ML19341B025
| ML19341B025 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Panetta L HOUSE OF REP. |
| References | |
| FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70 NUDOCS 8101300061 | |
| Download: ML19341B025 (2) | |
Text
~
.~
L._.
7 PDR o
UNITED STATES
',h
[
NUCLEAR REGULATORY COMMISSION
- (
- i 1 y wAssiscTON, D. C. 20555 o
a sgv j JAN 9 1981 w,
The Honorable Leon E. Panetta I
Z United States House of Representatives Washington, D.C.
20515
Dear Congressman Panetta:
This is in response to your letter of December 12, 1980 in which you expressed the concerns of your constituents regarding the NRC's proposed rule which would exempt certain smelted alloys which contain residual radioactive contamination from licensing requirements of the Commission. The October 27, 1980 Federal Register Notice requested comments by December 11 but noted that comments received after that date will be considered if it is practical to do so.
Coments and questions received will be addressed in the Final Environmental Impact Statement and considered by the Comission before promulgation of a final rule, I will address your constitutents' concerns in the same order as they were preser.ted in your letter.
1.
We agree that every effort should be made to " prevent unnecessary exposure to low-level radiation." The question becomes a risk / benefit analysis to determine the net benefit of the exposure, if any. The general consideration is that an action must produce a positive net benefit and exposures kept as low as reasonably achievable taking into account both social and economic factors.
In the case in question this is why the NRC did an extensive environmental assessment to determine the risks involved. A copy of this report was sent to you with Mr. Kamerer's letter. The conclusion of this study was that the risk was essentially negligible, i.e. a risk of 0.003 incremental cancers l
in the total population. The benefit, of course, would be a savings of about $42 million to the government (Department of Energy,) whyh is, in effect, to the taxpayer.
~
2.
The NRC evaluation in this case did not include the cumulative effect of this action since the effect was found to be so small in terms of low dose rates, low individual doses, low collective dose and low risk of causing any cancers at all.
l l
3.
It would not be possible to inform consumers of the products made from the smelted alloys. While total quantities and types of smelted alloys and the Tc-99 and low enriched uranium concentrations involved are reported to the NRC by the original licensee, reporting of the end use of any particular quantity is not required. Considering the negligible l
effect of the use of this material such reporting would provide no useful I
benefit for the effort required to maintain the distribution records that l
would be necessary to track these materials through qyriads of uses.
l 8101800@
4
~
y.
p-g Q
The Hcnorable 1. con E. Panetta -
4.
At noted ir. 'am 3, only the original quantities distributed are reported.
No records are required that would permit recall. Again the effort recuired for such records could not be justified.
It is unlikely that future evidence will indicate a health threat since the evaluations made in the assessment were not based on the assumption that there is zcro effect from low-level radiation but rather were calculated by accumulating the minimal risk i
effects of these minute quantities using highly conservative assumptions as set forth in the report.
5.
As stated in item 4, tFe effect was calculated by accumulating the risk effects of the minute radiation levels in various products. The result
~ 'tias a risk of 0.003 health effects in the total population.
In this case the " health effect" is considered in terms of incremental cancers that
..may result fron whole-body exposure on the assumption that the general public is exposed to the entire inventory of smelted alloys or derivative product for one year.
I hope this adequately responds to your constituents' concerns.
If you or your constituents would like further inforration, please let me know.
L Sincerely,
.?
c,-.s3 ylilliam 1.DIMM y
Willian J. Dircks
~.-
Exca:tive Director for Operations
,._.p h
1-.,,,
1 l
l l
l t
e e
{
/
s
..