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Requirements Memoranda (SRM) > 2006 > SECY-06-0168
August 23, 2006
MEMORANDUM TO: |
Luis A. Reyes
Executive Director for Operations |
FROM: |
Annette L. Vietti-Cook, Secretary /RA/ |
SUBJECT: |
STAFF REQUIREMENTS - SECY-06-0168 - STAFF COMMENTS ON
THE DRAFT RECOMMENDATIONS OF THE INTERNATIONAL
COMMISSION ON RADIOLOGICAL PROTECTION |
The Commission has approved the staff's proposed comments on the draft 2006
recommendations of the International Commission on Radiological Protection (ICRP), subject to
the comments provided below. The staff should take a lead role in discussing these comments
at the NEA/ICRP Forum later this month.
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The Commission endorses radiological protection recommendations that can enable
tangible improvements in providing for adequate protection of public health and safety,
and that can be implemented by practitioners and regulatory authorities in a practical,
timely, and cost effective manner. Therefore, the Commission supports the Advisory
Committee on Nuclear Waste's assessment that "this ICRP document does not add
value to the radiation protection programs in the United States, especially those
promulgated by the Commission for its licensees and for licensees in Agreement
States", and the staff's assessment that since there has not been any significant change
in radiation risks, there is no compelling public health and safety argument to make any
changes to the recommendations, or to national regulations that implement those
recommendations.
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The Commission specifically notes (as previously documented in the SRM on SECY-04-0223) that it is not necessary to develop a framework for radiological protection of non-human species, and Section 10 of the draft recommendations should be removed. The
staff should continue to express the Commission's opposition to developing standards
for protection of flora and fauna to the ICRP and IAEA in the appropriate forums.
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The Commission strongly supports the staff's view that ICRP should not propose any
numerical values that could be used as the basis for terminating a pregnancy and agree
that such discussion (paragraph 263) should be removed from the ICRP
recommendations document. This issue should be emphasized in a standalone general
comment, as follows: "The NRC believes that discussions regarding the termination of
pregnancy are beyond the scope of the ICRP's mission. Such discussions should be
held on case-by-case bases between competent medical practitioners and their patients,
and it is therefore inappropriate for the ICRP to propose any numerical value that could
be the basis for terminating a pregnancy."
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The Commission believes that the ICRP should be encouraged to provide stronger
statements to further discourage misuse of the collective dose concept and to provide
recommendations on the limited appropriate uses of collective dose. The ICRP needs to
provide clear guidance with numerous examples of when it is appropriate to use
collective dose and, more importantly, when it is not appropriate to use collective dose.
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The staff should continue to support the open process that ICRP is using to gather
feedback from the many groups interested in the development of these
recommendations. Coincident with the upcoming NEA/ICRP Forum, the staff should
urge domestic stakeholders, particularly States, industry and professional organizations,
and public interest groups to submit their comments on the recommendations directly to
the ICRP.
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The Commission supports the Advisory Committee on Nuclear Waste's (ACNW) view
that ICRP should not adopt a new set of tissue weighting factors and nominal risk
coefficients until the assessment of the atomic-bomb data is completed and published.
Additionally, the staff should continue to challenge ICRP to 1) clearly describe the
technical basis for its decisions and to incorporate peer-reviewed scientific information
that reflects the current state of knowledge and 2) delay finalizing the draft 2006
recommendations until the ICRP stated objectives have been fulfilled.
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The staff should continue to monitor the DOE Low Dose Radiation Research, and the
ICRP and other ongoing radiation protection activities to understand the boundaries of
our scientific knowledge of low dose radiation effects.
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The staff should address the following specific comments before providing them to
ICRP:
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Comments 60 and 61 provide an adequate discussion of a specific problem(s),
but they do not provide the corrections the staff desires to be made to the report.
The staff needs to be clear what they want done to address the issue.
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Comment 76 clearly indicates what the staff wants accomplished in the report but
provides no justification for the action. Some type of brief justification should be
provided.
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For Comment 78, the first two sentences are clear but the third sentence needs
some type of lead in phrase to connect it to the idea in the first two sentences.
Otherwise the third sentence is an apparent abrupt change in thought. A
possible revision of the third sentence is "As an example, U.S. materials ...".
cc: |
Chairman Klein
Commissioner McGaffigan
Commissioner Merrifield
Commissioner Jaczko
Commissioner Lyons
OGC
CFO
OCA
OPA
Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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