ML20207F120

Provides Comments on Proposed Commission Policy Statement on Regulatory Control Exemptions for Practices Whose Public Health & Safety Impacts Below Regulatory Concern.Proposed Policy Fails to Address Questions Raised by Commission

ML20207F120
Person / Time
Issue date:	08/09/1988
From:	Moeller D NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:	Zech L NRC COMMISSION (OCM)
References
NACNUCLE-R-0004, NACNUCLE-R-4, NUDOCS 8808180221
Download: ML20207F120 (2)

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August 9,1988 The Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

ACNW COMMENTS ON PROPOSED COMMISSION POLICY STATEMENT ON REGULATORY CONTROL EXEMPTIONS FOR PRACTICES WHOSE PUBLIC HEALTH AND SAFETY IMPACTS ARE BELOW REGULATORY CONCERN (BRC)

During the second meeting of the Advisory Comittee on Nuclear Waste, July 21-22,1988, we met with the NRC staff to discuss the referenced draft report.

This meeting represented a continuation of earlier df scussions on this subject by the Waste Management Subcomittee of the Advisory Comittee on Reactor Safeguards. As a result of these reviews, we offer the following additional coments, which were affirmed on August 4, 1988 during the third meeting of the ACNW.

We believe that the proposed Policy Statement is not presented in a logical manner, and it fails to address certain questions raised by you and your fellow Comissioners.

We believe that the Policy Statement should be revised to include the following coments and suggestions:

Exemptions should be based on an acceptable individual p/ year 1.

nnual, as as lifetime, risk.

The values proposed (10" and wel}/ lifetime) 10~

appear reasonable.

Once this guidance has been presented and justified, comprable annual and lifetime dose limits should be given.

At this level of risk, we believe that the limitation on individual risk will be sufficient; we see no need to provide a limit on the collective population dose.

2.

We agree with the NRC staff that, in all cases, each proposed exemption should be justified.

In this regard, applications involving radiation exposures to members of the public which have no offsetting benefits should not be approved.

However, con-siderable care should be exercised in describing practices that would be termed as frivolous.

3.

In those cases where an apparently useful application of radiation would result in individual risks slightly greater than the licits cited above, a cost-benefit analysis should be made to determine if the application should be designated as BRC.

Prior to undertaking cuch efforts, however, we believe that the methodology for conduct-ing such analyses should be carefully reexamined.

Specific items needing attention include the monetary value assigned per unit of 8808280221 880809 PDR ADVCM NACNUCLE R-0005 PNU J

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The Honorable Lando W. Zech, Jr. August 9,1988 collective dose averted.

In this regard, we suggest the develop-rnent of a system in which higher monetary values are used as the annual risk increases above the level considered to be BPC.

4.

Finally, the Policy Statement should require that, as a part of its implementation, all existing NRC exemptions be reviewed to ensure that they are comensurate with this approach.

If these coments and suggestions are incorporated, the revised Policy Statement should be satisfactory for presentation at the upcoming International Workshop on Rules for Exemption from Regulatory Control.

Sincerely, r

Dade W. Moeller Chairman

Reference:

U. 5. Nuclear Regulatory Comission, draft Comission paper (Pre-decisional) for The Commissioners from Victor Stello, Jr., EDO,

Subject:

Proposed Comission Policy Statement on Regulatory Control Exemptions for Practices Whose Public Health and Safety Impacts are Below Regula-tory Concern (BRC), transmitted by memorandum from B. M. Morris, Director, Division of Regulatory Applications RES, to R. F. Fraley, Executive Director, ACNW, dated July 14, 1988.

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