ML20202G057
| ML20202G057 | |
| Person / Time | |
|---|---|
| Issue date: | 02/15/1978 |
| From: | Pederson K NRC |
| To: | Bradford, Gilinsky, Hendrie, Kennedy, The Chairman NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9902040263 | |
| Download: ML20202G057 (4) | |
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j 84 UNITED STATES i *'
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NUCLEAR REGULATORY COMMisslON wassimoToN, D. C. 20555 1 February 15, 1978 y
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MEMORANDUM FOR: Chairman Hendrie Comissioner Gilinsky g % g ,y g g i Comissioner Kennedy gwg b quy og Commissionen Bfadf rd gg 3gjg AGc/Al/lC !
FROM: KenPeder$enA
SUBJECT:
D0LLAR PER-MAN-REM RULEMAKING (SECY-78-63)
I believe i.1e Comission should approve the staff recommendation to cancel formally the proposed dollar-per-man-rem ($/M-R) rulemaking.
However, I also believe the Comission should not abandon entirely the use of the $/M-R concept. Rather, the Comission should encourage the staff to use the concept,as appropriate, to supplement other methodologies for decision-making. In particular, the Commission should ask the staff to examine its use in helping to achieve ALARA for occupation exposure and in making policy judgments on the proper disposition of mill tailings.
Discussion Almost three years ago, the Comission decided that dollar-per-man-rem value was the " missing link" in the NRC rulemaking on Appendix I of 10 CFR Part 50 (ALARA for reactor effluents). It selected the upper limit of the range of values that had been suggested as a conservative value for imediate use while a more refined (probably lower) value was to be determined through a follow-on rulemaking -- which has never been undertaken.
Meanwhile, the NRR staff has found, in implementing Appendix I, that meeting the individual dose limits has always led to lower e# fluent limits than the $/M-R' analysis- would require. Putting it differently, the individual dose limits are more restrictive on effluents than could be justified on the basis of cost-benefit analysis, i.e., the industry.is probably spending more on radioactive waste treatment systems than the concomitant reduction in population exposure would be worth on the basis of the $1000 per-man-rem value. I Meanwhile, EPA has promulgated its 40 CFR Part 190 rule for generally applicable environmental standards for thefuel cycle. EPA considers
'that 10 CFR Part 50, Appendix I satisfactorily implements 40 CFR Part 90 for sites having three reactors or less. With four or more reactors, EPA's limits would be more restrictive than Appendix I.
(It should be noted that EPA generally stood firm on its numbers,
, despite NRC's arguments that the numbers were not justified on a cost-benefitbasis.) With regard to fuel cycle facilities, the y L
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To the Comissior. staff has been developing, through a series of ORNL technical stuJies, additional information on the costs and effectiteness of waste treat-ment facilities that was to provide a basis for a decision on- ALARA limits. The staff maintains now'that, given NRC's experience in implementing Appendix I and given the EPA limits, there is no need for a further rulemaking to settle on a $/M-R value.
I-agree that the Commission should dispense with the proposed rule-
_ making _to refine the value. I believe, however, that the concept
! should be retained in Appendix I to be used by the staff on an '
optional basis. In this regard, I would stron.aly oppose any proposal to eliminate altogether the S/M-R concept from NRC rules and practice
'as it is a useful and practical concept in determining how far we should go in imposing additional requirements to control population exposure. The existence of regulatory limits on individual doses does not replace the utility of the S/M-R concept. The concept can l provide values (e.g., $1000/M-R) to serve as one measure (not-necessarily the sole measure) against which we can judge the reasonable-ness of our requirements to protect public health and safety, i.e.,
to assure that everything worth doing will be done, no more and no less. My concern here is that without such a concept as one of many '
! regulatory tools, we would indeed have a " missing link," as the
- l. first Commission described it. EPA's lack of interest in the $/M-R L concept,'as reflected in its unwillingness to take the lead in a rulemaking on it, should not be taken as substantive reason for NRC dropping its use. The concept provides a' middle ground between those
, who would impose requirements without regard to cost and those who
! believe our standards are.already excessive. Depending on which group carries the day on a particular case,'we are subject to two types of '
errors if we ignore the concept: l
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-- placing no value on the benefit of risk reduction.
placing n_o value on the cost of achieving the risk reduction.
In my view, either outcome is undesirable and should be avoided.
The $/M-R concept is one way to strike a balance. l Applications of the Concept But given the state of the world, it is fair to ask, "Are there any 4
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real situations where the use of the concept could give us some-practical insights?" I believe there are several such real situations.
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- 1. Occupational Dose - While we are currently implementing a general i'
progre..:.0 a:n10.e ALAG exposure, Inc apprcacnes we use are l
-qualitative in natJre. Hard decisions in individual Cases may require a r;are quantitative, approach. Two examples would be:
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. Reduction of occupational dose limits (such as proposed in the NRDC petition). -
. ' Control of exposure' to transient workers, especially those ;
involved in specialized maintenance and repair of major j reactor systems, e.g.. steam generators.
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- 2. Uranium Mill Tsilings - The problems of mill tailings, which has been with us for more than two decades, is essentially to determine '
how close the radon release rate in the final _ disposition of tailings must approach that from the original ore body. It's basically a' question of money, and to determine how much should be spent will depend on how much we value the avoidance of future population exposure. In turn, the latter depends on resolving the policy question of how we define the period over i which we will account for the population dose -- the life of the i mill, the life of the reactor, or.should we calculate the population dose in a way that fully accounts for the 80,000-year half-life of the thorium precursor of radon? Using some monetary value' for relating dose reduction to the effort to reduce dose will aid in deciding the approach we should take in the final disposition of mill tailings.
In its 40 CFR Part 190 regulation,' EPA has specifically exempted radon from consideration. EPA expects that the NRC uranium milling GEIS will provide a-basis for further consideration of radon limits. Thus, the present EPA fuel cycle standards are-not responsive to the mill tailings issue raised by Pohl and Jordan. ' In this connection, I believe the dollar-per-man-rem concept would be a particularly useful additional tool in evaluating the alternatives presented in the mill tailings GEIS. !
Conclusion
'I recommend, iherefore, that you' cancel the dollar-per-man-rem rule- ,
making, but that you reaffirm the potential utility of using the dollar- !
per-man-rem concept as a supplement to other regulatory limits in making ALARA determinations. l I
cc: JeJome Nelson ;
Sam Chilk l
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Memorandum for the Record SECY-78 Dollar Per Man-Rem Rulemaking The Conunission, by a vote of 4-0, directed the staff to prepare and
. circulate to the Commissioners for concurrence, an Order suspending the Dollar Per Man-Rem Rulemaking. The Commission directed that this Order point out the factors involved in this decision, and that this Order will in no way eliminate Append 4x I. (SD) (SECY Suspense: March 1, 1978) i Staff Req - POL. Sess'78-9 2/16/78 l
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