ML20029C399
| ML20029C399 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1990 |
| From: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | NRC |
| Shared Package | |
| ML16252A423 | List: |
| References | |
| FOIA-90-415, FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9103270351 | |
| Download: ML20029C399 (14) | |
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otrN ELLYN 4LLIN04 60181 June 22, 1990 i
MEMORANDUM FOR:
BRC Steering Group FROM:
Carl J. Paperiello, Deputy Regional Administrator
SUBJECT:
PRESENTATION BEFORE THE MIDWEST INTERSTATE LOW-LEVEL RADI0 ACTIVE WASTE COMMISSION i
On June 20, 1990, I made a presentation on below regulatory concern before a meeting of the Midwest Interstate low-level Radioactive Waste Comission in
( Ann Arbor, Michigan. : Attached to this memorandum is a copy of-my presentation.
It reflects comments received from George Pangburn and Kathleen Black. Also attached is a copy of 4 memorandum from the Executive Director of that
. Commission summarizing the status of Below Regulatory Concern.=
LThe major concern of the Comission with respect to BRC appears to be a reduction in the anticipated volume of waste proh eted to be shipped to a 4
regional facility. This will cause the cost per cubic foot to rise since the overall cost-of running the facility varies very little with the volume.of waste received. -In my presentation 1-noted that volume reduction was a fact of life and even without BRC the volume of waste was going to be reduced. The Commissioner for Missouri noted that this was ying.to place a burden on-research licensees who did not have either the. sophistication or-the equipment to reduce volume the way utilities reduce volume. He wanted to know what the NRC staff was going to do about this.
I stated that there was little the NRC could:do when licensees for financial reasons made decisions to reduce volume.
I asked what their recommendations were. They could offer notie.
The-Comissioner for the State of Michigan then stated that the whole Waste Policy -
Act was wrong and that the NRC ought to go to Congress and lobby for its change,
~
Two' states have banr.ed the disposal 'of. low-level waste even if BRC in any-facility other than a. licensed site. :Their -legislation-is-attached.
There were a-number of citi: ens group representatives at the meeting.
it is L
clear from discussions with them that these individuals refuse to acce>t any i
level of. exposure to radiation. ~It is.also clear from speaking with taem that they cannot distinguish clearly between-ionizing radiation or non-ionizing radiation and that their technical knowledge was not very high.
I spent about 45 minutes af ter the meeting talking to them about radiation
-exposure;in general as well as BRC. They basically felt that they hadla right,to make a decision on what they were going to allow themselves to be' exposed to and that the Government had an obligation'to inform them if their t
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9103270351 910320 PDR FOIA BECKER90-415 PDR
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BRC Steering Group June 22, 1990 food was irradiated, there was radioactive material at any level in consunier products and if radioactive material was going into a landfill regardless if it were BRC.
h J.A.U
'arl J. Pap /.riello Deputy Regional Administrator Attachments:
As stated cc:
A. B. Davis, Rlli C. Norelius, Rlll W. Axelson, Rlli
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_BRC STEERING GROUP MEMBERS Hugh L. Thompson, Jr., DEDS 17 G-21 Robert M. Bernero, NMSS 6 A-4 Frank Congel, NRR/DREP 10 E-4 Richard E. Cunningham, NMSS/IMNS 6 H-3 Joseph J. Fouchard, PA 2 G-5 Martin G. Maisch, OGC 15 B-18 Bill M. Morris, RES/DRA NLS-007 Dennis K. Rathbun, GPA/CA 17 A-3
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li3RERT_I FIEMTAUl01-LEYIL_M D19MTlYIJ MIA39MIMI.9N 1% QEKTAT19H fRU19 Good Afternoon.
I am Carl Paperiello.
I am the Deputy Regional Administrator for the NRC Region 3 office, located in the Chicago suburbs.
I am pleased to speak to you today on the Nuc1 car Regulatory Commission's Below Regulatory Concern policy.
Currently this policy is under active review by the Commission and the staf f.
A final policy statement will likely be issued shortly.
Since the version under review by the Commission is still predecisional, I have to rostrict my remarks to the version already published but conceptually it is the same.
I would also direct your attention to the memo written by Mr. Gregg Larsen dated June 8,1990 on Below-Reguletory-Concern Status.
I think it is a good summary on this matter.
A Dolow Regulatory Ccincern policy statement will provide licensees and NRC staff guidance on the level of risk relating to certain activities involved in the uses of nuclear materials where the risks are so low that the activity need not be further controlled by the regulator.
The concept of exemption is not now.
Since the beginning of regulation certain uses have been exempt from regulatory control.
Some of these such a uranium glazes and thorium in gas mantles predate the nuclear
- age, others involving man-made radioisotopes permitted new uses of radioactive material in consumer products, while others seknowledged the reality that source material was present in some concentration in almost every substance on the surface of the earth.
Although experience has shown these exemptions have not resulted in any significant risk to the public, they are not based from today's viewpoint on any consistent radiological dose basis.
Likewise is true with respect t.o decommissioning nuc) e r.r facilities.
Currently there are a series of Regulatory Guides, Branch technical positions, and office policies on residual contamination limits.
These criteria are in significant need of overhaul to reflect current dosimetric models and the more sophisticated computational methods currently available. While these criteria have proved adequate for small facilities, they need revision and the development of new methodology for large sites.
From a practical viewpoint you can not decontaminate to zero. You can only decontaminate to non-detectibility.
Detectibility varies widely with isotope and the amount of money you are willing to spend on the analysis. We need to define an adequate level of analysis. This can not be done unless the staff is given dose goals.
The commission has recently established rules requiring decommissioning funding for all large facilities and most l
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midsize ones.
To ensure funds are adequate some target Icvel of residual radioactivity must be defined.
Defining a detection limit that must be met for radioactivity or defining a BRC dose practically amounts to the same thing.
A limit j
based on BRC however gives greater consistency within a more i
general exemption policy and can more easily be related to i
risk.
The greatest controversy surrounding this policy in that it would permit solid material containing lov levels of radioactivity not previously exempted from licensing to be disposed in other than a low level waste disposal site.
Note that I said not previously exempted.
Most things placed in municipal waste disposal sites contain source material already exempted due to its low concentration.
Because radiation and radioactive material are pervasive in nur environment practicality requires an eventual exemption limit.
Chairman Carr has previously noted we run the risk that the wastes repiring disposal in a licensed faellity may be cleaner than the environment we are trying to protect. I think, in part, this may be why in the 1985 Low-Level Radioactive Waste policy Amendments Act, Congress directed the NRC to develop standards and procedures for expeditious handling of petitions to exempt from regulation the disposal of slightly contaminated radioactive vaste.
If one accepts that an explicitly enunciated BRC policy is needed for sound practical reasons, how can one identify a dose limit suf ficLently low to say at this point it is not worth spending any more researces to lower the dose?
The Commisston works from two approaches. One approach is to use the done to risk conversion f actors from the BEIR V Committee to identify dose levels whose associated risk is comparable to other societal risks that are considered acceptable. The other approach is to identify variations in natural background dose that seem to play no role in individual decisions with respect to where they live, work or even play.
In fact the variation in background radiation in the US is considarably greater than any of the BRC dose levels being discussed. A level of 10 mrem /yr is comparable to the difference between living in a brick house va a wood house; 1 mrem /yr corresponds to an change in elevation of about 200 ft; and 0.1 area is probably the extra dose I received in flying from Chicago to Detroit for this meeting.
The 60-70 mrem per year difference 1
between annual doses received in Denver, Co, vs. Washington, D.C. has been noted many times. The BRC done will therefor correspond both to a risk that is comparable to other remote risks as well as a dose that society does not spend resources I
to avoid.
l An absorbed dose of several nrem/yr corresponds to a
theoretical incremental annual cancer risk of a several chances /million.
BEIR V acknowledges that for exposures comparable to external natural background radiation the m
I possibility that there can be no risks can not b3 ruled out.
On the other hand there are many other practices characteristic of our society that result in exposures of several mrom/yr to certain members of society. These include tha use of phosphate fertilizer, combustion of fossil fuel, the use of TV's and VDT's and any number of mining and smelting practicos.
It hardly scoms reasonable to require material to be sent to a licensed radioactive vaste disposal site which contains less radioactive material than slag from a smelter, f ertilizer, or slate and shale from a coal mine, just because it originated in a nuclear power plant.
I want to clarify certain misconceptions on the part of some.
pirst, a BRC policy will not in itself allow anyone to engage in exempt practices.
Rulemaking or licensing actions will first be required.
Decisions on these latter actions will be made only after consideration of public comment.
BRC however is a floor on optimization of radiation protection practices, frequently called AIARA (As low as reasonably achievable).
Exemptions will not be
" uncontrolled".
Licensees seeking exemptions would be required to meet appropriate constraints before transferring the material to exempt status. No exempt practices will exist without an NRC evaluation of their consequences.
Mr. Gregg Larson's memo discusses DRC policy impact on the volume of waste projected to be shipped to a regional disposal facility. I believe there is going to be a reduction in vaste volume with or without a BRC policy. Let us look at power reactor low level waste streams. A simplification would break them into 3 categories.
The first is contaminated and activated hardware.
This includes pumps, valves, pipes and even steam generators that need replacement. These tend to be solid objects that can be neither compressed or incinerated.
Until a plant undergoes decommissioning, except for steam generators, the volume and activity is relatively small.
The second is material used in reactor coolant clean-up systems.
This includes filters, evaporator bottoms, and ion exchange resins.
These are usually the major source of activity in the solid
.ste stream from an operating plant.
The third is dry active vaste.
This includes transient items, frequently dicposable, brought into the facility and which become contaminated through contact with contaminated items and areas in the facility.
This third category includes material that is a potential candidate for disposal under the BRC policy because it has a large physical volume but very low in radioactivity.
However, it is also the candidate for other reduction techniques. As the cost of vaste disposal has gono up, licensees have found it cost effective to reduce the volume of this material.
They stop using disposabic anti-C's. They remove packing material from hardware outside the protected area. They separate clean and contaminated waste and use incineration and compaction to further reduce volume.
Other industry initiatives undertaken for ALARA purposes and
i to improve maintenance indirectly contribute to reduction of this waste stream.
It is not much different than what is 1
occurring in the municipal waste disposal area.
As the cost of waste disposal has gone up recycling and other volume reduction techniques have become cost effect!ve.
Just as recycling in a sense has become environmentally virtuous, volume reduction at nuclear power plants has become a goal in itself and a industry (INPo) performance indicator.
There is another aspect of low level waste disposal for which BRC is important and that is mixed waste.
Mixed wastes are chemically hazardous vastes which are slightly contaminated with radioactivity.
Currently both the NRC and the EPA regulate this specia) category.
The BRC policy could permit some of the vaste to be treated solely as hazardous vaste under current EPA rules.
In conclusion, a BRC policy can have a number of important benefits:
- 1. It will allow us to focus on more risk significant issues; 2.
It will establish a floor to ALARA;
- 3. It will establish a consistent dosimetric basis for consumer product exemptions;
- 4. It will let us get on with the job of establishing consistent eritetla for decommissioning and therefore;
- 5. It will alipw ed quate financial planning for decommissioninq/ and 6.
It will allm*
he NRC to meet the Congressional mandate in accordance with the Low-Level Radioactive Waste Policy Amendments Act of 1985.
I would be pleased to answer any questions you might have.
T ALKlf.C 00lN15 BF.C 51LERit4G GFOUP STATuk
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$lfl!0R MANAGEMENT MCElitiG Juht 12, 1990 1.
Purpose:
To develop and implerent a comprehensive strategy for releasing the BRC policy.
Steering Group recont. ended by the Chairman and est6t,11shed by ED0 on May 18.
2.
Members:
H. Thom pson, Jr., Chair J. Fouciard, PA Yol YE_/
C. K6 merer, SP D. Rathbun, CA P., Cernero, kK$$
B. Morris, LES F. Cc:sel,14RR C. Papertello, Regions M. Maisch, OGC 3.
Actisities to Date:
Steering Group has met three tirnes (including meeting of 6/11)
Developed ati overall schedule for activities leading up to and follov,itig the release of the policy stateraent (see attet.hed)
Key ht6cquartert and regioral spokespersons identified Prep 6 red first cut of briefing package for early disseminatict to hegions; major components include:
Briefir.p Slides Critical concepts and nunierical criteria 2ne' draf t of Q's & A's Draf t outline on comunicating risk held dry rur. ses, ion with regional and headquarters spokespersons (June 7)
Identifico and coordinating development of materials consnunicating the essence of the statement Thest include:
Letters to Congress, Governors, affected groups Public Inforration Booklet Press Release Critical Concept Rist Comunications Guideline Working through Chairr.4n of the group, has provided recurrended changes to the language of the Comission policy statement
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hu,r.terrn Activities Developnent of final briefing package Comission approves BRC Policy Stateknt Final changes and printing of Public Information Bootlet Risk Cormunicatior.s Guide Completed Comission input to revisec Q's and A's received Final text agrecrient on standard letter Schedule briefings of appropriate Congressional personnel as well as other Federal agencies Send final policy statew nt to Federal Reoister Prepre for press briefint by Chairman and Headquarters spokespersons Develop concept of Regional Workshops to be held for interested States, profession 61 and pubitt interest grcups
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CH AIRM A N Mr. Tom Teepen Editorial Page Editor The Atlanta _ Constitution 72 Marietta Street, NW Atlanta, Georgia 30302
Dear Mr. Teepen:
I want to clarify the Nuclear Regulatory Commission's policy on exempting slightly radioactive materials that are below regulatory concern, which you addressed in your July 3 editorial.
The NRC's goal is to protect the public health and saf ety and the environment l
and I am confident our recent policy accomplishes our goal.
When the NRC implements this policy, we will ensure that any levels of radiation from exempted activities will be comparable to the lov levels that most of un encounter in routine activities such as the use of smoke detectors in our homes today.
I agree with you on one points few people know what a " millirem" is or what constitutes a " safe" level of radiation.
Everyone is continually exposed to low levels of radiation.
The radiation comes from the earth where radioactive materials exist in soil, rocks, and water, including radon gas. We also get radiation from outer space, building materials, food, and even our own bodies.
Radiation also comes from man-made sources such as medical x-rays and consumer products like falso tooth, smoke detectors, luminous exit signs, and wrist watches.
But how do you measure radiation levels, whether natural or man-made?
Radiation to our bodies is measured in units called ":; ems."
Most radiatioti doses to human beings are so low that the " rem" is too ?.arge a unit, so a " millirem" is used, which is one thousandth of a rem.
It takes 1000 millirems to equal i rom.
Let me give you a frame of reference with respect to radiation and safety.
We each get about 360 millirem por year of radiation dose from outer space, air, food, drink, soils, building materials, and medical exams.
In f act, the National Academy of Sciences committee report you referred to noted that no incroace in health effects has been documented in populations residing in areas of high natural background radiation. I want to emphasize that most of the radiation levels used by the eminent scientists who wrote that study as a basis for risk estimates are a thousand times higher, that is 10 ram (not 10 millircln), than the lovels in the NRC's policy statement.
J A177 d -
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Mr. Teepen
-2 Safety is our responsibility, and it is a matter that we at the NRc ts.ke most seriously.
NRC has been exempting very low levels of radicactise materials on a case-by-case basis for many years.
Tne NRC's goal. is to protect the public health and safety and we are confident that regulatory decisions based on current and sound scientific information will do just that.
Sitcorely,
.%L Kenneth M. Carr l
THE ATLA 51f CONSTITUTION re, m re.r, a y, an a. a
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Nuclear-waste detnsion feeds skepticism
'!he new po!!cy also would allow low-The Nuclear Regulatory Comtals'slos level redloactive wuis to be inc (NRC) has caused itself untweasary griefeven recycled into consumer items. The by announcing it will deregulate the dis-NRC octends the polley by claiming that it posal of some types of low. level nuclear will frw its regulaton to handle more dan.
waste. Whatever Its technical merita, the gerous waste. It also argues that the lev decisbn can only increase pubtle distrust of radioactivity involved less trun 10 of both the NBC and the industry it regn.
millirems per individual - wul be perfect.
lates.
IT S'f*-
S*metimes you wonder what siternate
!! is diffleult for laymen to siccept or universe the NRC occupies. It dosen't take a genius to know that a public increasindy refute the NRC's assertion. F concerned about the danger posed by dis
- know what a millirem is, let alone ho rnacy millinma constitute a 6afe" expo.
posable diapers is going to balk 41'ittting radinactlye material, no mt!!er how slight. sure level. }lowever, the Environm Protection Agency, which does have some ly tainted, into municipal landfilh as the l
expertin in this area, has taounced that NRC proposes.
it finds the NRC's expoecre 11rnits unac.
captably high. It's also a fact that scientisu han discovered recently that erposure lev ela of low level radiation once thought saf-
- lastead constituted serious hesith haurds Olven all that, and pvin the skept
elsm and fear of the American pubit toward nuclear power, the NRC's new pol.
i cy seems absurd. For the sake of a rete Lively minor regvlatory break,it has resur rected old quntions about its supposed' permissive attitude toward the industry
+
g oversets j..'
The NRC's long term goal is to rebu-F 3 'i
.public confidence in nuclear power. T1 grt v-4 t'
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- e confidence cannot be created by convu
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Ing people the atom la somehow less d4 4
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battle wu lost forever on Aug. 6,19 when the Enola Gay dropped its load
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Hiroshima.
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. No, the only way the public will ret
'y confidence in nuclear power is to be sured the NRC and the nuclear indu:
have become nbsolute nuts about pu safety. This policy sends the opposite n D. S. ItCU R Rt0VtMORY coggl$S10N s a.ge.
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NUCLEAR REGULATORY COMMISSION w AssiNovow, p. c. iosss August 13, 1990 CHAIRMAN Mr. Peter Schrag Editorial Page Editor The Sacramento Bee P. O. Box 15779 Sacramento, California 95852 Dear Mr. Schrag I want to clarify the Nuclear Rogulatory Commission's policy on exempting slightly radioactive materials that are below regulatory concern, which you addressed in your July 1 editorial.
The NRC's goal is to protect the public health and safety and the environment-and I.am confident our recent policy accomplishes our goal.
When the NRC implements this policy, we will ensure that any levels of radiation from exempted activities will be comparable to the low levels that most of us encounter in routing activities such as the use of smoke detectors in our homes today.
Let me give you a frame of reference with respect to radiation.
We each get about 360 milliram per year of radiation dose from outer space, air, food, drink, soils, building materials, and medical exams.
In fact,--our policy is basically consistent with the recommendations of the National Council on Radiation Protection and Measurements and the latest scientific assessments on the risk on radiation by scientists in national and international groups, including the National Academy of Sciences and the United Nations Scientific Committee on the Effects of Atomic Radiation.
For example, a recent National Academy of Sciences report noted no
[
-increase in health effects has been documented in populations residing in areas of high natural background radiation.
I want to emphasize that most of the radiation levels used by the eminant scientists who wrote this study as a basis for risk estimates are
. a thousand times higher, that is 10 rem (not 10 millirem), than the levels in the NRC's policy statement.-
The assessments of these internationally recognized scientific bodies were used by the International. Commission on Radiological Protection in formulating their recommendations to limit radiation doses, which are also thousands of times greater than those associated with potential exemptions.
I want to point out that it is not NRC's responsibility to come up
' with safe disposal methods for radioactive waste.
That is the responsibility of the people who genarate the waste, such as hospitals, research facilities, utility companies, and other
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'e Mr. Schrag industries who use these materials as well as the State and rederal agencies specifically charged with that responsibility.
- However, we are responsible for ensuring that the vasts generators safely dispose of their radioactive vastes in a manner that protects the public and the environment.
)
" Ignoring" radioactive waste is not our intent.
Nothing could be further from the truth.
The Commission has a demonstrated track record of developing and enforcing tough regulations to ensure the I
public is protected from radioactive waste, our Below Regulatory Concern policy is an attempt to tailor the amount of regulatory control to the potential risks posed by such vaste.
Safety is our responsibility, and it is a matter that we at the NRC take most seriously.
The NRC's goal is to protect the public health and safety and we are confident that regulatory decisions based on current and sound scientific information will do just that.
Sincerely, OmIh h Kenneth M. Carr O
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SACRAMENTO C0 BEE, SACRAMENTO, CA a
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Low at the dump hnneth Carr, chairman of the Nuclear ful. But that's one of several aspects of Carr's Regulatory Commission, has come up proposal that the Environmenta! Protection with r. nifty idea for getting rid of nearly Agency considers " totally inappropriate.'
one third of the nation's low level nuclear nere may indeed be safe alternatives for 4
wastes in one easy step: Ignore it.
disposing of some of this material more eco-Carr p?oposes to treat these slightly radio-nomically than it is being handled today.
active materials just like any other kind of Certainly it's an issue the government should trash, and although he has won the backing pursue. But is the NRC the appropriate agen.
of nuclear power plant operators, what he cy to detennine how much radioactivity is has in mind isn't going over so well with the safe enough? Some of the crNeism of Carr's
, other pub!!c agencies responsible for public 3roposal from other expem suggests that it health and safety.
s not.
It's easy to uriderstand the nuclear power
- Industry's enthusiasm. De NRC's continu-E PA contends that the level of radloactiv '
f'ing failure to come up with a safe, reliable
.0/ ity that the NRC has decided is low Ag*
'I means of nuclear waste disposalis one of the enough not to regulate anymore is roughly
. major stumbling blocks to the expansion of five times higher than it ought to be for pub-atom'c power. Even if no new nuclear plac. 3 lic safety. The Nananal Council on Radiation
~
ever open in this country, the industry is fac.
Protection, which sets the standartis for ex-
- ing potentially snormous costs over the neu posure that most radiologists follow, sug.
- 20 years as the facilities that are already in gests that the limits should be set even lower
- operation reach the end of their useful life still. And those estimates were all drawn up )p
- span rond have to be closed and dismantled.
before the International Commission on Ra-Under the NRC's plan, all sorts of dispos-diological Protection, which recommends -
, ables from the plants that are currently standards for nuclear exposure in the work-l treated as hazardous - gloves, air. filters, place, announced recently that the risks of
- used machinery, dead animals from laborn-radiation are roughly three times greater t tory experiments - could be sent directly to than scientists have calculated in the past.
', sanitany landfills. Some of it, Carr suggests, Carr may be on the right track, but he ap-
- could even be recycled into something use-pears to have a verylong way to go.
Sg
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't, CMMRMAM Mr. David Holwerk Editorial Page Editor The Herald-Leader 40507 Lexington, Kentucky
Dear Mr. Holwerk:
policy on i
I want to clarify the Nuclear Regulatory Commiss on s below regulatory exempting slightly radioactive materials that are i l.
The NRC's concern, which you address in your July L editor a d the environment goal is to protect the public health and safety anand I a goal.
When the NRC implements this policy, we will ensure ble to the low radiat ion from exempted activities will be comparalev i
h as the use of smoke detectors in our homes today.
i terials on NRC has been exempting very low levels of radioact ve ma The Commission has a demonstrated track record of developing and enforcing tough basis for many years.
case-by-case the public is protected from radioactive a
to tailor regulations to ensureOur Below Regulatory Concern Policy is an attempti l the amount of regulatory control to the potent a vasta.
such vaste.
t. to radiation.
Let me give you a frame of reference with respecradiation dose from 360 millirem per year of drink, soils, building materials, and We each_get about our policy is basically.consiatant withCiation Prot outer space, air,
- food, In fact, the reconmondations of the National-Council on Ra medical exams.
ts on the risk and Measurements and the latest scientific assessmen tional groups, of radiation by scientists in national and interna Nations including the National Academy of Sciences and the United i tion.
Scientific Committee on the. Effects of Atomic Rad a t noted no For example, a recent National Academy of Sciences reporin populat been-documented t to emphasize in health ef fects has resicing in areas.of high natural radletion. I wan i
t scientists-increase that most'of the radiation levels usea by the em nene a thousand who wrote this study as a basis for risk estimates a h
levels in the NRC's policy statement.
i t
low levels We are not aware of any credible studies that ind l nt. a marked nable.
increase in health effects. effects cited in your editorial are simply n b'
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August 13, 1990 CHAIRMAN Mr. David Holwerk Editorial Page Editor The Herald-Leader Lexington, Kentucky 40507 Dear Mr. Holwerk I want to clarify the Nuclear Regulatory Commission's policy on exempting slightly radioactive materials that are below regulatory concern, which you address in your July 5 editorial.
The NRC's goal is to protect the public health and safety and the environment and I am confident our recent policy accomplishes our goal.
When the NRC implements this policy, we will ensure that any levels of radiation from exempted activities will be comparable to the lov levels that most of us encounter in routine activities such as the use of smoke detectors in our homes today.
NRC has been exempting very lok levels of radioactive materials on a case-by-case basis for many years.
The Commission has a demonstrated track record of developing and enforcing tough regulations to ensure the public is protected from radioactive waste.
Our Below Regulatory Concern Policy is an attempt to tailor the amount of regulatory control to the potential risk posed by such vaste.
Let me give you a frame of reference with respect to radiation.
We each get about 360 millirem per year of radiation dose from outer space, air, food, drink, soils, building materials, and medical exams.
In fact, our policy is basically consistent with the recommendations of the National Council on Radiation protection and Measurements and the latest scientific assessments on the risk of radiation by scientists in national and international groups, including the National Acedemy of Sciences and the United Nations Scientific Committee on the Effects of Atomic Radiation.
k For example, a recent National Academy of Sciences report noted no increase in health effects has been documented in populations residing in areas of high natural radiation. I want to emphasize that most of the radiation levels used by the eminent scientists who wrote this study as a basis for risk estimates are a thousand times higher, that is 10 ram (not 10 millirem), than the levels in the NRC's policy statement.
We are not aware of any credible st.udies that indicate low levels of radiation could produce measurable effects--let alone a marked increase in health-effects.
sieflarly, the estimates of health l
' effects cited in your editorial art uimply not reasonable.
p' lh
_jl0421Gsb i
=
Mr. llolwerk safety is our responsibility, and it is a matter that we at the NRC take most seriously.
The NRC's goal is to protect the public health and safety and we are confident that regulatory decisionn based on current and sound scientific information will do just that.
Sincerely, v.
Kenneth M. Carr b
l l
HERALD-LEADER, LExlNGTON, KY
/LJLibJL ussNovost 0 C 7000!
Front Ecet other Page Page i Pode t
JUL 5 1990 ' '
LEXINGTON, KY HERALD-LEADER W - 116,875 S - 144,410 88 p, yma" ancfil c owsin :he darx Kentucky's failure to halt the Under federal standards, the importation of garbage became maximum acceptable radiation ex.
even more significant last week posure is that which would produce when the Nuclear Regulatory Com-one cancer fatality per 100,000 peo.
mission gave9FmoribuflP!fuelear ple. The effects of tie NRC decision power industry its latest economic supposedly would not exaed that mcentive. The NRC enhanced its standard. But with this waste being image as an industry shill by decid. dumped out with other trash all ing that vast quantities of low level radioactive waste are "below regu-across a nation of 240 million peo-l ple, 2,400 Americans could suffer latory concern"-
fatal cancers as a result. That's Baning a congressional reversal. assuming no one cheats by putting of the NRC action, generators of some still regulated radioactive radioactive waste - nuclear power waste in with the unregulated re-plants, weapons facilities and medi.
fuse, thereby adding to the health cal facilities-willbe able to toss a harard.
lot ofit out with the trash or flush it down the drain. Eventually, it will That also assumes that the gov-wind up in landfills, incmerators ernment stantards are adequate, an and sewage treatment plants across assumption th t is not supported by the nation, where its radioactivity some studies of nuclear accidents at will pose a health hazard to an Three Mile Isamd, Chemobyl and the Savannah River p unsuspecting public.
gia. These studaes m,lant in Geor.
Kentucky of course, doesn't dicate that
-l have any nu, clear power plants. It even low levels f radiation expo.
does, however, have a plutonium 7,y; uce marked mcreases ennchment plant and the usual number of medical facilities gener-ating radioactive waste, if the NRC This policy is being put in place decision stands, that is more than simply to cut the miclear industry's enough for the state to worry about.
waste disposal costs. Over the We don't need the added troubles of years, the NRC has made little imported garbage from, say, New-pretense about whose interests it Jersey that might include the refuse serves. But this trading of lives for money may set a new standard for from some nuclear power plant.
The Bluegrass State's problems shamelessness. It's a standard Con-gress should not tolernte and one aside,-the NRC decision is uncon-that states.chould move quickly to
'scionable.
protect against.
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wash NoToN, o, c. rosss August 13, 1990 CHAtRMAN 4
Mr. Jim'Hampton, Editor 3
The Miami Her_ald one Herald Plaza Miami, Florida 33101
Dear Mr. Hampton:
I want to cls -ify the Nuclear Regulatory Commission's policy on exempting sligi/dy radioactive materials that are below regulatory concern, which you address in your July 6 editorial.
The NRC's goal is to protect the public health and safety and the ens ronment and I am confident our recent policy accomplishes our goal.
When the NRC. implements this policy, wo will ensure that any levels.of radiation-from exempted activities will be comparable to the low levels that most of us encounter in routine activities such as the use of smoke detectors'in our homes today.
~
NRC has been exempting very low levels of radioactive materials on
-a case-by-case basis for -many years.
The Commission. has a-demonstrated -track record of developing and enforcing tough regulations to ensure the -public is protected from radioactive vaste. Our Below Regulatory Concern Policy is. an attempt to tailor -
the amount of regulatory control to the potential risk posed-by such waste.
Let-me give you a: frame of reference with respect to radiation.
.We each-get about 360 milliram per year of radiation dose from outer space,- air, food, drink, _ soils, building-materials, and
-medical exams.
In fact, our policy:is basically consistent with--
h the recommendations of the. National Council on Radiation Protection:
and Measurements and the latest sckntific assessments on the risk L
of radiation _by scientists in national-and-international groups, including the National Academy of Sciences and the United Nations Scientific Committee-'on the: Ef fects of Atomic Radiation ~.
For example, a recent National Academy of Sciences report noted no
, increase in-health effects has been documented in populations residing in areas of_high natural background radiation. I want to emphasize-that most of the radiation levels used by the, eminent
. scientists who wrote this study as a basis for. risk estimates are a thousand times higher, that is 10 ISE (not 10. millirem), than the:
levels in the NRC's policy statement.
In short, the estimates of health effects cited in year editorial as being associated with-the
.BRC policy are simply not reasonable.
f
-$ A n n a A,i -7&
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Mr. Jim Hampton,
Safety is our responsibility, and it is a matter that we at the NRC take most seriously.
The NRC's goal is to protect the public health and safety and we are confident that regulatory decisions based on current and sound scientific information will do just that.
Sincerely, Kenneth M.
Carr l
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Radioactive roulette TWO NEW propoeak to dssi withce ta w a w r e a g a n u s s &
t o eve wa.
w - r oes posald,radoactive m,aterkle with no con < huilly, Why would the NRC trols over potential contaminate' a.
% locrease Amerkans' risk at all? Becau.
The Nuclear Regulatory Commission ~k' seeks economic solu L
(NRC) wants disposal d "mDay" radioac, weste, whkh is heressina as older nuct '
dye weste from nuclear Acilitws deregu.
lated. Everything trorn used rubber gloves
- power plante are deco Flonda's De to obsolete equipment would enter the gen. Resources (DNP)partm proposes us!n radl:
I
' eral waste stream. They could be recycled Llve phosphogyptu'n Waste from intoever alning,in state r6ad bed for a landf2s.yday products or dumped la nearbyRight now, only th 11' U.S landfatcan this wasta,
.. tons of the stuff fa Central Florida where
-The NRC la alte thle idea to the ~ toxks are seepintinto 31ound water.:
! -~
. Enytrommental Protect A
(EPA), 'of phosphogypsum,14 can p The EPA lutheembert bonned all:
seta standards for necepta radla. -
and its radiation can last 1,630 yo eposure levels in products. 'heNRC u
wants to raise it to 10 millitems. % SPA r phosphocysum la roadbeds w-o hasproposed a standard d 4 mullroms..
bute the 19xk, whkh now show:
4 Theaverage Amerkanisexposed to 360 onlyinlocallaed concentrations.
millirems of radiation a year Most la frona Florida has-Invested -
d ' naturnDy occurring radan gas. Man.made ; researching phosph p
m usesc sources are X ray machines and airline DNR la buying into a short term soh E
flights. A coast.to. coast, round trip flight heavil suppon Sed tka men.ed by the industry tha L
has about 5 mitilrems of ex sure,-
This Osk bden da c -
'[,,'hricans' isk g ersate a much<ostikt future problem.
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NUCLEAR REGULATORY COMMISSION n
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- ,,,, s *j OF FICE OF THE COMMISSIONE R August 9, 1990 Editor CENTRE DAILY TIMES Post Office Box 89 State College, Pennsylvania 16804
Dear Editor:
I feel compelled to respond to your July 27, 1990, front page article about the Nuclear Regulatory Commission's (NRC) Policy Statement on "Below Regulatory Concern" (BRC)
Contrary to the article, the issuance of this policy statement does not mean that low-level radioactive waste can be disposed of as garbage.
The BRC Policy describes how the NRC will go about determining when radiation levels from radioactive materials are so low that they do not warrant further NRC regulatory control to protect the public health and safety and the environment.
The commission will use the policy to evaluate future petitions for exemptions, develop new rules or amend existing ones, and take specific licensing actions involving exemptions of nuclear materials.
Each such rulemaking or licensing action will provide an opportunity for public input.
The policy establishes a consistent framework for the commission to consider future petitions for exemptions, if requested to do so.
However, the BRC-Policy has not and does not in itself exempt any radioactive materials from regulatory control.
In 1985, the U.S. Congress directed the Commission to develop
-standards and procedures and act upon petitions "to exempt specific radioactive vaste streams from regulation... due to the presence of radionuclides... in sufficient low concentrations or quantities as to be below regulatory concern."
In part, the Commission's BRC Policy has been developed in response to that Congressional mandate.
The BRC Policy has several intended purposes other than those directed by Congress, however.
For example, the Commission must
' determine the amount of residual radioactivity that may be permitted from a public health and safety standpoint when nuclear facilities are decommissioned or when contaminated sites are I
cleaned-up for unrestrict.ed public use.
The standard for decommissioning and decontamination established in the BRC Policy is essential to enable the NRC and state egencies to determine the amount of funds facility licensees should be required to set aside for such purposes, i
[03 2 hMl i
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.. Also, the standards established in the BRC Policy will help the commission decide whether slightly contaminated equipment and materials from decommissioned sites can be safely recycled or reused.
Further, it should be understood that certain uses of nuclear materials in a limited number of consumer products have been exempted from regulatory control for some time.
Such exemptions include uses in commercial and domestic smoke detectors, luminous dials in wristwatches and marine compasses, thermostat dials, oil burners, incandescent gas mantles, finished circraft engine parts, automobile door lock illuminators and shift quadrants, aircraft exit signs, among other things.
The risks from materials exempted under procedures established in the BRC Policy would be generally comparable to the risks associated with these currently exempted products.
The NRC will review these existing exemptions, however, to assure that they do not exceed the standards in its new policy.
The policy is intended to ensure that such existing and future exemption decisions are consistent and will continue to protect the public health and safety and the environment.
It is unfortunate that there is so much misunderstanding about radiation and the use of radioactive materials.
Man has always lived in a sea of natural radiation from the sun, the earth, our own bodies and many of the materials we use and live in.
Under the standards established by the NRC for evaluating exemption requests, radioactive materials permitted in exempted consumer products would be limited so that the annual radiation exposure to an individual user would be limited to about 1/300th (i.e. 1/3 of 1%) of that from natural background radiation.
This is less than the exposure of a cross-country airplane flight, or the difference in exposure from living for a year in a brick house versus a-wooden one.
For those limited numbers of individuals who might spend time en-decommissioned sites, the commission would enforce controls to assure that their annual radiation exposure from that activity would be limited to about 1/30th (i.e. about 3%) of that from natural sources.
This is much less than variations in exposure levels from living in Denver versus living in Happy Valley, or variations that occur from floor to floor in many of our public buildings.
The standards established in the ERC Policy are voll within the realm of such everyday radiation risks.
People don't generally avoid commercial air flights or avoid communities with higher background radiation to reduce their radiation risks.
They don't have to. Take the recent, much publicized report on the health effects of exposure to low-level radiation.
In that report, i
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4 1
' the National AC acmy of Science's committee on the-Biological
~-
Effects _ofcIonizing Radiation says-that " studies of-populations
-chronically-'exposedLto low-level _ radiation,-such.as.those
' residing in regions ofLelevated: natural background radiation" --
- many1 times higher than our BRc criteria-' levels "have not shown-consistent.or' conclusive evidence of an associated increase irt I
the risk of cancer.r.
The-BRC Policy will enable the Commission-and its licenseas to refocus _ resources from these very low
- radiation risks to reduce more significant risks-for which the-
- time and money would buy a greater degree-of overall protection for.the.public.
i For your further information, I an enclos ng a= copy of the BRC' Policy Statement, a'public information pamphlet, and a press release explaining the:BRC Policy.
All of these would have been provided-to you or to other. interested individuals, had you 7
contacted-me.or the NRC's Office of Public Affairs, which I hope
=
you.will not hesitate to do--in-the-future.
Sincerely,-
F t J.-Remick issioner
Enclosures:
As' stated-i
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UNiit o sT AT t s cys:
Speis NUCLE AR REGULATORY COMMISSION Heltemes y
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n g....+/;I M$HING TON, D. C. 20655 Morris t
JUL 3 01993 goa,
MEMORANDUM FOR:
Robert M. Bernero, Director, hMSS Thomas E. Murley, Director, NRR G
Eric S. Beckjord, Director, RES Thomas T. Martin, Regional Administrator, RI Stewart D. Ebneter, Regional Administrator, Ril A. Bert Davis, Regional Administrator, Rlli Robert D. Martin, Regional Administrator, RIV John B. Martin, Regional Administrator, RV tROM:
James M. Taylor Executive Director for Operations SUBJtCT:
GUIDANCE ON FEDERAL REGISTER NOTIFICATION OF RULLMAKINGS AND LICENSING AttiONS WHICH EXEMPT MATERIAL FROM REGULATORY CONTROL The purpose of this memoran um is to provide interim guidance in light of the J
Commission's policy statement on "Below Regulatory Concern (BRC)', on Federal Register notification of rulemakings and licensing actions involving exemption decisions. The BRC policy statement states that opportunity for public comment will be provided through noticing in the Federal Register, for rulemakings and any new licensing actions involving the exemption of small quantities of radioactive materials from regulatory control where generic exemption provisions have not already been established.
The statement permits the continued use of existing generic exemption provisions that do not require a Federal Register Notice until the generic exemption has been reviewed for consistency with the BRC policy.
Licensing actions taken in accordance with such provisions may continue to be issued without such notice, unless notice is otherwise required (for example, Part 51 may require notice).
I have included as enclosures to this memorandum, interim guidance on how to proceed with exemption decisions in the near term.
In preparing these enclosures, the staff has taken a broad look at existing exemption provisions and has identified all those which could be relevant to the BRC policy. Enclosure 1 provides guidance for NRR actions and Enclosure 2 provides guidance for HMSS and regional actions.
Federal Register Notices required for regional actions should be preparea by the region following existing guidance, it you have any questions en this matter, please contact Lemoine J. Cunningham for NRR questions (492-1086) or John Hickey for NMSS questions (492-3425).
/, -
mes M. T lor xecutive trector for Operations
Enclosures:
N As stated I
--go !! 306 27(0-gA k
ENCLOSURE 1 NRR GUIDELINES FOR PUBLIC NOTICE OF LICENSING ACTIONS RELATED TO THE BRC POLICY POWER AND NON-POWER REACTOR LICENSEES CONTACT:
L. J. Cunningham, NRR, 492-1086 1.
The following licensing actions do not need to be noticed in the Federal Register, unless there is a~iireviously existing requirement for such notice; such as a Sholly Notice or 10 CFR 51:
a.
Authorizations based on regulations or guidance issued after June 27, 1990, if the regulations or guidance do not themselves require notice and were developed in accordance with the BRC policy and noticed for comment in the Federal Register, b.
Authorizations in accordance with provisions of 10 CFR Section 20.303, 20.306, 30.15(a), 30.18, and 30.20.
c.
Onsite burials in non-Agreement States approved pursuant to 10 CFR Section 20.302.*
d.
Authorizations to release equipment or facilities for unrestricted use in accordance with the guidelines in Regulatory Guide 1.86, NRC Circular 81-07, information Notice 85-92 or environmental lower limits of detection (LLO's) contained in NUREG-0472.
if the Approvals of incineration pursuant to 10 CFR Section 20.305, T e.
ash is disposed as non-BRC radioactive waste, transferred to licensed person, or contains non-detectable radioactivity.
2.
The following licensing actions must be noticed in the Federal Register, with at least a 30-day cocinent period.
a.
Any action not covered by No. I which uses the BRC policy as justification for approval, b.
Any exemption authorization involving transfer of radioactive material to unregulated status, not covered by 1(b) above, where a dose analysis is performed, and the projected doses exceed the BRC
- criteria, c.
Any 20.302 off-site burial.*
d.
Any authorization for incineration which allows disposal of ash which contains detectable levels of radioactivity as BRC waste, e.
Any HRR approval letter, license amendment or change in Technit Specifications that requires notice in the Federal Register (Sholly Notice).
- Note that actions under 20.302 do not remove material from regulatory control unless specifically so stated; thus 20.302 approvals may not be subject to BRC policy.
ENCLOSURE 2 HMSS GUIDEL1HES FOR PUBLIC NOTICE OF LICENSlHG ACTIONS FILATED TO THE ERC POLICY FUEL CYCLE AND MATERIAL LICENSEES CONTACT: John Michj, HMSS, 492-3425 1.
The following licensing actions do not need to be noticed in the Federal Register, unless there is a previously existing requirement for such notice:
a.
Authorizations based on regulations or guidance istued after Jane 27, 1990, if the regulations or guidance do not themselves require notice and were deveicped in accordance with the BRC policy and noticed for coment in the Federal Register, b.
Authorizations in accordance with provisions of 10 CFR Section 31.11(f)20.306,30.14,30.15(a),30.16,30.16,30.19},30.20.31.7 20.303
, 35.92, 39.47. 39.49, 39.77, 40.13, 40.22(b and40.25(e).
c.
Onsite burials approved pursuant to 10 CFR Section 20.302, in accordance with Policy and Guidance Directive FC 86-10, dated October 9, 1986, or the Federal Register notice entitled
- Disposal or Onsite Storage of Thorium or Uranium Wastes," 46 FR 52061, October 23, 1981.*
d.
Authorizations to release equipment or facilities for unrestricted use in accordance with the guidelines in Policy and Guidance Directives FC 83-3, dated March 7, 1983, and FC 83-23, dated November 3, 1983.
e.
Authorizations to dispose of waste which has been held for decay to non-detectable radiation levels, f.
Approvals of inciner6 tion pursuant to 10 CFR Section 20.305, if the
~
ash is disposed as non-BRC radioactive waste, transferred to a licensed person, or contains non-detectable radioactivity.
2.
The following licensing actions, including renewals, must be noticed in the Federal Regicter, with at least a 30-day coment period.
Any action not covered by No. I which uses the BRC policy as justification a.
for approval, b.
Any exemption authorization involving transfer of radioactive uterialtounregulatedstatus,notcoveredby1(b)above,wherea dose analysis is perfortned, and the projected doses exceed the BRC criteria.
Any 20.302 off-site burial or any burial which is not in accordance c.
with Policy and Guidance Directive FC 86-10 or 46 FR 52061.*
d.
Any authorization for incineration which allows disposal of ash which contains detectable levels of radioactivity as BRC waste.
e.
Any authorization to distribute a new type of consumer product on a license-c..=npt basis which has not been previously authorized.
- Note that actions under 20.302 do not remove materials from regulatory i
l control unless specifically so stated; thus 20.302 approvals may not Le wbject to BRC policy.
i j
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'o UNITED STATES NUCLEAR REGULATORY COMMISSION w Asm wo ton. o. c. 2csss August 13, 1990 CHAIRMAN -
Mr. Edward Higgins Editorial Page Editor The Post-Dispatch 900 N. Tucker Blvd.
St. Louis, Missouri 63101 Dear Mr. Higgins I want to clarify the Nuclear Regulatory Commission's policy on exempting slightly radioactive materials that are below regulatory concern, which you addressed in your July 5 editorial.
The NRC's goal is to protect the public health and safety and the environment and I am confident our recent policy accomplishes our goal.
When the NRC implements this policy, we will ensure that any levels of radiation from exempted activities will be comparable to the low levels that most of us encounter in routine activities such as the use of smoke detectors in our homes today.
Let me give you a frame of reference with respect to radiation.
We each get about 360 millirem per year of radiation dose from outer space, air, food, drink, soils, building materials, and medical exams.
In fact, our policy is basically consistent with the recommendations of the National Council on Radiation Protection and Measurements and the latest scientific assessments on the risk of radiation by scientists in national and international groups, including the National Academy of Sciences and the United Nations Scientific Committee on the Effects of Atomic Radiation.
For example, a recent National Academy of Sciences report noted no increase in -health effects has been documented in populations residing in areas of high natural background radiation. I want to emphasize that most of the radiation levels used by the eminent scientists who Yrote this study as a basis for risk estimates are a thousand times higher, that is 10 rga -(not 10 millina), than the levels in the NRC's policy statement.
The estimates of health effects cited in your editorial as being associated with the BRC policy are simply not reasonable.
The current disposal of high level and low-level radioactive wastes are incorrectly described in your editorial. Commercial high-level wastes are the very radioactive used fuel from nuclear power plants.
For the most part, this fuel is now-stored at the nuclear power plant sites awaiting the establishment of a
Federal repository by the Department of Energy.
The NRC has no intention of exempting high-level radioactive waste or most low level waste.
Based on studies prepared by the nuclear utilities and the Environmental Protection Agency, only about 0.01 % or less of the radioactivity in low level waste would be eligible for exemption
, x\\ under our policy.
Ij
Mr. Edward Higgins Safety is our responsibility, and it is i matter that we at the NRC take most seriously. NPC has been exe:spting very low levels of radioactive materials on a case-by-case basis for many years.
The NRC'c goal is to protect the public health and safety and we are confident that regulatory decisions based on current and sound scientific information will do jt.st that.
Sincerely, h.L Kenneth M. Carr 1
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wada=85== Pruencemen med Messer==*eam a group et Alters med reales casemmaammend by see et.e seclear ecleathis met closely moellers redletten, mies ep-feesty, weeld en longer he regolated. Itsess lhet espese a meseber et that puhIle to me seere Iben It poses the new policy.The Nuclear Regaletery Com-
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