ML20034B126
| ML20034B126 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Wilson P SENATE |
| Shared Package | |
| ML20034B127 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9004260044 | |
| Download: ML20034B126 (2) | |
Text
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g.,*(y*%gA UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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msmwoTow. o. c. rous March 19,1990 The Honorable Pete Wilson United States Senate Washington, DC 20510
Dear Senator Wilson:
I am responding to your letter of February 23, 1990, which requested our consideration of issues raised by your_ constituent, Mr. Irwin Ottenberg (reference your case 0054030011). Mr. Ottenberg's concerns involve the disposal of low-level radioactive wastes; specifically, those wastes characterized as "below regulatory concern" or "BRC."
You may recall that ny previous letters to you on August 11 and December 28, 1989, addressed this same subject.
I would first note that the Nuclear Regulatory Consission (NRC) has not any proposed regulations which would allow disposal of low-level waste (published LLW) under the BRC provisions of the Low-level Radioactive Waste Policy Amendments Actof1985(Pub.L.99-240). However, as brought ~out in our past correspondence, the Act directed the NRC to "... establish standards and procedures... and develop 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 in sufficiently 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 statement which you may again find useful in responding-to your constituent (Enclosure 1).
In our previous correspondence, I also indicated that we are aware that the nation's nuclear power utilities are preparing'such a petition but, to date, this petition has not been submitted to us.
Besides this 1986 policy, the Comission continues to be active in pursuing the development of the policy, discussed in our previous communications, that would identify the principles and criteria that govern Comission decisions which could exempt radioactive material from some or all regulatory controls. This policy, the subject of the enclosed advance notice (Enclosure 2), would apply not only to BRC waste disposals b?t also to other decisions which would allow licensed radioactive material to be released to the environment or to the general public. The Comission's proposed exemption policy is intended to provide a consistent basis for all our decisions that allow radioactive material to be exempt from regulatory control. Thus, the policy, alttough applicable to BRC waste disposal, would also provide the basis for deconuissioning decisions involving the release of lands, structures, or recycled materials for unrestricted use as well as decisions regarding consumer product exemptions. We believe the nation's best interests are served by a policy that establishes a consistent risk framework within which exemption decisions can be made with assurance that human health and the environment are protected.
Such a policy will also contribute to focusing limited national resources on those risks wii:h greatest potential impact on public health and safety.
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,..'E The Honorable Pete Wilson 2
In addressing Mr. Ottenberg's general concerns on the dangers of radiation, I would point out that any LLW considered to be "below regulatory concern" under the provisions of Pub. L.99-240 would only involve materials with the lowest levels of radioactivity content.
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.
It should be noted that the 30 percent of nuclear waste, referred to by fir. Ottenberg, most likely applies to a nuclear J
utility industry estimate regarding the volume percentage of their waste which 1
may qualify, in their view, for BRC consideration. This volume has been estimated to contain only about 0.01 percent of the radioactivity discharged as low level waste by the nation's nuclear utilities, it may be also helpful to summarize the typical exposures which we all routinely receive from a variety of sources of radiation. Tiese 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 effective dose equivalent receivec by the United States population averages about 360 millirem per year.
Of this total, about 300 millirem per year (or over 80 percent of the total) is a result of natural sources, including radon and its decay products, while medical exposures contribute an estimated 53 millirem per year.
Other man-made sources contribute the remaining 1 to 2 percent of the total exposure.
I am presenting this total exposure " picture" to provide a perspective on the hypothetic61 risks which ney be associated with potential BRC waste disposal practices. This perspective is one of several that the Connission 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 again want to assure you that we tale our mandate to protect the health and safety of the public very seriously.
As a result, the concerns i
expressed by Mr. Ottenberg are anong those that we must carefully consider and address as we carry out our regulatory mission.
Sincerely,
/
l g
l Ja s M. Tay r ecutive D ector for Operations
Enclosures:
1.
Final Policy (51 FR 30839) 2.
FederalRegister(53FR49886) 3.
Package Incoming Material 2