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MEMORANDUM FOR: Donald A. Nussbaumer, Assistant Director for State Agreement Programs State, local and Indian Tribe Programs Office of Governmental And Public Affairs FROM: Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research
SUBJECT:
RE0 VEST FROM STATE OF NEW YORK FOR NRC INTERPRETATION REGARDING USE OF EFFECTIVE DOSE E0VIVALENT IN DETERMINING COMPLIANCE WITH PART 61 Enclosed are RES comments regarding the questions raised by the New York State Department of Environmental Conservation and transmitted to me via your October 1, 1987 memorandum. The suggested responses were developed by Mr. Harold Peterson of my staff. Please note that has been provided copies of the incoming and our response, and I suggest that you solicit his coment prior to draf ting a reply to New York State.
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Bill M. Morris, Director ,
Division of Regulatory Applications '
Office of Nuclear Regulatory Research
Enclosure:
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...4 Enclosure RES Input to State of New York Inquiry The dose limits in NRC's 10 CFR Part 61 are intended to track the values in most of EPA's generally-applicable environmental radiation standards.
These standards are based upon the ICRP 2 critical organ concept rather than the newer ICRP-26/30 concepts. Until the revised Part 20 is effective and conforming changes are made to other affected parts, the use of "effective dose equivalent" would not be consistent with NRC regulations. Moreover, EPA may not amend its standards until it sets forth guidance on dose limits for the general public.
- 1. Is it correct to assume that the doses to the whole body and to each organ in rems shoulo be determined using ICRP 30 and that the dosos should be used to determine compliance with Part 617 Yes, it is correct to evaluate the dose to the whole body and to individual organs separately. The revised metabolic and dosimetric parameters in ICRP 30 could be used for this evaluation, although the older methodology in ICRP 2 would also be acceptable. [ Note: see question 2 regarding the use of effective dose.]
- 2. Is it cor' rect to assume that the concept of effective dose equivaler.t does not apply to 61.41 of Part 61? Is the proper interpretatien to address the risk of exposure to each individual organ rather than summarizing the total risk?
As part 61 addresses only individual organ doses, and does not consider use of the ef fective dose equivalent concept, it would be ,
appropriate to consider individual organ risk rather than a weighted l "whole-body effectve" risk. l
- 3. Would the State be considered "non. compatible" if an effective whole body 4
dose ecuivalent of 25 mrem per year were to be usea in place of the doses to individual organs and the whole body dose given in Part 61?
As Part 61 is considered a matter of compatibility under the !
HRC-State Agreement, at the present tire the use of the "effective i dose equivalent" would be considered to be nonccmpatible with the !
present version of Part 61 which does not recognize the "effective dose equivalent" concept.
NRC has proposed a revision of Part 20 which incorporates the "effective dose equivalent" but has not proposed a Part 61 revision until we incorpcrate the EPA's Part 193. As the Part 61 dose limits track previous EPA standards, if EPA were to adopt ICRP 30 methodology in their proposed Part 193 without modifying the others, an obvious inconsistency would be introduced.
Hopefully, within the next five years all applicable radia, tion standards will be revised to confom to the ICRP "effective dose" concept and consistency will again be restored.
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-y'fi 5 5 New York State Department of Environmental Conservation h
50 Wolf Road, Albany, New York 12233-w Thomas C. Jorling Commossooner l
February 1, 1988 Interested Parties: I On December 31, 1987, the Department of Environmental Conservation adopted its final regulations for certification of sites and disposal methods for low-level radioactive waste disposal, 6 NYCRR Part 382. Enclosed for your information is a I copy of the regulations, the final environmental impact statement I (FEIS) for the regulations, and an executive summary of the FEIS. 1 As you can see, the FEIS is in two volumes. Volume I is a revised edition of the volume issued as the draft environmental ;
impact statement. In Volume II, all the comments received by the Department on the 4 raft regulations and draft environmental impact statement are reproduced, and the Department's responses to those comments are presented.
1 Thank you for your inte' rest in these regulations. If you l have any questions, please do not hesitate to contact Barbara i Youngberg of the Bureau of Radiation at 518-457-5915. l Very truly yours, ;
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Paul J. Merges, Ph.D.
Chief, Bureau of Radiation fo /A - Ef /35 A/M ,
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