt the po3 icy can be applied, but then 11 h di wuss in sorr vore detail the basis for the staff's t
U h
r.o r o rm e n d e t 5 c :. on the major policy elements _ and 34 Us 15 h adCtionc factors the Commission should be aware of n
36 l a: Jt considers how it wishes to proceed.
17 The second page of the handout shows the 1S prrtinent chronol ogy of events which have led us to l
19 where we stand today.
In November of 1987 the staff 1
20 was asked to initiate development of a proposed policy l
l 21 statement which would identify a risk level below 22 which government regu3ation becomes unwarranted.
In 23 SECY FF-6C and during the related Commission meeting 24 on that paper, various concepts and approaches and the d'
25 relevant issues invclved in devcloping such a policy NEAL R. GROSS i
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1 were discussed.
The concept of risks which are below
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regulatory concern was discussed in the context of j
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i 3 !l establishing a floor ' to the ALARA process and was 4g proposed as being potentially different from the n
4 ij 5h concepts of de minimis or negligible risks.
I q
1 6
Staff plans for organizing an international 7
symposium or workshop to be attended by national and 8
international] regulatory authorities on this subject C
were also presented at that time.
10 Fo33owing that meeting the Commission asked 2*g for the development of a proposed policy to be acted
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c:.
by the Cor :.i ssion prior to the international l
13 h raeting.
This was provided in SECY paper 88-257 in i
14 which n policy was proposed which relied on adherence 15 tn basic radiation protection principles in evaluating 16 I exemption proposa2s and suggested compliance with 17 certain dose criteria as a basis for cutting off the d
18 h ALARA process.
The Commission modified that paper and 29 that policy statement and recommended that comment be 20 sought on certain major policy provisions that were of f
1 21 significant interest to the Commission.
They directed 22 the issuance of an advanced notice, which was then 23 published on December 12, 1988.
24 Going on to page three, and with this i
25 background in mind, I'll briefly note that then the i
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1 put pos e of today's presentation is to discuss the 1
o i:
2 policy statement as it has been revised based on the 1
3d information from the international workshop, public l
l 41 corments received between December of 1988 and April l
l 5
1989, proposed policy.
And finally, on the public 6
meeting he3d in January of this year.
7 On page 4 we just briefly note that the E
nbjective of the policy statement is to establish i
i o
guidelines and criteria for development of regulations U
30 or licensing decisions which could exempt practices 13 h fro-some or all regulatory controls.
Such guidance, 12 h when availab3e, would
.ed to a more efficient and
!!n l
censistent decision making procese related to these 13 e
i la exemption proposals.
{il 25 j S on, e specific examp3es of how the policy 1:
16 p cou3d be app]ied are indicated on page 5 of the i
l handout.
These include application to practices such 1 *7 i
as disposa]
of very low level radioactive waste; 18 j
i 19 release of lands and structure with small residual 20 '
Jevels of radioactivity; distribution of consumer 21 products containing small amounts of radioactive 22 materia]; recycle and reuse of residua 11y contaminated 23 materials and equipment.
24
- How, there are various ways that either i
25 rulemaking or licensing decisions could be initiated.
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9 1;1 with regard to the first of these items on this page, 0
'l 2d we do expect petitions from the industry for 3 !I ruler.aking under the Commission policy for disposal of l
4l the below regulatory concern waste streams which 5l implements the Low Level Radioactive Waste Policy 6
Amendments Act of 1985.
7 A]ternately, there may be applications for S
3icense amendments or the action that could be 1
9]-
involved could be a decision of the Commission or "OL sonething that the staff wou3d initiate and propose to 13 l; the Commission.
I want to just mention that in each H
12 d of thesr cases the focus of the regulatory decision it h
13 0 vould be on an exemption of a practice from some or d
l a !l all regulatory controls.
And just because we'll be 15 h using the word time and again during this H
1F h presentation, let me mention that
" practice" is 9
f defined in the policy statement as an activity or a 17 1 F' set or combination of a number of similar sets of 19 coordinated and continuing activities aimed at a given 20 j
purpose which involve the potential for radiation 21 exposure.
That rather involved definition is one that 22 we found useful.
It is essentially from the IAEA l
23 Safety Guide No. 89.
J pe i
With this objective and these potential l
l 25 applications in mind, let me now mention, on page six NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS l
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- now, the actions the staff has taken to use the h
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- nformation from the international workshop, the i
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3 il public -
ing and the public comments on the proposed I
1, 4jj policy.
We were able to categorize the information we i
5 ;!
had collected into 18 subject areas or issues where we j
k 6
fe3t either we would need to be resolving or an issue
]
l 7
or where we would need to communicate better to the
? liI public what the intent of the policy was.
We then I
i 9 'q rcvised the policy statement in key areas or clarified j
20h Commission positions in other areas.
These were il y eithr<r inc]uded in the revised policy itself or was I
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put into t h r-responses to public comments and which 13 h then were transmitted to the Commission SECY paper 89-T i
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14 l
SP4
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15 Some of these issues were more important g
n 16 than othors.
And what I hope to accomplish in the j
1 1
l 37 4
remainder of this presentation is to focus on the key 4
l 18 issues for which Commission decisions would be most l
39 crucia].
In the Federal Register notice, which was I
20 issued on December 12 of last year, there were several I
23 major policy elements in which comments were sought.
l 22 These are summarized on page 7 of the handout.
23 One question was how should fundamental j
24 principles of radiation protection be applied in f
25 l
establishing an exemption policy?
Specifically, what j
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON. D C. 20005 (202) 232 6600
l 11 I
r rM re should justification of practice, dose limits and
-2 ALARA play in such a policy.
q 34 Another question raised by the Commission n
4 ~
related to the use of the collective dose criterion in Bl establishing a floor to ALARA or a level of risk below l
r 6
which further efforts to reduce doses would be l
7 unwarranted.
The question then is whether a 1
i E!
coilective dose cri terion is needed.
l l
t 4
- Finally, among the major issues was that i
30 a9sociated with the potential that exposures to 11 L r"'tiple practices could result in receiving 32 co u]ntjve doses /
ar the public dose limit even l
i 13; thouch each contribution would be only a small 1
14 I fraction of that limit.
That is, how should t
15 curulative effects from multiple practices be dealt i f, h with?
u 17 i
- Now, on page eight of the handout we've I
18 provided a diagram which we find useful in reflecting i
l on the policy statement and its various elements.
39 l
T'21 be continuing the discussion today along the 20 i
20 lines indicated in subsequent pages of the handout, 22 but you've been provided an extra copy so you won't 23 havc to flip back and forth between the handout and 24 i
tho figure.
i i
2E j; Let me first call your attention to the i
Il NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON. D C. 20005 (202) 232-6600
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.l 12
-l Il u
t ', t ' e of'the figure, which indicates that it applies 3
ll^
l 1
- t. c justifir:4 FIactices.
This brings up one of the
]
I I
3 ll majev policy issues which we discussed earlier on page l
I 4j n i n e-of the handout, which we discussed earlier and 5,
which is a lot more thoroughly discussed on page nine j
j 4
6-n o t, 7
The staff is proposing that justification of 8
p r a c t i e r-is a needed element of the current policy.
4 W '- wou3d continur-the precedent established by the n
10 i Cemissinn's l o 6 c.
policy on consumer products.
The i
13 l'l point wc're making here is that no practice involving "l
l U
i 32 nr.t en ti n1 for exposure of the public to ionizing i
N 13 r a d i a t a c r; fror radioactive material should be 9
hI' 14 i permittr6 without a policy judgment by the Commission 35 thM there i. s n commensurate net benefit to society h
16 i
which would result from that exposure.
I 17 l
COMMISSIONER ROBERTS:
That's a terrible i
1 18 subjective standarc.
19 MR. MORRIS:
There are a number, as we noted 20 j
in the policy statement and in the response to 1
21 com r-nts.
Thir, an area where a broad range of factors 22 can be considered by the Commission in making such 23 po3 ; cy j ud gme r.t s.
But it is one that, as policy 24 d mal c -
tm ' r e recommending that you face up to.
And I
i 4
25 we 6:-
p act limits here on what any of you might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234s.433 WASHINGTON. D C. 20005 (202) 232 6600
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wish to consider, but it does seem to us that you 3o i
should be looking for some benefit in your minds that 2
i 3l would justify this release of radioactive --
1 4
COMMISSIONER ROBERTS:
- Well, what.'s a 4
5 i benefit to me is not necessarily a benefit to somebody 6
else.
7 I don't play golf, but if I did, maybe I'd R
want those funny little balls that you can find in the 9
high weeds.
It would be of no benefit to me u
j 10 [
whatsoever, but some other person might think it was a i
h 11 great benefit.
i;
- 2 ;;
MR.
TAYLOR:
I believe the staff's intent h
3 3 h!
that this is prom hly the best body to mai:e that type
'4 [
of determination in examining the various practices in 35 ;
order to address the problem.
H V
16 o MR.
BERNERO:
And we have had in the ii 17 regulatory arena on the issue of gemstones an example 18 where there's kind of a sitergitism at a very low i
19 level of radiation, it is possible to justify a 20 l
cosmetic benefit as a justifiable practice.
And the i
I..i issue in gemstones is you can get gemstone activity so 1
22 low as to be almost off scale on this chart here and 1
23 then say, "well, is it a reasonable justification of 24 practice that it's simp 3y an ornament?"
So that's 25 j possible.
But if those golf balls, if they've, let's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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4 e
o 1 !l
- say, t.
radioactively traced golf ball had a more n
^j significant dose associated with it or dose rate, then o
3y wr'd have to say is that modest benefit?
Can that be l
I 4d obtained so:ne other way?
Is it justified to put more d
E ll radioactive material into the biosphere for that 6
purpose?
And that's part of that 1965 policy and it's l
7 continuing.
i 8)
CHAIRMAN CARR:
But you're at the point l
ll 4
where you'rt' regulating a voluntary practice.
10 [
COMMISSIONER ROBERTS:
Regulating peopic's a
'I choiCCT.
12 h MF PERNERO:
Yes.
Yes, indeed.
'i L
L 13 i
CHAIRMAN CARR:
And if we could apply the T
14 samc thing to tobacco, we'd have it made, right?
L lE]
COWTeSIONER ROBERTS:
To what?
16 l MF. TAYLOR:
Fortunately, that's not under i
17 om jurisdiction.
18 MR. PERNERO:
No.
But we have from time-to-l I
i 19 time applications for what some would call frivolous l
l l
20 j
uses, you know, luminous fishing lures, the necktie 21 that glows in the dark, that sort of thing.
And the 22 do))'s eyeba]3s, another exv.p3e that glow, that light 23 !;
up.
24 Er do justify the use of radioactive
- f 25 f
- t a *.o r i n 3 in exit signs under general license.
But 5
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I there are other things, the radioactive fishing lure, 1
f 7 '
?l we do not justify.
We don't concider that a
i
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3h sufficient justification for that distribution of l
4h radioactive material..
- j l
1 5h The gemstones being only cosmetic in their q
1 l
1 6
benefit, are justified becaus; of the extremely low 1
7 level of radiation.
In fact, that's basically the i
ji n
P4 qua:ity assurance we provide on it, that they're down i
9-so lov a radiation --
10 c.
COMMISSIONER ROGERS:
Why do you have to do 31 h anything more than that?
22 CHAIRMAN CARR:
If you determine that it's L
13 li truly
"? low regulatory concern, then you shouldn't li 3 4 !!
I we to justify it at all.
I 35 p MR. PERNERO:
No.
But there's a difference.
16 g The gemstones aren*t just at 10 mrem per year.
h 77 l
They're way below that.
I 38 CHAIRMAN CARR:
Oh, no.
I know that.
I 19 MR. BERNERO:
Way below that.
There you're 20 really arguing more a de minimis that it's virtually 21 none radioactive.
22 COMMISSIONER ROGERS:
Why do you have to i
23 really introduce,inything except a health and safety t
24 consideration?
- l 25 l MR.
BERNERO:
Other than the justification I
NEAL R. GROSS COURT REPORTERS AND TRANSCR:BERS 1323 AHODE ISLAND AVENUE.N W (202) 23A44433 WASHINGTON, D C 20005 (202) 232-6630
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36 r-1 of practico.
I mean, that is the issue.
Should a
,l
..*iation --
7, h COMMISSIONER ROGERS:
Well, the thing I have i
i 4H a 3ct of trouble with is this social benefit.
Who is V
l 5;
going to judge a social benefit?
6 MR. BERNERO:
Absolutely.
7 COMMISSIONER ROGERS:
And what's my concept l
l c
F of a social benefit might be somebody else's concept l
9!
of a
social disease.
And I think that it is 10 subject ive, it's cult' Ira).
11 ME. BERNERO:
It is, e
't COMMISSIONER ROGERS:
It's not absolute and 12 h;
13 T don't see why we have to interject this into the 7
i 24 h process if we can properly pay attention to the health h
TE U and safety aspects.
F 36 q MR.
BERNERO:
Okay.
But you see, we're I
1 ~7 l
dealing with radiation exposure, which by definition, i
18 we consider harmful and under the linear hypothesis we 19 consider it harmful even down into undetectable 20 3evels.
And we say it is ALARA, it is as low as 21 reasonably achievable considering the radiation q
22 I
exposure, which is a cost, and the benefit of the i
23 practice, whatever it is.
Whether it be a gemstone or
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it be n 13uclear power plant or x-ray --
o
(
l 3
25 l
COMMISSIONER ROGERS:
But we can't avoid NEAL R. GROSS
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radiation.
We're being exposed right here'as we sit
.i
!l 2 ii hno.
We know that.
,)
3 lI MR. BERNERO:
Certainly we know that.
j ij i
0 COMMISSIONER ROGERS:
And, you know, there's l
4 l'n 5I going to be a certain arbitrariness in this whole L
6 business as your whole policy statement illustrates.
7, You can't really be sure, so you have a couple of I
1 8
different criteria that you're going to apply.
And l
9q interjecting n social benefit, to me, is a very I
30 quest $onab]e kind of area for us to get into.
11 h T can see strong concern for any kind of
!i 1?
ht.7tt and safety question.
We're jumping the gun, "3 h bo*
T can sec questions about toys and cosmetics and c
s r
14 h tM ngs of that sort, things you ingest or rub on your 1F s k i r.
But once you put into the hands of a collection f
I 16 of people such as us who have no special claim to 4
i 1 ~7 j
distinction in this business a judgment of social I
1E beimfit, I think we're out of our depth, frankly.
And j
I can see a strong concern for health and safety.
I 19 l
see abso3utely no justification for adding on to this 20 i
21 l
a layer a judgment of social benefit.
22 MR. TAYLOR:
That may be an element that the' 23 Corrission directs the staff to revise.
It still ll domn't negate the attempt of the staff to set what is
?4 t
ll rs "
a c=pted --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENJE, N W l
1 (202) 2W33 w ASHiNGToN. D C 20005 (202) 232-6600
)
o d
18 q!
1 CUATRMA!! CARE:
It's one of those policy I
r 7
issues, that*s right.
t l
u 30 MF. BERNERO:
It is a major policy issue.
I 4 i CHAIRMAf! CARR:
Okay, then let's proceed.
i!
5j MF MOFFTS:
What we have mentioned here e
l 6
wou3d be that what a decision by the Commission to do i
sor.ething different than the earlier precedents would 8
be a s i g n i f.i c a n t one.
And I would call to the f
a
- t e n t i nr. --
c 10 COMMIS.eIONER ROBERTS:
But that's why we're i
33 i' h T ' t ti
'I l
the 1965 policy statement 2? h MR.
MORPTS:
N 13 h an' the fact that 5
- j h
14 !!
COMMISSIOt?TR ROBERTS:
I don't want to hear 15 g a1 + t h.- 1965 policy statement.
This is 1989.
16 !!
MR. MORRIS:
Understood, sir.
But it still
[
17 i-theit and it may be that you would want to look at i
.18 that stateront again and decide whether it was l
19 i
sorcthing 3cu wanted to change or not because it does 20 have erbodied within it this concept of justification l
l l
21 of pr,cticE, even for very low risks for certain kinds 22 cf uses.
And that's the reason we have called it to 23 l
yeu-attrntion here.
1 l
24.
MP. LAMF-Well, but you may point out also 4l 2 5 'l tha* in the Presidential guidance that is on the books NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON, O C 20005 (202) 232 4600
19 Lj richt now and also the Presidential guidance which is 1
1 2
being proposed for the public also has justification a
3 il
,ractice principle embodied within it.
c_
o I
4ji COMMISSIONER ROGERS:
- Well, you can d
"i justification of practice without necessarily basing l
6 that on a social benefit.
7 MR.
LAHS:
But didn't you raise before in R
yoor mind you said wc11 there would be certain things in toys.
You just made that 9
that you would i
10 decision right there.
It H COMMISSIONER ROGERS:
Sure.
H 2 2 ':
MR.
LAHS:
And that's what we're saying we f
13 h should continue to do.
l l
COMMTESIONER ROGERS:
But I would make it on 14 ll 15 !!
the basis of we don't know enough to be able to ensure I:
16 that there isn't a negative health effect.
Not p
17 lj because it has some other abstract benefit.
If you b;
can connect it to health and safety, then I'm happy.
18 I
19 If you can't, I'm not very happy.
t 20 CHAIRMAN CARR:
Some of those policy things 21 we have to look at.
Let's proceed.
22 MR. MORRIS:
The next issue on page 10 is 23 whether a collective dose criterion should be included 24 in the po) icy and be coupled with an individual dose 25 criterion as a pair of criteria to define a floor to 4
f NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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20
- ^
the ALARA process.
Referring back to the figure, what 1
i 4
w now propose in the policy is a 500 person-rem per
?
j
- q year per practice of value for this purpose.
We 4[
believe that such a criterion is important and should i
1 5i be included for several reasons.
6 The co31ective dose has been commonly used l
l 7
by regulatory bodies, including the NRC, as a measure
~
8i of societal detriment in ALARA or optimum assessments.
h 9y CHAIRMAN CARR:
Is it really a measure of 20 l societal detriment or has it not been what I would 11 call a safety factor, a fudge factor?
7e don't know f
-h l
1 ?
't what ri gh t happen, so let's pick a number and hope
[
o i
13 Il that's it.
14 [
MR.
MORRIS:
No, I think it has been the I
15 former, rather than the latter.
i 16 CHAIRMAN CARR:
What if I had 510 or 490?
f.
MR.
MORRIS:
Yes.
Understood that what i
3 '7 I
18 we're ta3 king about in this policy statement are 19 criteria to assist us in judging exemption proposals.
i 20 They are not limits.
And if a proposal came in and i
21 the analyses said, well the collective dose is 510, or 22 any number above this criterion, doesn't mean that the j
i.
23 proposal would be denied.
It would si= ply mean that 24 you would 3cok at whether there are ways to 25 pra-tically reduce that dose in a cost effective NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W 1
(202) 234 4 33 WASHINGTON. D C. 20005 (202) 232 6 L_ _ _________
(_-,---,--.-
31 1
manner.
And if you found-tat there were none, this p
y 2
policy would not prohibit the exemption being granted h
l 3g on that basis.
I h
A]
And what it does do is, you know, if you 5
look -- well, referring back to the 1965 policy 3
6l
)
r statement and to the 1986 policy statement.
Each of l
7 those policy statements refers to an assessment of 8
co))ective dose as a factor in the assessment.
And 9
neither one of them, however, gives any criteria for J0 what is a sma)) enough collective dose that you need 12 not bother with further efforts to reduce these doses 32 a r.y :ower.
And so, what the criterion would do would 1 3 it be to afford a method to truncate that ALARA process.
t j
'i 4 y' And that's the way we envision it being used, too.
15 CHAIRMAN CARR:
When you add this in, it g
i l
16 '
means that nothing is below regulatory concern because l
1 17 i; you have to lock at everything.
l N
IP MR.
MORRIS:
Well, we believe you should 19 look at everything that you're considering exempting 20 anyway.
21 CHAIRMAN CARR:
But then the term "below 22 regulatory concern" means nothing.
23 MR.
MORRIS:
Well, we are in this policy l
24 j statement somewhat diminishing the use of the term 2;
)
"bo]ot regulatory concern" because --
1l NEAL R. GROSS COURT REPORTERS AND TRANSCRIEiERS l
1323 RHODE ISLAND AVENUE. N W WASHINGTON. D C. 20005 (202)232 6600 (202) 234-4433 J
f 23 1
CHAIRMAN CARR:
But that doesn't seem to be i
?
what wc asked you to do, though.
t 4
l l
3J MR.
LAHS:
It's really creating the basis a
for when we can allow radioactive material to be i
4y 5
transferred from control, from control of our f
6 licensees to someplace where it is'not under our 7
control of our licensees.
Isn't that what we're 8
doing?
I mean, the consumer products for low level 9!
waste disposal in other than licensed sites when we ii 3 0 jl re7 ease a facility that's been contaminated, you know, N
11 h which has some residua'l contamination on the walls.
3?
Ec*re eventua31y going to terminate the license and i
L i
2 3 j{
wolk away from it.
We're trying to set up the c
1 34 criterion of which you're going to make those types of i
15 L j u dg:r en t s.
Remember that the --
16 ih CHAIRMAN CARR:
That's what you're trying to h
17 do.
l 18 MR. LAHS:
Yes.
I 19 CHAIRMAN CARR:
But what I'm trying to do is 20 to find some level of radioactivity that I'm not going 21 to worry about.
22 MR.
LAHS:
Well, that's what we discussed i
23 with you, you know, as Bill mentioned in the earlier 24 da scussi ons we 've had.
And that's why --
5 2'
CHAIRMAN CARR:
Yes.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (2021 234-4433 WASHINGTON. D C m (202) 232 4600
'f
23 3l 4
MP. LAHS:
-- he was saying in a way you're 3
h
(
2 lonking --
!i 3 !j CHAIRMAN CARR:
We're still looking for 4j that l
5l MR.
LAHS:
-- you're grasping for the de 6'
r i r.i ni s or negligib3e risk.
And when we went into 7
this, if we tried to go that way, I think we'd fight a 8
let of battles, but I think you'd find out we'd be i
9 talking about negligible risk which would involve 10 ind$vidual doses that are in the micro-rem range.
I
- 11 0 wan, we'd be -- EPA, FDA talk about negligible risks 1
12,
ws being ten to the minus 6,
lifetime risk.
Whether l
n il 13 h von acree with that or not, if you think that--
hl; because a Jot of people, including myself, feel that 14 n
IE nurber is too small.
And when you translate that back 16 5Mo individua3 doses, you're talking about small 1
17 h nun.be r s, not 10 mrem.
I 18 l
COMMISSIONER ROGERS:
- Well, I understand 19 what you're trying to do and I'm somewhat sympathetic 20 j
to it.
But the prob 3em I have with the collective i
21 dose is how you really determine it, because how far 22 do you trace these things out into possible l
23 eventualities before you give up?
And the multinle i
??
j pnths, the -- a31 these questions.
It seemed to me
?S that it leads you into something that you really can't l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4 33 WASHINGTON. D C 20005 (202) 232 6
ty l
24 1
p avrnliy sure abont in every case.
Maybe in some
? n, y4 a can, se that it right be a useful number guide in
~!
sc.
situatione And in others, almost hopeless to 4l vrz v i f; d
,1 5l l'E LAHF:
That's probably true.
I mean, a e
i i
i, r
f' J e' of vhat you nre saying is true.
What we're trying 7
te do on this collective dose criterion, as we brought F
out I th5nF in your comments the last time we put the 1
l 1 -' ' i r y t r-ye is ron11y to develop that criteria 9
10 u w?
ch nJ'y sepnrates practices nto two major 11 N+rgorios One, those practices such as walhing away P
12 frc fael:5 ie<-
with residual contamination or low i
n 23 y im r ? wartc disposal and specific sanitary land fills, 4
i.
li j
for exarple, as opposed to those practices where you'd 14 15 be t r.1 k i r ;
about widespread distribution of 16 i
raddonctivity to large numbers of people.
Consumer l
17 products If wr ever get into things like recycle of 18 cor.t an i na t ed mat erials or equipments.
t i
l So f r o n, what I've seen, a number in the 19 i.
20 l
range of 500, a 3000, you know, you can vary that I
21 nurber up high probably in order of magnitude.
You're 22 re a)); -- what you're doing is really creating a found 1
rrally applies to the practices involving 23 l
which e
l 24 w' C -sprr-ad di s t ri but i on of radioactivity.
And for the f
4
?5 1 re, levr' waste disposal and for terminating the NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W (202) 2y.-4433 WASHINGTON. D C 20005 (202) 232 6 u_________
l l
25 u
c.
ji 1-licenses on contaminated facilities you're going to h
find you're ta2 king about collective doses that are, i
you know, less than 10 person-rem per year per l
1 41 4i!
package.
5 MR. MORETS:
With regard to the concept that f
6 you're discussing here, we had looked at in the 7
previous version of this the idea of setting up some 8
criterion in the po] icy for truncating the calculation 9
l cf ecliective dose.
That's the issue.
How far out do o
10 you go, how long in time do you ca3culate, how small a 11 L dosa do you chase in time to do these very elaborate 22 ;
ca1eelations.
And we believe that later on in the h
13 l!
implementation phase of the policy we would want to go 14 l back to that issue.
But at this time which would i
1 9 5 ll uitimately be one of what's practical to do, what's i!
16 h possib2e to do in practical terms that would allow us a
l tn distinguish between alternatives or make resource
'L 7 i
optimization calculations.
18 e 19 At this stage of the policy development, we 1
think we have focused on the major policy issues; 20 I
21 whether you should have a criterion in mind as you go 22 forward.
And really not --
23 COMMISSIONER ROGERS:
Well, I'll tell you 24 what we're trying to do is map out some kind of a 3
25 boundary that --
NEAL R. GROSS COURT F1EPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON, D C. 20005 (202) 232 6000
26 1
MR. TAYLOR: 'That is correct.
h 2\\
COMMISETONER ROGERS:
-- gives us a guide as L
f 3'h to where to lonk very hard and where not to look so o
j 4j very hard.
I I
5 MR. TAYLOR:
If you can't show it as being 6
within that boundary, then it lies outside.
I mean, f
7 you have to have sufficient information to establish r,
that it f a]Is within that former --
9 COMMISSIONER ROGERS:
These are really aids, 30
$n o sense, to --
11 j; MR. TAYLOR:
That's correct.
a 12 l COMMISSIONER ROGERS:
-- in administering l
I 13 h the policy and not absolute measures in their own 3a right?
35 MR.
TAYLOR:
If there's not a reasonable l
l 16 !!
hasis to show that, then it would not fall within the H
l' 37 exempt category, right, Bill?
I, 18 MR. MORRIS:
Yes.
Now, what we're saying is 39 that if you --
20 CHAIRMAN CARR:
But nothing is.
23 MR. MORRIS:
-- cannot fall within this box 22 here, that you would then simply do a more elaborate 23 ca3cu]ation.
24 CHAIRMAN CARR:
Right.
Nothing is going to 26 just fall within the exempt category.
We're going to NEAL R. GROSS COURT REPORTERS AND TRANSCR:BERS 1323 RHODE ISLAND AVENUE N W (202) 234 4 433 WASHINGTON. D C 20005 (202) 232-6600
27 1
have to look at everything.
2 (
MR. MORRIS:
Yes.
II 3p CHAIRMAN CARR:
And it's.all going to be a 4
case basis.
So there is nothing that is BRC.
h 5 l1 MP.
MORRIS:
I believe that's one of the 6
reasons we felt that it might be appropriate not to 7
focus on that term in this policy.
And it gives a 8I signal to the public that there would be -- you know, 9
that for instance, licensees would be making these ii
)O deCiskon$.
11 CHAIRMAN CARR:
But I personally think i
12 ii that's the wrong signal and that I happen to be one of h
fi 13 J t h o s r>
guys-that don't necessarily believe that a ll 14 I!
little radiation is harmful because I live in it.
I il o
35 o outs de.
I wouldn't hesitate a minute to move to t
16 t
Denver and you would argue that I really ought to 17 consider that.
l l
18 MR. MORRIS:
No.
What we're saying is that 19 a little more -- every time you add a bit more 20 radiation to the environment and you keep on doing i
21
- that, then eventually what you could add up to is i
22 something that is comparable to the radiation i
23 background we live in.
Double it or comparable to it l
l 24 so you have an extra e3ement.
?
4 25 CHAIRMAN CARR:
But background, as I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 123 RHODE ISLAND AVENUE, N W
@ 2) 234 4 33 WASHINGTON.OC 20005 (202)232 6600
4 38 4
1 understand, varies somewhat --
I 2
MR. MORRIS:
Yes, it does.
3 u
3 CHATRMAN CARR:
-- doubled for certain parts 4
of the world.
And if I fly in the Concord all the Si time instead of a Cessna, why I'd probably get more 6
radiation.
But I don't want to alarm the public that 7
they should always not ever fly the Concord.
I don't i
8 think that's the message I want to send.
9 '!
MR. MORRIS:
We do not either.
30 CHAIPMAN CARR:
No matter how small it is, 11 q any inert: ment of radiation is bad for you.
i 32 MR.
LAHS:
- Well, what you're really i
p a
l' challenging, and certainly a lot of people do, is e
i 14 j chaIJenging the low threshold hypothesis.
L 15 l; CHAIRMAN CARR:
Enll, it considerably rates J6 being challenged because nobody's brought any data out 17 l
to prove it's otherwise.
I 18 l
MR. LAHS:
That's right.
That's right.
So i
19 it's either wa)
F 20 CHAIRMAN CARR:
So you can really defend the l
21 argitment that you ought to use it just per se, 22 MR. MORRIS:
But neither can you dismiss it 13 easily either just because --
j i
24 CHAIRMAN CARR:
I wouldn't dismiss it 25 easily, but I might dismiss it.
I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W
)
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F,E I
l 29 i.
l 1
MF. LAHS:
We've been asked that question a s.
[
2 nu: ber of times and I think I would be willing to lay I
h 3-a wager, I don't know if I'd win it, but I believe if l
4 yei looked at most of the people that deal in i
5 jI evainating the possible cancer from. radiation l
I I
6 exposure, even chemicals for that matter, I think 7
y cm ' r e going to find the vast majority of people 8
bc3 i eve there's more support for the no-threshold C
hn othesis than there is against it.
q 10 CHAIRMAN CARR:
But not measurable.
11 !;
MR. LAHS:
Pardon me.
i:
?2 j CHAIRMA7J CARR:
Not measurably.
They admit t
- f 13 3 th(; aren't going to be able to determine that they h
24 y can measure the additional numbers of cancers.
15 ]
MR.
LAHS:
- Yes, that's correct.
But, I 1:
16 i
mean, if I'm going to add ten mrem or 20 mrem on to 17 l
what you're getting now, say 300 mrem, am I really i
38 l
anured?
If we believe that that little delta can 19 lead to an increased probability of someone getting 20 cancer, shouldn't we be concerned about that?
21 CHAIRMAN CARR:
That's why you're here.
I i
it's a po3 icy statement.
22 don't 23 Let's proceed Yes, sir?
24 !
MF. MORRI.:
We33, along this same line, we E
?
29 dc went to point out additional factors that are in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W
' (202) 234-4433 WASHINGTON. O C. 20005 (202) 232-6600
j 30 I
o.
1
,1 out minds'as we propose this to you.
Other agencies 2j he a uwd the concept of collective doses, some other i
i i
3[
the criterion of measure of societal detriment 4
co'iective doses included in the recent international I
5 ll guidance, which I mentioned earlier, which addresses l
6 this subject of exemptions, that's IAEA Safety Guide 7
No. 89, which uses 100 person-rem.
S Furthermore, the use of the collective dose 9
cri'.crion provides added assurance that the public 30 L dow limits of 300 person-rem mrem will not be o
exceeded because of the exposures to --
11 It? "
C H ' I F !' U: CARR:
How does it do that?
I I'
!e 13 p cculdn't figure out a way to do that.
i s
14 MR. MORRIS:
For instance, if you took the n
1e,'
ce c.
of how rany people would be exposed to 10 mrem at 3F
-- 5f wc used the 500 person-rem criterion as opposed i
17 l
to no criterion.
If you use no criterion, the entire q
l 38 U.S.
population cou3d be exposed to a level of 10 mrem 19 for any given practice we might exempt.
20 l
If you use something like 500 person-re'm, or i
21 maybe somt other -- maybe larger number, you would be i
22 making a 35mitation of the number of people that would 23 g r.
- an cxposure near that level.
24 h In the case of 500 person --
U j
26 CHAIRMAN CARR:
How yould you limit?
Where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202i 23r.-433 WASHINGTON D C. 20005 (202) 232-6600
31 3
would you use that?
How do you --
h
.}
2 j-MR. MORRIS:
It would just be --
D 3 0 CHAIRMAN CARR:
You'd say, "Okay, you can't U
4 put 10 in that practice?"
5 l MR. MORRIS:
When you assess the collective 6
dose, you would determine whether or not you were 7
within or without the box on the figure.
And --
8 CHAIRMAN CARR:
But that's only for one 9
practice?
10 MR. MORRIS:
Yes.
11 CHAIRMAN CARR:
Now, how does that assure me u
4 3?
that I won't be exposed to more than one practice and 79 cot over that number?
I don't understand the added 1
U 34 assurance, u
15 ll MR. MORRIS:
The likelihood of being exposed n
16 l
to more than -- to be exposed to more than one i
37 practice in sufficient number of practices at or near 18 the 10 mrem level is certainly truncated or limited 19 by the collective dose figure.
As I said, 50,000 20 people would be the total number that would be exposed 21 for a given practice.
50,000 is a small fraction of 22 the total population of the country.
23 CHAIRMAN CARR:
So you wouldn't approve it 24 if more than 50,000 were going to get that see f
)
i 29 something that's a --
l NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
I (202) 234-4433 WASHINGTON. D C. 20005 (202) 232 6 l
._ j
32 f
MR. MORRIS:
But at least you're taking the 1
- l t
l 2
doing the cross benefit stry of looking at the 3 i:
rn'rulation to determine whether you could reduce that ll dose effectively somcwhat, to a somewhat lower value.
4 i;
E l CHAIRMAN CARR:
So do I know have to say, i
\\
6 i exnmine that same 50,000 people for the next practice i
7 to make sure?
F Mk. MORRIS:
One of the things we could 4
F 9 li not go that far, but we could --
l' CHAIRMAN CARR:
Really this doesn't make 10 11 sense tc ne that it adds assurance because the dose l
1?
Jim i is rea))y the assurance.
il MF. MORRIS:
I think it has to do --
i
+
i 34 l; CHAIRMAN CARR:
You ' re just mul tiplyir.
dose i
liH t times the number of people that might happen to 15 o L
16 L get exposed to it.
h 1:
1 *7 q
MR. MORRIS:
But by doing that, what we're i
JP doing is saying that the probability of being exposed t
l to multiple practice is somehow related and it isn't a 19 h
20 'j tight relationship, there's no formula that I can i
21 provide to you.
It's somehow related to the 22 co1] e ct i ve dose criterion and the maximum number of 23 people exposed.
I, 24 'i CHAIRMAN CARR:
It's that somehow I'm trying l
2' l
to get to the bottom of.
i d
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W
(?02) 234 4 33 WASHINGTON, D C 200C5
- 202) 232 4 600
~
33 c,
1 MR. MORRIS:
It is a qualitative judgment
?
ha:s ed on the likelihood of being exposed to multiple u
3q practices, add-on year, a number such as 10 mrem.
4h CHAIRMAN CARR:
Let's proceed.
You're not I
i 5;
going to solve my problem.
f MR. MORRIS:
And we had to make the point 7
earlier and in the paper that the collective dose 8
criterion does seem to us to be indicated because the 9
individual dose criterion in the policy is not claimed 10 tn be a de minimis or negligible risk level.
10 mrem 13 is a value chosen on the basis of resource utilization li 32 r a t h r> r tha!! a statement that it's a trivial dose to 23 j
tolerate.
And so that is an added feature, in our f
t i
34
- thinking, that would -- that has persuaded us to 35 propose to you the collective dose criterion.
u 16 h Let me ao on.
On page 11, we discuss a l
l 17 third major policy element, the issue of multiple 18 exposures, which we were just talking about a moment 39 ago, of course.
Referring back to the figure, yes, I 20
- agree, the like3ihood or the possibility of being l
21 exposed to multiple practices to the extent that you 22 could get a total c..mulative dose up near the dose l
l is certainly 23 limit at 100 mrem is somewhat l
dependent on what the maximum individual exposure is.
24 i
u 25 And in addition, we note that in the policy we state 1
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (232i 234 4 433 WASHINGTON, O C. 20005 (202) 232 6
34 1
that in defining practice we will be doing this in a f
?
broad
- sense, which will avoid what is called a
3 !!
fractionation of practice.
And this way the number of 4h potential' exemption decisions will be limited so we I
5 would not have a proliferation of practices of a 6i simdiar nature, but rather they would be lumped 7
together in an assessment under the policy.
It just l
Fh cuts down the number of practices.
1 9>I COMMISSIONER ROGERS:
Just in a practical a
10 way, how wou]d you do that, though, if a practice is li o exanined and just barely meets both your criteria of 72 tN i n nre:r and 500 person-rem?
And then a few years o
13 h Inter somebody else comes along and wants to do the e
1 p
34 h same thing.
What do you te13 them?
You can't do it 15 h because we're saturated?
o MR.
MORRIS:
Well, we're not setting any 16 17 l
hard criteria on how you would do that.
28 COMMISSIONER ROGERS:
How would you envision 19 l
dealing with that situation?
u 20 MR. MORRIS:
What we have said that we would 21 do in the policy is we had to continue.
Every time a 22 new submi ttal or a new proposal for exemption comes 23 in, wc need to look at this issue of whether we 24 i be33 eve there are similar practices which could i
?5 involve or impact on the same set of people in a way l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234-4433 WASHINGTON. D C. 20005 (202) 232-6600
9o j!
35 h"
1 th t they would be cur.:ulative doses built up.
And V
j 2L we'll have to do that on a case-by-case basis, as we 7
et,mine exemption proposals case-by-case.
4 lL When we have the opportunity to look at a 5
cluster of similar activities so that we can put them, I
6 you knew, consider them as a single practice, we would 7
take advantage of that.
In looking at waste streams 8
frw reactors, I believe,
.te're going to take a hard f
o l' i c. ' k at how that would be considered to be a single F
30 p '.i c t i c o or whether there would be potentia 1 S i i:
frnetionation of practice h
12 ti COMMISSIONER CARR:
- Well, I
read R
13 fr'-tienization as not permitting the guy to dilute X
q i.
14 U tL stream so he can meet the criteria.
15' MR. MORRIS:
Yes.
L 16 i:
MR. LAHS:
The other example, that would be 17 in waste streams -- for example, you could talk about JS dinposable dry active waste from a reactor as one 19 waste stream.
And then you could consider another 20 I
wa :, t e steam as being contaminated sand or, you know, i
2 "t you could come up with three or four waste streams l
22 l
from a power p3 ant in the submission.
The submission 23 l
we'll be getting, I believe, from NUMARC had to do
?4 I
with waste streams from power plants.
That's going to 2
25 b.- considered a single practice.
In other words, all NEAL R. GROSS COU1T REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4 433 WASHINGT ON. D C. m (202) 232 4 600
ls o
36 j
1 1 wn e + c strears, all waste coming out of power plants h
(
2 will be treated as a practice.
CHATRMAff CARR:
But it seems the objective 4'
in the whole thing is to find something that we don't i,
5 I
have to look at.
You're still having to look at 6
everything.
7 MR. LAHS:
Well, I guess that's correct.
If 8
you say that you have to look at it to determine, you 9
k vw, a f yce ' re poing to establish a level below which 10 h y r n ' r.c going te allow this material to go to a I
s.,Jtory 2andfill, certainly you have to look at it 33 l!
12 L b,~
c r m;gh tn dcfine what that level is.
It h
13 h CHAIRMAN CARE:
Yes, that's what I'm trying 1
p 14 0 te de 25 p MR.
BERNERO:
But that's exactly it.
If L
16 it's atomic energy --
17 CHAIRMAN CARR:
I only want to look at it l
t 18 oncc.
l 19 MR. BERNERO:
But if it's Atomic Energy Act, l
radioactivity, you have to look at it once.
Now, it 20 21 may be demonstrative 1y exemptible.
It may be in that 22 one look it's demonstrably well below 10 mrem per year 23 individua], 500 person-rem --
l CHAIRMAN CARR:
I'd want to generically then 24 4,
\\
2s say NEAL R. GROSS COURT REPORTERS AND Tr.ANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4 433 WASHINGTON. D C 20005 (202) 232M
ji~
ll 37 11 1
il 1
MR.
BERNERO:
And you say, yes, but you l
7 1 looked at it.
4
!l 3
CHAIRMAN CARR:
-- is it within that box, j
4 p fine.
SY MR. BERNERO:
But you looked at it, sir.
6 CHAIRMAN CARR:
I only looked at one case.
7 T didn't look at every case.
i 8 l MR. MORRI.c:
I think the way this would be l
implemented wo'21 d be that would happen would be in o
10 using these criteria the staff would, based on 11 proposals from the licensees or others, would go through ru3emaking and during the rulemaking they l
12 u
13 jj would establish detailed exemption criteria based on e
h 34 h these broad policy criteria that would be in the u
L j
pCliCf.
)E u
26 For instance, a set of volumetric or surface 17 i
contamination levels for different isotopes could be 38 estab3ished as the basis for decommissioning a 19 structure, a soil.
And having done that, that would 20 l
be done one time, those concentrations would be placed 23 in the regulations for a category of practices or a 22 practi ce, and would then allow the licensee to proceed 23 to clean up that site to the point that he reached 1
i 24 l
those 3cvels, And then all that would be left would t~
?"
I be the record keeping or the things he would have to NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE N W (232;234 4433 WASHINGTON, D C. 20005 (202) 232 4 600
I L
i 38 1-do to demonstrate that he had complied with that.
- I 1
2 So I believe your objective would be met by N
3 il the way we envision implementing the policy by 1
4 1 establishing those that's a second tier criterion.
I 5 !
It would be established based on the risk levels that I
6 wou3d come from the policy.
Those specific l
7 contamination levels would be determined as levels 8
whi ch would demonstrate that the risk objective of the l
9 ;
pol i cy statement had been met.
And that will be the h
D 20 w n;. you wou]d --
11 [
CHAIRMAN CARR:
Then I guess what I don't ii i,
12 l undt.rstand is why we need a two step process.
If we 33 ll can do that, why don't we just do it now?
/
H
(
o 14 [
MR. MORRIS:
Well, we could.
At one time 3r when we spoke to the Commission about this policy, one J
16 option that was available and still would be i
17 I
ava31ab]c, would be to do those rulemakings on a case-30 by-case basis.
What the policy would provide would be 39 T-consistency so that for,
- say, if we compared a 11 20 decommissioning rulemaking step to one involving 2 '1 t
distribution of recycled material or to one involving 22 low level waste streams, the same risk criterion or 23 the same how you determine the low regulatory concern 24 criteria of 10 mrem or 500 person collective dose
?;
would be app]ied to each of those exemption decisions.
NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS l
1323 RHODE ISLAND AVENUE. N W (202) 234-4433 WASHINGTON. D C 20005 (202) 232-6600
l 39
~
1 Il So this would be guidance that the staff would then 5..
?,j u s e-to go and develop the rulemaking decision.
h 3h It could be done without the intermediate 4
step of making the policy decision.
But I think the 5j policy decision would provide very useful guidance on 6
how both the proposers of these exemptions and the 7
staff would deal with this.
And it would lay out the
?
risk framework for how this could be done.
i 9
l CHAIRMAN CARR:
Okay.
Let's proceed.
20 0 MR.
MORRIS:
Okay.
Going on to page 12, 1"
we're not proposing a change in the individual dose q
o
[!
rriterio:, that was recommended earlier in the previous 3?
t, l'
H pniicy statement, which would be 10 mrem annual 4
j 14 i :id i vi d u a l dose.
There were,
- however, comments
.l
't 15 ll
'nverable to both higher and lower values, including H
36 p EPA's cor. ment that this value is too high as a generic I:l' 17 l criterion.
However, as we point out in the policy, 2?
based on two prospective, that is that most 1
19 individuals would not spend resources to avoid the 1
l 20 risk associated with this dose level and, furthermore, 21 it's comparability with variations in background 22 radiation, which were tolerated by most people without 23 concerr, we believe this value should be retained.
24 Simi3arly, the policy still provides, as I A
(
25 j
mentiened earlier, for the possibility of Commission t
]
NEAL R. GROSS
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- i CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4 433 WASHINGTON. D C 20005 (202) 232-6600
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1 40 1
consideration of exemptions and practices in which the numeric criteria are exceeded.
This policy is
^
1 g
li l
3j indicated on the figure in the cross hatched area as 4 l being possibly exemptible.
However, in clarifying f
5j this point in the revised policy, we've emphasized 6
that exemptions for such practices would be relatively 7
rare and we would look at them fairly carefully before 8
granting the-m, 9
The Commi ssion paper indicated that this is 10 il ctil] o point of some concern with EPA, the issue of i
2: ;
whether or not these criteria should be thought of as
!i 12 l i r i t c.
er whether we should allow exemptions in the L
f 13 range in the cross hatched area.
And we believe this t
ij 14 j!
has been somewhat alleviated by the clarification I n
35 q just mentioned.
16 I would point out also that the Advisory
[,
17 Committen on Nuclear Waste has suggested establishment 38 of variab]e what they call limits on individual and 19 co11cetive dose or any exemption.
In that case what 20 they would propose would be a kind of a sliding scale 21 in which the collective dose that would be in the 22 criterion would be variable with the individual dose.
23 But they would view that line that they would draw, 24 which would not be a simple square but a more complex f
1 25
- curve, as a
limiting line.
- However, we are NEAL R. GROSS COURT REPORTERS AND TRANSCR:BERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. O C PJXS (202) 232 4 600
l 43 recommending that flexibility be retained in the 1
o l!
l a
pcMicy
[
^
' i, l
3 ii Turning now to page 13, we indicate four l
l 4 ij areas where we felt some clarification woald be useful l
f 5i in better communicating the intent of the policy.
h l
6 i,l Scre comments which were opposed to the exemption i
7 policy believe the Commission was giving cart blanche i
8 l to the 3icensees to implement the exemption policy.
4
- McVever, many nuclear utility comments fully 90 u recognized that monitoring, record keeping on their l
11 h pm *, and perhaps inspections occasionally by the NP.C, l
o 12 wm ' 1 be necessary parts of the process of assuring V
13 lI thai radioactive raterial will be transferred from a y
(
14 cord ro31ed to an uncontrolled state in a proper way.
1" The policy now emphasized that there would "J 6 p be some kinds of conditions associated with exemption 17 l
decisions with which licensees would have to comply.
if J An example of that would be the surface contamination I
19 i
levels of the volumetric contamination levels that r
l would be examined as material went out of a site.
20 21 A second point is that the intent of the l
22 po3dey is to make it clear that the numerical criteria 23 for curtailing incremental class with ALARA are not 2t 15 v t s I've a3 ready discussed that.
I won't refer l
/
i 1
2E tc
't any further.
i f
NEAL R. GROSS 1
COURT REPORTERS AND TRANSCRIBE.RS 1323 RHODE ISLAND AVENUE. N W (202; 234.u.33 WASHINGTON. D C. 23%)5 (202) 232-6600 i
i
42 6
n 3 'l Third point is to empha si:::e the importance H
1,1, c e c:,
rer
- n defining what constitutes a
-n
'q p a-tice Fy de fining prectices broadly, the multiple 4 i F v r e.s u r o i c.
odorossed by reducing the
- r. umber of 5j pra."ict, for which exemptions would be considered.
I 6'
Arid fina]?y, as I mentioned earlier, we are 7
suggesting that the reference to the term below l
i 8
ro gui nt ory er+ corn be reserved for the possibilities i.
l,'
9 !!
c' vaste dirposals under the Low Level Radioactive 20 Wi. s t e P n0 i c-Arend cnts Act of 1985 and suggesting by l
J 2
11 th:t that applyinC that
- term, BRC, to a policy l
o t
i 1
1
- -n<'
fcr n 5: p c e t r un, of possible exemptions has 32 [O 3 3 Il caw r d s orr-confusion among commentors.
i h
14 01: pagr 14, I just want to point out --
- c.
I COMMISFIONEF ROBERTS:
Well, wait a ninute.
1 I
26 i Bach op.
ME. MORRIS:
Yes, sir.
1 *7 28 l COMMISSIONER ROBERTS:
I think you short 1
19 changed the last bullet.
20 l
MR. MORRIS:
Page 13.
1 1
23 COMMTSSIONEE ROBERTS:
How does that square 22 I'i reading fror the SECY paper, 88-69 of March 8,
23 page
?,
second paragraph.
Current NRC regulations 24 h i ne t;dr e s vern3 instances of implied or defacto FRC
^r it a9+5 up thc. are scidem refcrenced to as such.
NEAL R. GROSS COURT REPORT [R$ AND TRANSCRIBERS 7323 RHODE ISLAND AVENUE.N W.
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1 l
43 4:
1 l Then there's an enclosure which lists these implied or II
?O defacto ERC levels, which include things.other than d
3 vaste disposals under what you cite.
Now, is there--
c
]I; MR.
LAHS:
That's right.
At that time my 4
decision, which probably was wrong at the. time, we 6
t ried 'to use a ter:rino3cgy that was used in the Low 7 i Leve3 Radioactive Waste Policy Amendments Act, which i
8 l
was pointing toward waste disposal practice.
And 9
there they talk about waste streams that were below 30 [
regu3atory concern.
And so, in trying to carry that U
11 concept over into this exemption policy at that time i? O thr' that Corri s si on paper was writ an, we used that t
h l
0 13 [
tern We talked about exemptions from regulatory k.'
Ir
'i 4 h contro2 I think we said for practices whose health I !
4 15 and safety s 7nificance were below regulatory concern.
36 Looking back on that, that was a big mistake l
17 l
on my part, i
38 CHAIRMAN CARR:
I thought it was a good use.
i 39 l
MR. LAHS:
Is that right?
20 h COMMISSIONER ROBERTS:
I did, too.
l 1
21 MR.
LAHS:
The commentors we got many l
22 consent ors fe1+ this policy was only directed toward 23 waste disposals.
And it got very confusing in many why this policy was 24 l
people's mind that this 7
25 different than the Commission's '86 policy.
And so we l
l NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON.D.C 20005 (202)232 4 600
g*
.1 44
. s I
were always explaining to people, "No, this is broader l-p
?
.in centext and we're not just talking about the 0,
3 j po wibility cf waste stream as going to other than the 4
licensed sites, but the other exemption decision which 0
5 could be involved in radioactive material going from a f
6' contro33ed te an uncontro13ed status.
7 COMMISSIONER ROBERTS:
All right.
i S !.
MR. 1AHS:
So, yes, we've gone full circle U
II 9 i.l on that and it's --
!i 30 ME.
MORRIS:
This is really a matter of 31 h corrunications.
It's not a real health and safety h
I 3? [
s
.c.
.a herc It's just a
matter of better h
il communicating to the public is the reason for our t
74 [
recommendation..
[
Back to page 34, there's some other issues
- E 16 we want to just focus on for a moment.
There were
]
v 2 e v e, expressed by EPA and the Advisory Committee on 17 i
I P.
i Uuclear Waste and which we infer on the international l
19 I
3evel which are different from those that have been I
20 expressed by the staff regarding the magnitudes of the 11 exemption of those criteria.
The Commission should be 22 aware of those differences.
23 The EPA, at least in their comments, 24 documented a date, considers the value of 10 mrem too i
II i
?E high as an i ndi vidua3 dose criterion.
In the IAEA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON. D C 20005 (202) 232 4 600
L l
l 45
~.
L s
7
.e,afety Guide No. 89, this criterion is proposed as few 2
rren And, as T mentioned. before, the collective l
Ih dose criterion is proposed 100 person-rem.
Although I i:
i 4 il do recall that at the international workshop there was 5!
some support for higher values, specifically the 1
6 Canadian representative noted their values as higher.
l 1
I 7
We believe that in the absence of any 8 L technical basis for ?1 ternate values in the absence of i
il 9
either federal guidance or specific EPA exemption 20 0 criteria and their regulations, it's the Commission's
'1 foi making prerogative to select criteria such as n
12 L thorm we've recommended.
As was discussed earlier for l
L l
13 the ACNW, the individual and collective dose criteria 4
j 14 l
would follow a more complex relationship than that II 15 g
proposed by the staff.
I f, j
Furthermore, compounding this issue -- this i.
17 l
situation regarding the individual dose criteria, over h
18 thc years EPA has proposed or developed several i
19 standards which place numerical dose, and I'll use the 20 word now, limits on various e:Kposur e pathways or I
21 sources of radiati a.
These include low level waste, 22 drinking water standard, the fuel cycle standard, and 23 most recently EPA has proposed Cle.an Air Act national l
24 l
erissjon standards for hazardous air pollutants I
+.
p i
25 invelving regulation of radio neutrons.
These 1
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2W33 WASHINGTON. D C. 20005 (202) 232 6600
i
}
46 s
i 1
standards provide dose criteria, perhaps is a better 2,i
- word, in the range from four to 25 mrem per year, d
- i !j wh!ch are viewed by many as establishing a bright red d
I
{
4 d line boundary between acceptable and unacceptable dose 5l 1evels l
l 6
We believe in our thinking that a more 7
appropriate candidate for this hard boundary would be 8
the 300 mrem done limit for members of the public proposed in 10 CFR 20 which is shown on the figure o
,i 30 l herE The former view,
- however, leads to an U
11 h impression that the proposed exemption policy provides I'
I?
nn individua3 dose criterion for curtailing compliance j
13 I
with the ALARA process which is comparable to basic
(
14 j
radiation protection dose limits.
,I l'
n While this issue cannot be easily resolved h
l l
16 by policy decisions, we believe better mutual 17 l
understanding between the agencies could alleviate the i
38 situation, i
19 Furthermore.
I need to call to your i
20 attention the trend in risk coefficients which are 21 developed from exposures at higher doses.
The 22 Commission should know that the risk coefficient 23 developed for higher doses and dose rates have 24 recently been revised upward by the United Nations 25 Scientifie Committee on the Effects of Atomic NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 234-4433 WASHINGTON. D C 20005 (202) 232 6 i
e' 47 l-l l
Faniation.
A' similar conclusion is expected to be 4
l l
1 i
l 5
2 g reached by the t!ational Academy of Sciences Committee j
l t
n! 1 1
l l
3 j!
on the Biological Effects of Ionizing Radiation in 4
their forthcoming Five report.
This increase has been 5 ;
reregnized in the proposed policy.
There will be some i
1 l
l 6
reviewing the pc3 icy who would give significant weight 1
7 te these changing estimates of risk factors.
8 CHAIRMAf7 CARR:
But those are only at higher 9
doses?
30 MR. MORRIS:
What has happened is that they 11 p are raising their estimates of the risk at higher i
12 L dor but then there are those who would project 13 thcse down into the low dose range.
And those
'i 4 r r c. j e c t i on s are, admittedly, judgments by these Ie l '1 ex;'rts not demonstrated as yet by scientific data, 16 f
but they do represent some judgment by experts in this 17 field.
However, because the individual dose criterion I P.
I proposed in the policy is based on the perspective of 19 l
both variations in background as well as the I
20 I quantitative risk prospective evolving from the risk i
21 coefficient, the increase in risk coefficient has not 22 caused any changes in the policy.
23 Just a minute then to summarize on page 15.
I
- Z TLt proposa3 that we've provided to you would require d
1 25 pra-tirs justification as a basic policy element.
It NEAL R. GROSS CoVRT REPORTERS ANDTRANSCRIBERS 1323 RHoDE ISLAND AVENUE N W.
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48 i
i i
prev 4 des nurericci criteria on both individual and
.i 2
. c r.11 e c t i v e anu levcis as a basis for curtailing 1 q M.W.
It includes several features we believe are
{
1rperton:
to assure that exposure to multiple j
4 i
5 practices will not result in doses near the limit for i
i f
pt10 i c exposure Finally, it permits exemptions based I
i 7
or F enstration of ALARA e'en if the numerical l
l
?
rr;tcria arc not ret.
1 i
9 On pnpe 16 of the handout, we indicate that i
?O thv sta'f prnpoces that in view of the comments from e
l 11 0 ETA vhich 1,d s r 6 several concerns they had about the l!
32 ]
'1
- 7 of the policy and the need to further er-1 5
h 13 ci a t fy t b r-vieus of the two agencies, that the c
1 ro sol uti c-
' di'fevences that remain with EPA could 14
.i 15 Q Fr ct be arcon;lished through the process of h
P J6 }
devc:oprent of federal guidance by an interagency task i
17 force.
Thir, would be a way of following EPA's j
i 18 i
proposal in their forma] comment on this policy that 19 the two agencies should work together.
It would also 20 help to clarify some of those issues relating to the l
21 comparability of the EPA standards and the proposed i
22 exemption criteria that I was discussing a few minutes 23 age 24 And f 5 na17 '
on the 'last page, the staff i
25 believr' th,t b a s r: d
.;n the progress made to date in NEAL R. GROSS COURT REPORTERS AND 7 TRANSCRIBERS 1323 R'40DE ISLAND AViNI' NW (2 p 2 y.u,03 WASHINGTON, D C. 23005 (202) 232-6600 m _
l ji i
h, 49
$2 4
'l j
i resniving the issues related to policy development, it i
1 l
I 2
would be appropriate for the Commission to approve 3 !!
publication of the proposed policy and the response to 4 ;)
public comment in the Federal Register and the H
H l
5 ll continuation of staff efforts to work with EPA to plan J
i f.
for deve30prent of federal guidance.
)
i 1
l That concludes our presentation.
l 7
P CHAIRMAN CARR:
Any comments?
9 COMMISSIONER ROBERTS:
Not at this time.
10 h You and I can fix this thing.
[!
1'
'HAIRMAN CARR:
Mr. Rogers?
? p COMMISSIONER ROGERS:
Just picking up on l
1?
just what you just finished saying.
You're proposing
(
p
'4 thnt the po35cy be published again for comments.
Why?
1E b Ubat do you expect to happen with another publication o
V 36 of this po3 icy?
After all, we've done it what?
I? lj
- Twice, n
38 MR. MORRIS:
No, once.
i 19 COMMISSIONER ROGERS:
Once is all?
20 MR. MORRI3:
Only once.
21 COMMISSIONER ROGERS:
But we've had quite a 22 bit of comment.
23 MR. MORRIS:
We have had a number of pub 3ic l
i 24 corrents, and I believe that as this evolved and we've J
l 1
?R a had Setters from congressmen reflecting, you know, NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202i 234 4433 WASHINGTON. D C 20005 (202) 232 4 600
1 l
)
J i
50 i
i 1 I relaying the conce ns of their constituents and a i
f
- Y
?
number of others have been writing to us about this h
issue, we have noted in -- these have been signed and 3
a 4 4 sent out by the agency.
We've indicated that the i
5, public will get another chance to look at this.
I i
6 don't know that that. commitment would preclude issuing 7
it as a final policy statement now, but it seems that
?
a though 7 in my n, nd, I feel that there's not a i
9 lot that we on the staff could learn by those new o
I; IO ji commentR.
T believe it would gi ve a more thorough h
il 11 !l airing of this relatively complex and controversial b
12 'i i s sur-And it iright be worth the effort to go through t
13 l
that next step in the --
t 34 COMMISSIONER ROGERS:
- Well, I'm a little U
ic I!
concerned about the empty gestures.
If we really 16 don't think we're going to change it because we think i
1 37 we've pretty well exhausted ourselves and the 18 possibilities, then putting out for public comment is 19 really an empty gesture.
If you really don't think 20 anything is going to change as a result of that, what 21 is accomplished by it other than the frustration of 22 Laving to see the thing go out and then finally go 23 into final form without any change whatsoever after 24 the second issuance for public comment?
.s 25 So, it's not clear to me that this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 23W33 WASHINGTON D C. 20005 (202) 232 4600
i li 4
51 4
s 1
necessarily --
i h
CHAIRMAU CARR:
You wouldn't expect any new j!
2 i
l 3 li corments,.would you?
4 h MR. MORRIS:
What I would be hoping to see, e
i 5
I
- think, would be some indication that in our P
6 clarification and the way we've expressed the 7
resolution of some of these issues that a larger l
8 segment of those reviewing the policy would understand I
9 l
it better.
We could be more confident then that it 20 [
was going to bear the test of time.
"t i I CHAIRMAN CARR:
It might get a fewer I
1? I coit ten t n.
h n
13 H MR.
MORRIS:
And that last point I made n
la woM d be that it would give us some more confidence
- F that we had capture the best thinking of those out 16 !;
- there, look for any new ideas, perhaps, that could cc:te in.
Part of this is a communication effort.
An 17 i
18 cffort to outreach to those who are reading this to I
19 let them understand what the Commissioner's views are 20 and have, yes, the opportunity, perhaps -- we did not 22 prejudge whether you would have other questions that 22 you would want to raise in another round.
23 So, that was also --
l 24 CHAIRMAN CARR:
It does look like the facts i
25, aro a)) in What we're talking about now is policy.
+
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W (202) 234 4 433 WASH:NGTON, D C. 20005 (202) 232-661)
52 e
o 4
1 MR. MORRIS:
It's policy.
N.i 2
MR.
TAYLOR:
And the comments, there were i
o diverse comments and it tells people how those 3
h comments were handled and I think to the best of the t
5 staff's ability.
That's the benefit.
For a very 6
important po3dey.
7 DR.
SPEIS:
But at the same time, it has R
received intensive scrutiny over the last six months.
n 11 9
The advanced noti c-e, the international workshop, the h
public workshop.
It's more clarification, more 10 H,
".. I 6 di ges ti on, you know.
- l I? j COMMISSIONER ROGERS
Well, I don't think
!i 33 there's any rush on this.
I don't know that there's l
14 something that this has to be done by a certain date.
It's just really when do you come to closure on an S c.
l 16 issue and whether there is something to be gained b3 17 l
putting out again.
I 1E MR.
TAYLOR:
It's a judgment call and the i
i 39 staff thought it would be better to do this.
l 20 CHAIRMAN CARR:
It's on my hurry up list.
23 MR. TAYLOR:
Oh, I see.
Okay.
l 22 MR.
LAHS:
It would also give you the 23 chanet, if you wanted to, to allow EPA to modify its l
corrents, many of which I think --
24 2'
CHAIRMAN CARR:
I'k not sure I want to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
1323 RHODE ISLAND AVENUE. N W-R02) rM-4433 WASHINGTON.D.C 20005 (202) 232 6
g J.
53 j
l
-q l
1 I that.
U j.j 2 l MR. LAHS:
Many of which have been modified' l
l 3 li by dj CHAIRMAN CARE:
I may want.to get my policy 4
5[
on the street before EPA does-.
6 MR. BERNERO:
Mr. Chairman, if I could add a 7
comment on the priority or urgency for it.
I feel 8
corpe] 3 ed to say i t 's one of the most long awaited and I
9 hardy standards of all is how clean is clean enough.
i
- D j Ami this is an elementa3 part of that whole policy.
o 11 p t've been in this agency for 17 years and 1
h 22 I whc-I first entered it, it was just around the corner J
13 we'd have a standard.
And it just gets dragged out 4
l 34 j
om' gets dragged out.
IF 4 MR. TAYLOR:
It takes most of our attention.
!i 4
36 CHAIRMAN CARR:
But I'm not sure I can tell j
i 17 ther how clean is clean enough from this.
i l
38 MR. BERNERO:
Yes, this is a part of that.
19 CHAIRMAN CARR:
They won't know.
They'll 20 say, we12 we have to go and get at this issue.
21 MR. BERNERO:
When we decommission a site, 22 what we are doing every day when we approved remedial 23 actions for the removal or stabiliza n of 24 rad.onctivity, this is one part of the r e.,1 du a l i
2s activity.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUL N W (202) 234 4 433 WASHINGTON, D C. 20005 (202) 232 4 600
l' l
L.
i j
l 54 3
1 CHATPMAt! CAPE:
But what's clean enough for ll n s i t i. in thc middic of Nebraska might not be clean i
t i
l
- i enough fnt a sirr in the middle of the New York.
?
j NF.
EERNERO:
Certainly.
You just used a l
4 F4 5h crlir-etive dose to get that l
6 i CHATRMAN CARR:
And that's what you're 1
7 using.
And I think the two things ought to be the I
i i
F snm l
l 9 [
MP.
MORRIS:
I believe that we think that 10 g t) p-1i r3 would allow for consistent would 21 ?
prorett t%? thost two would be the same.
I think it h
I? i, u
' vel ve-r docision on your part that this would l
H h
13 bc r
policy app]icable to Nebraska and New York, 4
i 14 l arp'ienb e
t c.
consumer
- products, residual I
l 16 h radjntetivst3 jn the 3 ands instructors.
So that would 16 b e-
+he significance of your issuance of the policy, o
37 CHAIRMAf CARR:
But using your collective 18 oc%, it wcuidn't seem that we could do that.
39 ME. LAHS:
That just means we would have to 20 e v a l u a t. r a21 practices having to do with, let's say, 21 dc rann s ssioning f acilities as we --
22 CHAIRMAI! CARR:
Or we would have to evaluate 23 how rany kids are going to play in the park in New 24 Yo' k versu: how many were going to play in the park
\\
2' ove " ? ?.
19
'r i ddl e of Nebraska?
NEAL R. GROSS COUAT REPORTERS AND TRANSCR$ERS 7323 RHODE ISLAND AVENUE, N W (202) 2M 4432 WASHINGTON. D C 20005 (202) 232 4 600
55'
- ~.
i-L-
MR. LAHS:
That's right.
1 j
i p
., t
[;
2 p' MR. BERNERO:. Yes.
Yes, indeed.
-Just like 2l we do for a reactor site.
4 CHAIRMAN CARR:
Yes. 'And this is the number 5
' we 're looking: for.
6
' COMMISSIONER-ROGERS:
Well, just.touching on 7
t hi.a kind of thing.
There are the two dif f erent-l 8
. situations, the: low level waste streams and the l
i 9
consumer products applications of this.
Are you i
30 l totally so3d on-the notion that you don't want to have li-l separate levels for these two different types of jf.
-12 rractice?
Do you think that they really.should be 1
1
'13 coupled up together in one policy?
i 14 MR. MORRIS:
I ~ think it's the consensus.of 15 the staff that, yes, we had fully in mind that they 16 would be in this policy, yes.
17 MR. BERNERO:
It's the principle.
38 MR. MORRIS:
It's a risk policy principle 19 that we're following and I don't think people would be 20 concerned about whether the risk came from one 21 practice or another.
It's --
22 MR. BERNERO:
Yes, it's really a threshold 23 of concern and then the secondary concern of more than
?4 one practice piling on, you know, the multiple J
25 practice issue.
Now, the collective dose, it does NEAL R. GROSS COURT REPORTERS A' O TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2W33 WASHINGTON D.C 20;;D5 (202) 232-6600
56 4
- 9. -
i have a role, as it was said, in the consumer products D
i 2 'I because they're more generally distributed.
The l
q 3
muitiple practice issue is much simpler in the reactor 4 !
waste stream.
You know, do they all go to the sam.
5 landfill.
6 The principle of a risk basis for a
7 threshold of concern, regulatory concern, is --
8 COMMISSIONER ROGERS:
Well, it's just that 9
I ' t.
not sure we really have such a wonderful bases for SO !!
those numbers in these cases.
U 11 ij CHAIRMAN CARR:
It seems to me you're U
12 [
struggling against the threshold.
I'm for threshold,
!!o 13 4 bnt I can't find it here.
(
14 MP.
BERNERO:
Well, let me try it.
The h
15 [
pub 3ic dose-limit that our regulations, the new part t
36 j
20.
adopts 300 mrem per year as a level of clear 17 unacceptability.
Onc doesn't want an individual 18 exposed to that.
And what this exemption policy --
19 CHAIRMAN CARR:
Over background?
20 MR.
BERNERO:
Yes.
From artificial 21 radiation.
It happens to be less than or equal to 22 background.
AEA regulated radioactivity.
23 Now, 10 mrem per year is another threshold, 24 you cou]d ca23 it or a line, that below which with l
2" only one other test you can say it's clearly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234-4433 WASHINGTON.O C N (202) 232-6600
l,.
I l
57 t
s p
1 acceptable, exemptible.
A practice that produces less l
((..
2 than 10 mrem per year can be set aside from any 3 l further consideration with, of course, the proviso 4
that it's not close to that limit and with the l
5l sufficient number of people to have this population 6
dose in it.
To exceed the population dose.
7 CHAIRMAN CARR:
I was with you to a point.
l 8
MR. BERNERO:
Yes, I recognized you got off 9
the bus at the second half of the sentence.
1.
I-30 h CHAIRMAN CARR:
I can agree if it's 10 MR or h
11 h
- below, I'm not going to worry about it because I'm q
3?
i rea22y worried about the 300 MR number and the odds of 13 somebody having 10 of those 10 MR numbers doesn't 4
i l
14 worry me.
Uo 15 h MR.
BERNERO:
When we look at the reactor b
h" 16 waste stream that would go to, say, a landfill and 27 n.ight produce an off-site dose to a handful of people 18 who live near there down water from the landfill and 19 the imputed dose is 2 mrem per year, that is a far i
20 l different thing than if NMSS gets consumer product I
4 21 Iicensing of 2 mrem per year for everybody in the 22 United States from a new kind of smoke detector or 23 something like that.
That is a very large population 24
- dosc, a
25 I
COMMISSIONER ROGERS:
Yes, but aren't you l
NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234-4433 WASHINGTON, O C 20005 (202) 232-6000
58 s
1 just saying --
1'I 2 j CHAIRMAN CARR:
It doesn't worry me because n
(
3 j I*r only getting 2 millirems d
MR. BERNERO:
Yes, they're very different.
4 5
And this policy lets me distinguish between those two.
i-6 MR. TAYLOR.:
It's a decision making.
7 MR.
BERNERO:
It lets me distinguish that P
that few people exposed to that one landfill practice l
is clearly exemptible.
But that one that's 2 mrem per 9
10 l year et the 250 million people is something I'd better 31 y think about.
4 I? ?
CHAIRMAN CARR:
Well, I'm more worried about u
ti 33 l
the O mrem discharge going to the same landfill for a i
d 14 4 Inng period of time and concentrating at the landfill.
i' 15 h MR.
BERNERO:
Yes, indeed.
That's why it h
16 has to be looked at.
Or if we say that the practice i
17 l
is the reactor spent resins, the low level trash, the i
18 residue from the incinerator, etcetera, etcetera.
You l
t 19 know, maybe four different streams, each of which is 20 bumping the clearly acceptable limit, we license a l
21 l
licensed landfill, namely a low level burial ground, 22 on a
25 mrem per year limit to the critical 23 individual.
So, you know, we have to look at that.
COMMISSIONER ROGERS:
I think I'll pass.
24 j
EERNERO:
I'll pass out some gemstones NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4 433 WASHINGTON. O C. 20005 9 02) 232 6600
59 l
k here.
1 4
- i
- [
? '
COMMTSSTONSR CURTISS:
I just have one o
j qusstion on the EPA issue.
If the disagreement 3
u 4 g bet wecn the EPA and the Commission continues on both l\\
6j collective dose and the individual dose criteria, I 6
gwss the question I have is what's the consequence of 7
us establishing a BRC policy if the other agency here P
- wh5ch, according to the paper, has cited other 9
overl.appin0 authority as the basis for their standard 10 h se't*ing authority, if the other agency comes in and 11 says we disagree with that and we're going to regulate
- i l
'ower 3evel?
A12 in favor of a BRC policy, or 32 i
13 i
whatever we're calling it today.
And it seems to me e
I i;
,1 l
t h, t the simplicity approach that the Chairman's 14
- r.
outlined makes a good deal of sense.
It could not n
36 l
avo5d some of the complexity that we have here, but at I
i
'l 7 l
the same time if the upshot of it is that we i
18 deregu3 ate and end up turning that over to EPA for 19 l
regulation because they disagree, I'm not sure I'm l
I l
l 20 much in favor of that outcome either.
How do you l
21 recencile that disagreement?
22 MR. MORRIS:
Well, I think the first point 23 we'd make is that we believe that it's very important N
that we begin to work with EPA to develop federal
?"
guidance that would allow us to have a uniform top man NEAL R. GROSS CoVAT REPORTERS AND TRANSCRIBERS 13?3 RHODE ISLAND AVENUE, N W
' (202) 234-M33 WASHINGTON. D C 20005 (202) 2324 600
60 1
apprr,ch to this issue that not only EPA and NRC would f
n i
j 2q be i t,v ni ve d in, but DOE'and other government agencies.
i 11 And it's just one of those decisions we'll have to a
l' 32 lls Take.
But we've toyed with it long enough.
It's been 4
l 13 on and off the plate for 17 years, Mr. Bernero?
4 i
14 l
MR. BERNERO:
Oh, far longer than that.
I'm TE [
just a child.
i 36 CHAIRMAN CARR:
It probably hasn't been 17 around longer than 1936 or so.
i l
MR.
BERNERO:
The 190' policy statement 38 19 might give you a clue.
I 20 CHAIRMAN CARR:
So, we need to do that and 21 so I think it's up to us now to -- you've done your 22 homework.
You've done a good job in presenting the 23 issues and I think it's up to us to decide where we l
i 24 want te come down on it.
.c l
4 25 Any other comments?
l NEAL R. GROSS 4
COURT REPORTERS AND TRANSCRIBERS l
1323 RHODE ISLAND AVENUE, N W (202}234 4 3 WASHINGTON. O C 20005 (202) 232-6600 I
u____-
1 65 i
1 MR. PARLER:
Mr. Chairman, there's no legal i!
i 2 :l requirement that this policy statement be put out for L
j!
il comment again that I know of.
It's a policy call.
3 j\\
4 1 CHAIRMAN CARR:
Thank you.
"s l In that case, we stand adjourned.
l i
6 (Whereupon, at 2:48 p.m.
the public hearing 7
w,v, adjourned.)
P al' 9
i' 30 11 it 12 il;!
i 13 1
] t.
1 #s o
it li 3f j
1:
17 i
I I
') S 19 i
no I
21 22 23 24 i
2 c.
NEAL R. GROSS I
COURT REPORTERS ANDTRANSCRIBERd 1323 RHODE ISLAND AVENUE. N W (202 234 4 33 WASHINGTON. D C 20005 (7J2) 232M
s.
- o 4
.c
-ht CERTIFICATE OF TRANSCRIBER
.This is to certify that the' attached events of a meeting of.-the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING ON POLICY. STATEMENT.ON' RULES FOR EXEMPTION FROM REGULATORY CONTROL PLACE OF MEETING: ROCKVILLE, MARYLAND
' DATE OF MEETING:
JULY 11, 1989 were transcribed by me. I further certify that said transcription is accurate and complete,.to the'best-of my ability, and that the
transcript is a true and accurate record of the' foregoing events.
o 9 ~4_1thn{*
\\ 19AM L
- ~ ~
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Reporter's name:
Peter Lynch
\\.
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R NEAL R. GROSS
~
COURT Rf*0RTERS AND TRANSCRitfR$
1323 RHODE 15LAdo AVENUt, N.W.
(202) 234-4433 WASHINGTON, D.C.
20005 (202) 232-6600
PROPOSED POLICY STATEMENT ON EXEMPTIONS FROM REGULATORY CONTROL STAFF PRESENTATION TO COMMISSION JULY 11, 1989 i
s OUTLINE OF PRESENTATION
- BACKGROUND PURPOSE OF PRESENTATION
- OBJECTIVE OF POLICY STATEMENT ACTIONS TAKEN IN RESPONSE TO COMMENTS POLICY CLARIFICATIONS PROPOSAL ON MAJOR POLICY ELEMENTS
SUMMARY
-KEY POLICY ELEMENTS OTHER IMPORTANT POLICY CONSIDERATIONS
_______--_-___n
i 1
e BACKGROUND SRM-Nov 1987-IDENTIFY RISK LEVEL BELOW WHICH G0v'T REGULATION UNWARRANTED SECY 88-69, MAR 1988-CONCEPT DISCUSSION SRM-MAR 1988-REQUESTS POLICY STATEMENT SECY 88-257, SEPT 1988-PROPOSED POLICY COMMISSION AUTHORIZES PUBLICATION OF ADV. NOTICE SOLICITING COMMENTS ON SEVERAL MAJOR POLICY ELEMENTS 1
l A____-.m__._
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' PURPOSE 0F PRESENTATION
'TO DISCUSS REVISED POLICY. STATEMENT-AND THE-RATIONALE FOR STAFF PROPOSALS ON KEY POLICY ELEMENTS CONSIDERING INPUTS FROM:.
- THE INTERNATIONAL' WORKSHOP-0CT 1988
- PUBLIC;COMMEt.TS RECEIVED ON ADVANCE NOTICE. ISSUES (DEC 1988-APR 1989)
- PUBLIC MEETING-JAN 1989-w e
.-- _ _.-.-_-------_---.i_.--_.___ _ _ _ _ -. _ _ _ - -. _
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i OBJECTIVE OF POLICY STATEMENT TO ESTABLISH GUIDELINES AND CRITERIA FOR DEVELOPMENT OF REGULATIONS OR LICENSING DECIS!CNS WHICH COULD EXEMPT PRACTICES FROM SCME OR ALL REGULATORY CONTROLS
r.
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, POTENTIAL POLICY APPLICABILITY TYPICAL PRACTICES DISPOSAL OF VERY LOW LEVEL RADWASTE RELEASE OF LANDS AND STRUCTURES WITH RESIDUAL LEVELS OF RADIOACTIVITY CONSUMER PRODUCTS CONTAINING SMALL AMOUNTS OF RADIOACTIVE MATERIAL RECYCLE AND REUSE OF RESIDUALLY CONTAMINATED MATERIALS AND EQUIPMENT
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ls ACTIONS TAKEN AS A RESULT OF COMMENTS ON ADVANCE NOTICE OF POLICY DEVELOPMENT
' CATEGORIZED'AND RESOLVED ISSUES IN 18 SUBJECT AREAS REVISED POLICY IN LEY /TEAC.
CLARIFIED COMMISSION POSITIONS IN OTHER AREAS 1
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- POLICY ELEMENTS ON WHICH COMMENTS SOUGHT HOW SHOULD FUNDAMENTAL PRINCIPLES OF RADIATION PROTECTION BE APPLIED?
(JUSTIFICATION OF PRACTICE,' DOSE.
LIMITS, AND ALARA)
- IS A COLLECTIVE DOSE CRITERION NEEDED?
- HOW SHOULD CUMULATIVE EFFECTS.FROM MULTIPLE PRACTICES BE DEALT WITH?
7 m__-___1_____._________
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- L PROPOSALS ON MAJOR POLICY' ELEMENTS
" JUSTIFICATION OF PRACTICE NEEDED (1) NO EXPOSURE T0 IONIZING RADIATION PERMITTED W/0 COMMENSURATE BENEFIT (2) WIDELY-ACCEPTED RADIATION PROTECTION GOAL l
(
PROPOSALS ON MAJOR POLICY ELEMENTS { CON'T'i COLLECTIVE DOSE CRITERION ADDED TO DEFINE " FLOOR" TO THE ALARA PROCESS (1) COMMONLY USED BY REGUIATORY BODIES AS EASURE OF SOCIETAL DETRDENT IN OPTIMIZATION ASSESSENTS (2) USED BY OTHER U.S. AGENCIES & INCLUDED IN INTERNATIONAL GUIDANCE (3) ADDS ASSURANCE THAT DOSE LIMITS NOT EXCEEDED (EXPOSURES TO MULTIPLE PRACTICES?
(4) REFLECTS POSITION THAT INDIVIDUAL DOSE CRITERION NOT "DE MINIMIS"
. _ - -, - - - - - _ - - _ - ~ _ - - - - - - -. - - - _ _ _ - - -. - -
PROPOSALS ON MAJOR POLICY ELEM'TS (CONT.)
- MULTIPLE PRACTICE ISSUE ADDRESSED BY:
(1) BROAD DEFINITION OF " PRACTICES" (2) REQUIRING PRACTICE JUSTIFICATION (3) COLLECTIVE DOSE CRITERION (4) APPROPRIATE PERIODIC ASSESSMENT (5) COMMITMENT TO CONSIDER ISSUE IN EACH EXEMPTION DECISION l
1 1
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OTHER MAJOR POLICY ISSUES
- - RETENTION OF 10 MREM ANNUAL INDIVIDUAL DOSE CRITERION ALLOWS EXEMPTIONS WHET. ABOVE NUMERICAL CRITERIA e 9 e
__,__-___________m___
e i.-
l-POLICY CLARIFICATIONS CONSTRAINTS ARE ASSOCIATED WITH EXEMPTION DECISIONS NUMERICAL ALARA CRITERIA ARE NOT LIMITS EMPHASIS INCREASED ON NECESSITY TO DEFINE SCOPE OF PRACTICE APPROPRIATELY REFERENCE TO "BRC" RESERVED FOR WASTE DISPOSALS UNDER LLRWPAA 0F 1985 e
3-OTHER IMPORTANT POLICY CONSIDERATIONS DIFFERING VIEWS ON MAGNITUDES OF EXEMPTION DOSE CRITERIA
- EPA, ACNW, AND INTERNATIONAL COMPARABILITY OF EXEMPTION DOSE CRITERIA AND " ACCEPTABLE" DOSE STDS, TREND IN RISK COEFFICIENTS DEVELOPED FROM EXPOSURES AT HIGHER DOSES
b;* :, m; ' n,,..
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SUMMARY
- KEY POLICY ELEMENTS REcVIRES PRACTICE JUSTIFICATION AS.
BASIC.FDLICY ELEMENT 7
PROVIDES CKtTERIA FOR " CURTAILING"
!ALARA "0PTIMAL" RESOURCE USE-INCLUDES FEATURES TO ADDREE.S THE
" EXPOSURE,TO MULTIPLE PRACTICE" ISSUE-PERMITS EXEMPTIONS BASED ON DEMONSTRATION OF-ALARA IF~ NUMERICAL CRITERIA NOT MET 4
1________=._____
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INTERACTIONS WITH EPA ~
ST/,FF. PROPOSES THAT RESOLUTION OF ANY RESIDUAL.' DIFFERENCES WITH EPA CAN BEST'BE ACCOMPLISHED THROUGH THE PROCESS OF DEVELOPMENT OF FEDERAL GUIDANCE BY AN INTERAGENCY TASK FORCE.
4 i
26 L_...
--_-_. - _ _._-...-_-__.-----.-__-_._._..__.=_-___.- -- _-..---._-_--- _.--_ - _..-._.-.. -.-_ _ - _ - _- _ _. _ _ _____ _.- _ _ _
.. r;f RECOMMENDATIONS
- THAT THE COMMISSION APPROVE:
(1) PUBLICATION OF THE PROPOSED POLICY AND RESPONSE TO PUBLIC COMMENTS'IN THE FEDERAL REGISTER.
(2) CONTlfiUING STAFF EFFORTS TO WORK WITH EPA TO PLAN FOR DEVELOPMENT OF FEDERAL GUIDANCE.
I
- _ - - - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _