[ RadSafe ] ALARA, BRC ,& regulatoty self-interest
wlipton at sbcglobal.net
Tue Jun 24 21:40:29 CDT 2008
Another de facto BRC is in 10 CFR 20, Subpart E, "Radiological Criteria For License Termination," which allows the release of a licensed facility for unrestricted use, "if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that from groundwater sources of drinking water, and that the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA)."
It's not about dose, it's about trust.
Perception is reality.
----- Original Message ----
From: "BLHamrick at aol.com" <BLHamrick at aol.com>
To: pdemopoulos at af.umaryland.edu; jjcohen at prodigy.net; sperle at mirion.com; radsafe at radlab.nl
Sent: Tuesday, June 24, 2008 9:22:08 PM
Subject: Re: [ RadSafe ] ALARA, BRC ,& regulatoty self-interest
BRC died a political death. The anti-nuclear activists opposed to BRC did
not understand (or intentionally ignored) the fact that BRC was already a
reality (and had been for the 30 - 40 years of regulation) through "case-by-case"
determinations to exempt certain things from regulatory control. In fact,
BRC actually continues to exist as it always had through guidance.
The NUREG 1556 series for radioactive materials licensees provides
"unrestricted area contamination limits" (based on the old Regulatory Guide 1.86), and
allows these limits to be applied to the release of equipment and other
items from restricted areas. Most licensees across the U.S. (except NPPs) have
these limits incorporated in their license via a reference in their license
application to the NUREG or other comparable guidance. The sad part is these
limits weren't incorporated into regulation..
NRC issued BRC as a policy. The squeaky wheels objected (certainly not the
majority of the public), and Congress listened, and instructed NRC to retract
the policy, as written, but not the practice.
In recent years, NRC tried again to codify the de minimus limits used by
virtually everyone (except the NPPs), when they went forward with the proposed
"Control of Solid Materials" rulemaking. Again, the squeaky wheels had their
way, and NRC staff ended up recommending a completely unworkable,
radiation-phobic approach to the problem, which the Commission in its wisdom shut down,
by stating that other matters had precedence at this time, and they weren't
going to pursue this rulemaking.
EPA also approached this problem in their "Low Activity" rulemaking effort,
which also received bad reviews from the anti-nuclear contingency, and EPA
promptly stated they too had other more pressing priorities.
Both NRC and EPA were informed as they headed toward these rulemaking
efforts that in order to succeed, they needed to 1) stand together and proceed on
conjoined paths, and 2) introduce the rulemakings by making it quite clear
that low activity materials were released all the time, and had been for the 50
years of regulatory control, 3) by stating, quite clearly, that the retraction
of the formal BRC policy did nothing to change the ongoing release practices
authorized on a "case-by-case" basis, and 4) it would be more efficient and
provide better regulatory control and consistency to codify these
"case-by-case" criteria than to leave them in guidance space. But, the agencies didn't
do that, and they ended up with exactly the mess that was quite predictable
from the outset.
Barbara L. Hamrick
In a message dated 6/24/2008 3:43:37 P.M. Pacific Daylight Time,
pdemopoulos at af.umaryland.edu writes:
I was at a BRC public meeting conducted in Philadelphia, and it seems
the reason why the BRC concept was
dropped was because of the public opposition to it. The opposition came
in with dolls and
said something to the effect that the NRC wanted to kill the babies.
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