ML20042F947
| ML20042F947 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Humphrey G SENATE |
| Shared Package | |
| ML20042F948 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9005100211 | |
| Download: ML20042F947 (2) | |
Text
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l UNITE D STATES l'
NUCLE AR REGULATORY COMMISSION i
psmuovow. o. c. rom
....+
April 4, 1990 i
i The Honorable Gordon J. Humphrey United States Senate 1
Washington, DC 20510
Dear Senator Humphrey:
i
! am responding to your letter of March 10, 1990, which requested our.
consideration of issues raised by your constituents Messrs. Ben and Jackson Daviss. The Daviss' concerns involve the disposal of low-level radioactive wastes specifically, those wastes characterized as "below regulatory concern" 4
or *BRC."
I would first note that the h'uclear Regulatory Commission (NRC) has not published any proposed regulations which would allow disposal of low-level waste (LLW) under t3e BRC provisions of the low-Level Radioactive Waste. Policy Amendments Actof1985(Pub.L.99-240).
However, 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 out.ines the criteria for considering such petitions.
I have enclosed a copy of the statement which you may find useful in responding to your constituents (Enclosure 1). We are aware that the nation's nuclear power utilities are preparing such a petition but, to l
date, this petition has not been submitted to us.
Besides this 1986 policy, the Commission continues to be active in pursuing the development of the policy that would identify the principles and criteria that govern Commission 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 but also to other decisions which would allow licensed radioactive material to be released to the environment or to the general public.
The Commission'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, although applicable to BRC waste disposal, would also provide the basis for decomissioning decisions involving the release of. lands, structures, or L
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 the focusing of our limited national resources on those risks with greatest potential impact on public health and safety.
' W.p'
^
9905100211 l
FDR ORO hDC 1
.The Fronorable Gordon J. Humphrey 2
In addressing the Daviss' 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 f raction of natural background radiation that it may not be readily detectable.
It may be also 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 milliree 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 n.edical 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 potential BRC waste disposal practices. This perspective is one of several that 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 again want to assure you that we take our mandate to protect the health and safety of the public very seriously.
As a result, the Daviss' concerns are among those that we must carefully consider and address as we carry out our regulatory mission.
Sincerely, d
a y
.ecutive Di ector for Operations
Enclosures:
1.
Final Policy (51 FR 30839) 2.
FederalRegister(53FR49886)