ML20011E003

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Carr Response to JB Breaux/Ak Simpson ,Question 1b Re Adequacy of Regulations,Per Beir V Rept
ML20011E003
Person / Time
Issue date: 01/11/1990
From: Carr K
NRC COMMISSION (OCM)
To: Breaux J
SENATE, ENVIRONMENT & PUBLIC WORKS
Shared Package
ML20011E001 List:
References
BREAUX-900111, CCS, NUDOCS 9002050195
Download: ML20011E003 (2)


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4 0VESTION 1(b).

Does the NRC still believe that there is no' public health j

and safety need for additional regulation under the Clean 1

Air Act?

= ANSWER.:

Yes. Under the Atomic Energy Act, the NRC has an establithed and comprehensive program to regulate emissions of radionuclides to air and water from all facilities licensed by the Commission and Agreement States. The result of this comprehensive regulatory scheme has been to keep public exposure to radiation at levels far below the regulatory limit.

Information in the BEIR V report does not change the health and' safety basis for eliminating dual regulation of

-f acilities subject to NRC or ' Agreement State licensing. By EPA's own calcula-

- tions, the. total number of potential health effects attributable to air i

emissions of radionuclides from all NRC licensees combined is less than 0.33 fatalities ~per year. EPA's calculations were based upon a risk coefficient of 4 x 10~4 per rem, which is generally consistent with that presented in the BEIR V report.

For this reason, as EPA itself has acknowledged, duplicative EPA regulation in the face of NRC's regulatory program is "hard to defend from any L

logical or policy perspective." Indeed, as EPA indicated in prior comments on this issue, " existing emissions from these sources are already so low that the public health is already protected with an ample margin of safety..."

U 50 Federal Register 5190, 5191 (February 6,1985).

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l QUESTION 1(b).

(Continued),L.

This view, based on a risk estimate consistent with the BEIR V report, was.

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reflect.ed in EPA and NRC recommendations to Congress to eliminate dual regula-tion of radionuclides under the Clean Air Act (letter from Chairman Carr to

. Senator Burdick, dated November 14,1989).

Based on NRC's review of BEIR V to date, we continue to believe that there is no public. health and safety need for dual regulation under the Clean Air Act of radionuclide emissions from facilities licensed by NRC and Agreement States.

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