ML20034C600
| ML20034C600 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Grassley C SENATE |
| Shared Package | |
| ML20034C601 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9005040198 | |
| Download: ML20034C600 (2) | |
Text
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March 8, 1990 The Honorable Charles E. Grassley United States Senate Washington, D.C.
20510-1501
Dear Senator Grassley:
I am responding to your. letter of February 8 1990, in which you asked us for our views on matters pertaining to low-level, radioactive waste (LLW) disposal raised by your constituent, Ms. Catherine Prall. Specifically, Ms. Prall's concerns are directed at Nuclear Regulatory Comission (NRC) activities'to-exempt specific waste from further regulation if its radioactivity content is sufficiently low as to be "below regulatory concern (BRC)." The BRC terminology reflects a class of material described in Pub. L.99-240, the Low-Level Rwdioactive Waste Policy Amendments Act of 1985.
In response ~to Ms. Pra11's concerns, I would first note that the Nuclear 2
Regulatory Commission (NRC) has not published any proposed regulations which would allow disposal of low-level waste under the BRC provisions of-Pub. L'.99-240.
However, in 1986, we did issue a final policy (Enclosure 1 51 FR 30839), which established the standards and procedures that will permit i
the NRC to act upon "BRC" rulemaking petitions in an expeditious manner, as l
called for in the Act.
The NRC has also initiated the development of a broadly applicable exemption policy. An advance notice of this policy development effort was issued in the Federal Rerl1 ster on December 12, 1988 (Enclosure 2, 53 FR 49886). The policy would publ'cly express the principles and criteria that underlie Commission exemption decisions including those related to BRC waste disposal. The policy is intended to provide a consistent basis for all of our decisions that allow radioactive material to be exempt from regulatory control.
Thus, the polley, although applicable to BRC waste disposal, would also provide the basis for decommissioning 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 with greatest potential impact on public health and safety.
In addressing Ms. Prall'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. As a result, the implication that more hazardous radioactive low-level waste could be disposed of as BRC waste is incorrect.
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 l
readily detectable.
It should be noted that the 30 percent referred to in
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The Honorable Charles E. Grassley 2
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"The Nation" article attached to Ms. Prall's letter most likely refers to a f
volume percentage as estimated by the nuclear industry and is applicable only to the waste generated in nuclear power plant operations. This volume has been i
estimated to contain only about 0.01 percent of the radioactivity discharged as i
low level waste by the nation's nuclear utilities, j
It may be helpful to summarize 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 effective dose equivalent received 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 l
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 hypothetical risks which may be associated with i
potential BRC waste disposal practices. This perspective is one of several that the Commission believes are relevant to its decisions involving regulatory resource allocations to control.the potential radiological risks associated with the use of radioactive materials.
Ms. Pra11 also asked if other States besides Maine had passed legislation to control the disposition of [BRC) radioactive waste.
Our information i
indicates that only the State of Maine has passed such legislation although similar legislation is under consideration by the States of Vermont and New.
Hampshire.
l 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 Ms. Prall are among those that we must carefully consider and address as we carry out our regulatory mission.
Sincerely,
. /
4 J
s M.
lor xecutive Director for Operations 4
Enclosures:
1.
FinalPolicy(51FR30839) 2.
FederalRegister(53FR49886) i
)
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