ML20034C634
| ML20034C634 | |
| Person / Time | |
|---|---|
| Issue date: | 03/05/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Damato A SENATE |
| Shared Package | |
| ML20034C635 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9005040245 | |
| Download: ML20034C634 (2) | |
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MarchSI1990-The Honorable Alfonse M. D'Amato e
United States Senator 1259 Federal Building 100 South Clinton Street Syracuse, New York 13260
Dear Senator D'Amato:
I am responding to your January 24,1990, letter which asked us for-our views on matters pertaining-to the low-level radioactive waste disposal program raised by Mr. Edward Fuhr, Chairman of the Saint Lawrence County Environmental Management Council and forwarded through the Honorable John McHugh of the New York State Senate.
I Mr. Fuhr states that the Environmental Management Council believes that the Nuclear Regulatory Comission and the public should first determine whether exemptions are ever warranted and that the resulting policy should then dictate the economics of proper waste management.
The Low-Level Radioactive Waste Policy Amendments Act of 1985 (the-Act) directed the Commission to "... establish standards and procedures... and develop the technical capability for considering andactinguponpetitions[emphasisadded]toexemptspecificradicactivewaste streams 1 rom 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 this legislation, NRC developed and published in 1986, the enclosed Statement of Policy and Procedures (Enclosure 1) which outlined the criteria for considering such petitions.. To date,-the Comission has received i
two petitions from the Rockefeller University related to biomedical waste, but these petitions have not qualified for expedit:td consideration'under this policy.
Moreover, when and if petitions on this subject are received, they will be published in the Federal Register to solicit public coment, and if the NRC should determine that there is merit in an exemption regulation, the proposed regulation would again be published for public consideration and coment. This is the process that has been followed in the past to promulgate the exemptions which currently exist in the Comission's regulations.
You also may be aware that the Commission is in the process of developing a policy statement thatwould identify the principles and criteria that govern l
Commission decisions which could exempt radioactive material from some or all regulatory controls. This policy was the subject of the enclosed advanced notice (Enclosure 2)'and would' apply not only to waste disposals but also to all our decisions which would allow material with a very low level of radioactivity to be released to the environment or to the' general public. We received over 250 coment letters on this notice, and we have given the issues and questions raised in these letters serious consideration in our policy development efforts.
I believe that it is this kind of careful deliberation on the issue of exemptions recomended by your constituents.
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In the Act, the Commission was specifically directed to determine whether the
"... concentration or quantity of radionuclides present in such (BRC] waste stream requires regulation by the Commission in order to protect public health dnd saf ety." Thus, any exemption decision must assure that there Continues to be adequate protection of puslic health and safety. Our goal is to operats under policies that optimize the effectiveness of our public health and safety-resources while assuring that there are no resultant unacceptable risks to the public.
a Finally, I would point out that, while radiation protection policies have
. conservatively ) resumed that any level of radiation exposure involves risk, the recent study, "iealth Effects of Exposure to Low-Levels of lonizing Radiation,"
BEIR V, issued by the National Research Council, points out that "... the possibility that there n.ay be no risks from exposures comparable to external natural background radiation cannot be ruled out." As you know, everyone i
routinely receives exposures from a variety. of sources of radiation, including i
radiation naturally occurring within our own bodies. 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 estinated by the National l
Council of Raciation 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 and its decay prcducts, while meaical exposures, such as x-rays, when averaged over the U.S. population, contribute an estimated 53 millirem per year. -Other man-made sources contribute the remaining 1 to 2 percent of the total exposure, including nuclear falicut and nuclear power plant effluents.
I am gesenting this total exposure " picture" to arovide a perspective cn the hypothetical risks which may be associated witi very low levels of radioactivity that is associated with potential FRC waste disposal. practices.- Any exposures from-1 such practices are expected to be a small fraction of the total received annually by any individual. The I;RC believes this relative risk perspective is relevant to its decisions to allocate its regulatory resources to control the potential radiological risks associated with the use of radioactive materials, i
in conclusion, I want to assure you that we take our mandate to protect the health and. safety cf the public very seriously.
As a result, we will continue to do our best in carefully and clearly responding to issues.and questions raised by you, and by concerned citizens.
1 Sincercly,
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a mes P xecutive Director for Operations
Enclosures:
- 1) i;RC Advanced hotice of Folicy NRC Statement of Policy and Procedures b
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