Re[2]: linear hypothesis - NRC's BRC proposal and resolutio

["ALDEN N TSCHAECHE" <XAT@inel.gov>]

So there we are with no BRC and nothing in 10CFR20. Maybe we should
petition the NRC to put BRC back into 10CFR20?

*** Reply to note of 10/16/95 11:55
To: RADSAFE --INELMAIL RADSAFE

Subject: Re[2]: linear hypothesis - NRC's BRC proposal and resolutio
     As Wes stated, the NRC did propose a BRC rule. Below are some excerpts
     from the Final published 10CFR20 rule:


     (1) Establishment of "Below Regulatory Concern (BRC)" levels (related
     to de minimis levels and a negligible level of risk).  On June 27,
     1990, the Commission announced the issuance of a policy statement on
     Below Regulatory Concern, which was subsequently published in
     the Federal Register on July 3, 1990 (55 FR 27522). This policy
     statement establishes the framework for the Commission to formulate
     rules and licensing decisions to exempt certain practices involving
     small quantities of radioactive materials from some or all regulatory
     controls.  The BRC policy statement sets forth criteria for protection
     of both individuals (individual dose criteria) and population groups
     (a collective dose criterion).
     ----------------------------------------------------------------------

     Response:  The Commission agrees that "Below Regulatory Concern" (BRC)
     levels would be useful and has issued a policy statement on
     the application of the concept of BRC with regard to waste disposal
     ("Radioactive Waste Below Regulatory Concern," 51 FR 30839,
     August 29, 1986) and a general policy statement on BRC (55 FR 27522,
     July 3, 1990).  The general policy statement establishes the
     framework for the Commission to formulate rules and licensing
     decisions to exempt certain practices involving small quantities of
     radioactive materials from some or all regulatory controls.  The BRC
     policy statement sets forth criteria for protection of both
     individuals (individual dose criteria) and population groups (a
     collective dose criterion).

        In order to ensure that any computational changes reflect the
     policy that evolves from the effort to develop generic BRC policy,
     the Commission removed the threshold for truncating collective doses
     (Proposed  20.304) from Part 20 and has included such a
     threshold in the generic BRC policy statement.  This deletion is also
     consistent with comments that noted that this section described a
     method for calculating a quantity (collective dose) that was not
     required to be calculated by Part 20 and comments that such details of
     calculations would be better in a regulatory guide rather than in a
     regulation.



     Sandy Perle
     Supervisor Health Physics
     Florida Power and Light Company
     Nuclear Division

     (407) 694-4219 Office
     (407) 694-3706 Fax

     sandy_perle@email.fpl.com


______________________________ Reply Separator ________________________________
_
Subject: Re: linear hypothesis
Author:  radsafe@romulus.ehs.uiuc.edu at Internet-Mail
Date:    10/16/95 12:48 PM



Excuse me, but the NRC DID propose a BRC.  It got shot down.  The
public and the Congress would not except the proposal, so it was
withdrawn.  So the argument that you can't convince the regulator is
incorrect in this instance.  Now, whether the NRC bungled its PR may
be debateable, but don't discredit their attempt.

(Yes, it's true.  This may be a first for me to defend the NRC)

Wes

> Date:          Mon, 16 Oct 95 11:29:27 -0500
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          "ALDEN N TSCHAECHE" <XAT@inel.gov>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: linear hypothesis

>
> If Marv Goldman is correct, namely: the mitigation of tiny doses is not
> cost effective, why couldn't the NRC establish a BRC? I submit that,
> until the linear hypothesis is discredited and tossed in the trash, we
> will never be able to convince a regulator that tiny doses should not be
> avoided, no matter what the cost.


*********************************************************************
Wesley M. Dunn, C.H.P., Administrator      512-834-6688
Licensing Branch                           512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
*********************************************************************