ML20028H158
| ML20028H158 | |
| Person / Time | |
|---|---|
| Issue date: | 10/17/1990 |
| From: | Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Vander Jagt G HOUSE OF REP. |
| Shared Package | |
| ML20028H159 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9011140051 | |
| Download: ML20028H158 (2) | |
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a October 17, 1990 The Honorable Guy Vander Jagt United States House of Representatives Washington, D. C.
20515
Dear Congressman Vancer Jagt:
.I am responding to your October 1,1990, letter in which.you asked us to address the concerns of your constituent, Jan Doran who expressed disagree-ment with a Nuclear Regulatory Commission (NRC1 poIIcy which establishes t
guidelines for the NRC staff in reviewing requests for exemptions for certain law level radioactive waste-(LLW) as being below regulatory concern or BRC.
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On July 3, 1990, thi Commission issued a-Below Regulatory Concern Policy
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Statement.
I have enclosed a copy of this statement together with a companion explanatory booklet for vour use in responding to your constituent.- The statement identifies the principles-and criteria that will govern Commission decisions to exempt certain radioactive material from the-full scope of regulatory controls.
Thus, the policy could apply, but would not be limited to potential BRC waste determinations.
I'would emphasize that the policy is not self executing and does'not, by itself, deregulate any LLW. Any specific exemption decisions would be accomplished through rulemaking or licensing actions during which opportunity-for public comment would be provided in those situations where generic exemption provisions have not k
already been established,
-The policy can be considered'an outgrowth.of the concepts articulated in 99-240).- That. Act (i.e., Section 10)y Amendments Act of 1985-(Pub..L.
the low-level-Radioactive Waste Polic directed the!NRC to "... establish standards and procedures...and davelop the' technical capability-for considering and acting upon petitions to exempt specific radioactive waste.
streams from regulation...due to-the presence of radionuclides in such waste streams 11n sufficiently low-concentrations or quantities as to be 1
below regulatory concern."
In response to the legislation, NRC' developed and published in 1986 a Statement of Policy and procedures which outlines a
the criteria for considering such petitions. -Our recently issued broad-policystatement,whichhas'implicationsbeyondwastedisposals(e.g.,
. applicable to' decommissioning decisions involving:the release of residua 11y-contaminated lands or structures), reflects much of the basicL radiationLprotection approach descr msd in tais earlier Commission policy. The Commission, in both actions, has acted in the belief that the
-nation's best interests are. served by policies that establish a consistent-k pubuoygsAA?
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risk framework within which exempt lon decisions can he made with assurance that human health and the environment are protected, in this regard, we believe our actions are consistent with those of other Federal agencies; e.g., the Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA),whohaveformulatedorareattemptingtoformulate similar policies for the hazardous materials they regulate, it may be helpful to summarize the typical exposures which we all routinely receive from a variety of sources of radiation. The exposures 4
occur from radiation that is natural in origin as well as from sources which involve man-made uses of radioactive material.
In total, as estimated by the National Council on Radiation Protection and Measurements (NCRP Repor; No. 93), the ef fective dose equivalent received by an average individual in the United $tates population is about 360 millirem per year. Of this total, over 83 percent (about 300 millfrem per year) is a result of natural sources, including r6doh and its Cecay products, while medical exposures such as x-rays, when averaged nyer the U.S. population, contributaonestimated15 percent (53miilirempertear). Other man made sources, including nuclear fallout, contribute the remaining 1 to 2 percent of the total exposure. The remaining 1 to / percent also includes the contribution from nuclear power plant effluent >. Any low-level radioactive material associated with an exemption decision would not be expected to. change this typical exposure " picture."
In fact, the level of radioactivity for some potential BRC wastes may be such a small fraction of natural background radiation that it may not be readily detectable and, therefore, could not cause measurable' increases in radiati3n levels currently associated with drinking water supplies, in closing, I want to assure you that we take our mandate to protect the health and safety of the r,ublic-very seriously.
1.-therefore, hope the views-expressed and the enclosed information will prove useful in responsibly expanding the dialogue on this controversial and technically T
complex issue.
Sincerely,
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l Dennis K. Rathbun, Director L
Congressional Affairs Office-of Governmental and Pubik Affairs
Enclosures:
As Stated l
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