ML20029B993
| ML20029B993 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Lautenberg F SENATE |
| Shared Package | |
| ML20029B990 | List: |
| References | |
| FOIA-90-415, FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9103220145 | |
| Download: ML20029B993 (3) | |
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April 19,1990 The Honorable Frank R. Lautenberg United States Senate i
Washington, DC 20510
Dear Senator Lautenberg:
I am responding to year latters of March 28 and 30,1990, which requested our
- consideration of issue; raised by your constituents, Ms. Mary Vincenti and Mr. pet.tr Cohen. Their concerns involve the disposal of low-level radioactive wastes and, in particular, those wastes characterized as "below regulatory concern" or "BRC."
I would first note that the Nuclear Regulat>ry Commission (NRC) has not published an waste (LLW) y proposed regulations which would allow disposal of Icw-level under the BRC provisions of the low-level Radioactive Waste Policy hendments Act of 1985 (Pub. L.99-240).
However, the Act directed the NRC to
- ... establish standards and procedures... and develop the technical capabil'ty for considering and acting upon petitions to exempt specific
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radioactive waste streams from regulation... due to the presence of radionuclides in such waste streams in su'ficiently low concentrations or quantities as to be below regulatory concern."
In response to the legislation, NRC developed and published in 1986, a Statement of Policy and Procedures which outlines the criteria for considering such petitions.
I have enclosed a copy of the tatement which you may find useful in responding to your constituents (Enclosure 1). We are aware that the nation's nuclear power utilities are preparing t,uch a petition but, to date, this petition has not been submitted to us.
Besides this 1986 policy, the Commission continues to be active in pursuing the development of a broad policy that would identify the principles and criteria that govern Commission decisions which could exempt radioactive material from some or all regulatory controls. This broad policy, the subject of the enclosed advance notice (Enclosure 2), would apply not only to BRC waste disposals but also to other decisions which would allow licensed radioactive material to be released to the environment or to the general public. Thus, the policy would airo provide the basis for deconmissioning decisions involving the release of L
lands, structures, or recycled materials for unrestricted use as well as decisions re' eding consumer product exemptions. We believe the nation's best t
interests wt be served by a policy that establishes a consistent risk framework within whic' nption decisions can be made with assurance that human health j'sT and the env.m..ent are protected.
Such a policy would also contribute to the focusing of our limited national resources on those risks with greatest potential
-l impact on public health and safety, g
n' In further addressing your constituents' concerns regarding potential bRC waste disposals I would point out that any LLW considered to be "below regulatory
\\ concern"u,ndertheprovisionsofPub.L.99-240wouloonlyinvolvematernis l
kith the lowest levels of radioactivity content.
In fact, the level of 4
radioactivity for some potential BRC wastes may be such a small fraction of
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s The Honorable Frank R. Lautenberg 2
natural background radiation that it may not be readily detectable.
I would also point out thac the dose-effect hypothesis, to which the Comission prudently subscribes, does not presume that there are safe doses of radiation.
- Instead, the relationship between risk and dose is derived from cautious extrapolations of the most recent data available from studies of the Japanese atomit bomb survivors and other individuals who have recieved large doses of radietion.
As a result, the policies discussed previously are entirely consistent in their presumed risk-dose relationship with the conclusions of the report cited by Mr. Cohen, " Health Effects of Exposure to Low-Levels of lonizing Radiation,'
authored by the Comi', tee on the Biological Effects of lonizing Radiation (i.e., the BEIR Y re', ort).
It may be also helpful to sumarize the typical exposures which we all routinely receive from a variety of sources of radiation. These exposures 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 Report No. 93), the affective dose equivalent received by c average individual in the United States Of this total, over 83 percent p(opulation is about 360 millirem per year.about 300 millirem per year) is a result of natural sou and its decay products, while medical exposures such as x-rays, when averaged uver the U. S. population, contribute an estimated 15 percent (53 millirem per i
year). Other man-made sources, including nuclear f allout, contribute the i
remaining 1 to 2 percent of t5 s total exposure. The remaining 1 to 2 percent also includes the contribution from nuclear power plant effluents.
I am presenting this total exposure
- picture" to provide a perspective on the hypothetical risks which may be associated with >otential BRC waste disposal practicas. This perspective is o.. of several t1at the Comission believes are relevant to its decisions involving regulatory resource allocations to control the potential radiological risks associated with the use of radioactive materials.
in closing, I want to assure you that we take our mandate to protect the health and safety of the public very seriously. As a result, the concerns expressed by your constituents are among those that we must carefully consider and address as we carry out our regulatory mission, fn$lkinedBys 4
James M. Taylor James M. Taylor Executive Director for Operations
Enclosures:
1.FinalPolicy-(51FR30839)
- 2. Federal _ Register (53 FR 49886)
See next page for Distribution
'See previous concurrences.
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