ML20127A848
| ML20127A848 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1983 |
| From: | Fraley R Advisory Committee on Reactor Safeguards |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20127A006 | List: |
| References | |
| FOIA-85-3 NUDOCS 8308190515 | |
| Download: ML20127A848 (4) | |
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UNITED ST ATES
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,7, 1 NUCLEAR REGULATORY COMMISSION
- $ ADVISORY COMMITTEE ON RE ACTOR SAFEGUARDS
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August 11, 1983 MEMORA:O'JM FOR: William J. Dir
.gxec*iveDirectorforOperations FROM: R. F. Fral , txecutive Di ctor, ACRS
SUBJECT:
ACRS SUBCOMMITTEE REPORT ON TRANSPORTATION REGULATIONS On July 18, 1933, the ACRS Subcommittee on Reactor Radiological Ef fects cet with the NRC Staff to discuss the radiological aspects of the transpor-tation regulations,10 CFP Part 71, and how they relate to other parts of NRC regulations, particularly 10 CFR Part 20.
Based on these discussions, the Subcommittee has prepared comments on the above. During its 280th ACRS meeting on August 4-6, 1983, the ACRS was briefed on these comments and approved forwarding them to the NRC Staff.
A copy is attached for your information.
Attachment:
" Review of Transportation Regulations," by ACRS Subcommittee on Reactor Radiological Ef fects - 7/18/83.
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Review of Transportation Regulations ACRS Subcommittee on Reactor Radiological Ef fects July 18,1983 At a meeting on July 18, 1983, members of the ACRS Subcommittee on Reactor Radiological Ef fects were briefed by the NRC Staff on those aspects of the prep: sed revisions in the Federal regulations pertaining to the trar.sporta-tion of radioactive materials that relate to personnel exposures. Specific items discussed were NRC Regulations (10 CFR Part 71) and 00T Regulations (49 CFR Parts 171-178). Although the primary reason for the proposed revi-sions is to make the regulations compatible with the 1973 IAEA transporta-tion standards, the Subcommittee members made a number of observations that gave them cause for concern. These include:
- 1. There is apparent confusion and ambiguity in the interpretation of current NRC regulations relative to dose limits for the public (10 CFR 20.105). Although Subconmittee members thought that everyone agreed on a limit of 500 mren/y for the maximally exposed individual menbers of the public, NRC Staff members indicated that current regulations could be interpreted to permit doses an order of magnitude higher than this. This is a natter that should be immediately addressed and resolved. We urge that the NRC regula-tions be made consistent with the guidance previously provided by the federal Radiation Council .
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- 2. The Subcommittee learned that few data exist relative to the number of people involved in radioactive material transporta-tion activities, the number and types of vehicles involved, t't nv*.ber of trips being made and the nur.ber of packages being handled, the percentage of the loadings that fall within various fractions of the dose limits, and the collective doses inv ol ved. There is also a need to estimate growth rates for the radioactive materials shipping industry 50 that projections can be nade of future regulatory needs in this area. We recommend that studies be initiated to gather such data.
- 3. Unless employed by an NRC licensee, freight-forwarders and drivers of vehicles transporting radioactive' materials are currently not subject to NRC regulations. Recent surveys and analyses by NRC contractors and others suggest that such people can incur doses substantially in excess of the establir .. (Federal Radiation Council) limits for individual members of the public and perhaps even in excess of the established limits for radiation workers.
' The Subcommittee recommends that the NRC request DOT to implement as soon as possible that portion of the proposed IAEA regulations that would assure that such people are classified as radiation ,
workers and appropriately monitored.
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- 4. The Subcommittee noted that the subject regulations could allow radiation exposures to members of the public and to the drivers of trucks transporting spent fuel and solid waste that are sub-stantially greater than stated in Table S-4 of 10 CFR 51.20(g).
Apparently the old supporting document for this Table has been updated by a NUREG report now ready for publication. It is important that the values in Table 5-4 be revised, as appropriate, to reflect wr.at is perr.itted by the revisions to 10 CFR 71 and that new evaluations be made of the potential consequences.
- 5. In addition, the Subcommittee was concerned about the extremely slow schedule on which current plans call for these problems to he addressed (e.g., implementation of the final rule in 1987).
The current situation, if not promptly corrected, could have the potential of resulting in unnecessarily high doses to transporta-tion workers and could reflect poorly on the Commission. We urge
.that work be promptly initiated to gather the recommended data and that the NRC Staff work with 00T to develop a program for resolving these deficiencies. Such a program should include the develo7nent of an adequate plan to enforce the requirements -
ultimately developed.
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