[ RadSafe ] NRC Recommendation

[Miller, Mark L]

Unintended consequences, or something to live with?

> May 2, 2005 * NRC Staff Recommends Solid Materials Not Be Cleared for
> Unrestricted Use
> The Nuclear Regulatory Commission (NRC) staff has forwarded its
> recommendations to the Commissioners on proposed rulemaking on
> controlling the disposition of solid materials that have no, or very
> small amounts of, radioactivity. In what is often referred to as the
> "Clearance Rule," the staff actually recommends against clearing
> materials for unrestricted use with no further regulatory controls.
> Rather, the staff recommendations are that materials that meet the
> recommended radiological criteria may be released from licensed
> control if sent to (a) disposal in Environmental Protection Agency
> (EPA)/state-regulated landfills, (b) reuse in a predefined set of uses
> (specifically concrete in road bed construction and reuse of tools and
> equipment), or (c) other disposition paths, if supported by a
> case-specific analysis and approval of proposed procedures. The
> recommended radiological criterion is a dose of 1 millirem per year
> (mrem/y) [0.01 milliSievert per year]. The NRC would establish tables
> of volumetric and surface concentration levels associated with this
> dose criterion. The recommendation also calls for a record-keeping
> system to provide reasonable assurance that disposition of the solid
> material has been conducted in accordance with the rule. 
> 
> The NRC staff recommendation is in disagreement with the Health
> Physics Society position statement
> <http://hps.org/documents/materials.pdf>  that materials meeting a 1
> mrem/y dose criterion be removed from any further control of any kind
> as described in ANSI/HPS 13.12 "Surface and Volume Radioactivity
> Standards for Clearance
> <http://hps.org/membersonly/committees/standards/n13.12-1999.pdf> ." 
> 
> The NRC staff recommendations are contained in SECY Letter 2005-0054.
> The complete SECY package, which includes the forwarding letter, a
> draft Federal Register Notice (FRN) of rulemaking, a proposed Draft
> Generic Environmental Impact Statement, Draft Regulatory Analysis, and
> Letters from Cooperating Agencies and Agreement States, is available
> on the NRC Web site
> <http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2005/>
> (NOTE: The file is relatively large [7 MB] so it may take awhile to
> open depending on your connection speed). A copy of just the
> forwarding letter and draft FRN is available by clicking here
> <http://hps.org/membersonly/documents/Secy05-0054Extract.pdf>  [807
> KB].
>