ML20043E535

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Carr Response to Bevill Subcommittee on Energy & Water Development Question 22 for 900327 Hearing
ML20043E535
Person / Time
Issue date: 03/27/1990
From: Carr
NRC COMMISSION (OCM)
To: Bevill
HOUSE OF REP., APPROPRIATIONS
References
BEVILL-900327, CCS, NUDOCS 9006130099
Download: ML20043E535 (2)


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%00ff MR. BEVILL:

Why is there a need for rulemaking on "below regulatory concern" waste and what is the maximum ~public exposure to radiation with and without the rule? Please compare this to' exposure f rom natural radi6 tion.

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CHAIRMAN CARR:

The need for rulemaking on "below reguletory concern" waste disposals is both explicit in the directives contained in the Low-Level Radioactive Waste Policy Amendments Act and implicit in the need to establish a consistent framework for making decisions on exempting certain' quantities or concentrations of radioactive material from further regulatory control.

Illustrative of this need, is that one of the most significant lessons learned from the Shippingport decommissioning project was the need for the establishment of criteria for the release of materials for unrestricted use.

Current NRC regulations address only specific types cf waste, for example, biomedical, or require case-by-case approvals.

NRC regulations in.10 CFR 20.302 require individual licensees to apply to the Commission for approval of-proposed procedures to dispose of licensed material in a manner not otherwise suthorized in the regulations. The regulations do not currently provide sptcific criteria for approval of "below regulatory concern" waste disposals.

Conequently, such approval would have to be addressed on an case-by-case i

basis tupported by a separate detailed technical justification developed by,

each licensee who requests such actions.

l The maximum public exposure to radiation from disposal of BRC waste in an t

I l

unlicensed facility would not exceed a small fraction of the public dose limit. The dose limit set forth in 10 CFR Part 20, specifically 500 millirem per year in the current 10 CFR Part 20, and 100 millirem per year in the final revisions to Part 20, which are currently under Commission consideration.

The.

Comission currently is considering a 10 millirem per year individual dose l

criterion for BRC purposes.

If this criterion, as well as other policy conditions and constraints is met in any licensing action or rulemaking, the l

l Comission believes that the human health and the environment will be adequately protected while, at the same time, allowing limited national resources to be 900613009 CONG ++ss,9 900327 p[}I BEVILLO22 Question 22/Bevill/RES PDC 03/27/90

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-2 focused on those risks with greatest potential impact on public health and safety. This criterion would be used to make regulatory decisions in a consistent manner as to whether exemptions were granted by rulemaking or on a case-by-case basis.

Exposures occur from radiation that is natural in origin as.well as from sources which involve man-made uses of rar.iation and radioactive material.

The National Council on. Radiation Protection and Measurements, NCRP Report No. 93, has estimated that the total effective dose equivalent received by each person in the United States averages about 360 millirem per year. Of this total, about 300 millirem per year, or about 83 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 when averaged over the nation's population. Other man-made sources contribute the remaining 1 to 2 percent of the total exposure.

Thus, if disposal of BRC waste were carried out in accordance with a 10 millirem per year individual dose criterion the additional exposure would be less than one-thirtieth of the average exposure presently r(ceived on average by all members of the U.S.

population.

i Question 22/Eevill/RES 0.'/27/90

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