ML20044A668
| ML20044A668 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Graham B SENATE |
| Shared Package | |
| ML20044A669 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9007020033 | |
| Download: ML20044A668 (2) | |
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May 16, 1990 The Honorable Bob Graham United States Senator P.O. Box 3050 Tallahassee, FL 32315
Dear Senator Graham:
I am resoonding to your letter of April 18. 1990, which requested our consideration of issues raised by your constituent, Ms. Mary C1 Dougherty. Ms. Dougherty's concerns involve the disposal of low-level radioactive wastes and, in particular, those wastes characterized as "below regulatory concern" or "BRC."
IwouldfirstnotethattheNuclearRegulatoryCommission(NRC)hasnot published an waste (LLW) y proposed regulations which would allow disposal of low-level under the BRC provisions of the Low Level Radioactive Waste Policy Amendments Act of 1985 (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 outlines the criteria for considering such petitions.
I have enclosed a copy of the statement which you may find useful in responding to Ms. Dougherty (Enclosure 1).
Besides this 1986 policy, the Commission continues to be. active in pursuing the development of a broad policy that would identify the principles and criteria that govern Commission decisions which could exempt radioactive material from some or all regulatory controls.
This broad policy, the subject of the enclosed i
advance notice (Enclosure 2), would apply not only to BRC waste disposals but -
1 also to other decisions which would allow licensed radioactive material to be released to the environment or to the-general public. Thus..the policy would l
also provide the basis for decommissioning decisions involving the release of lands, structures, or recycled materials for unrestricted use as well a:
decisions regarding consumer product exemptions.
We believe the nation's best interests would be 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 would also contribute to the l
focusing of our limited national resources on those risks with greatest potential impact on public health and safety.
l In further addressing Ms. Dougherty's concerns regarding potential BRC waste disposals, I would point out that any LLW considered to be "below regulatory concera" under the provisions of Pub.' L.99-240 would only involve nwterials l
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.
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The Honorable Bob Graham 2
It may be also helpful to suunarize 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 estinated by the National Council on Radiation Protection and lieasurements (llCRP Report flo. 93), the ef f ective dose equivalent received by an average individual in the United States Of this total, over 83 percent p(opulation is about 360 millirem per year.about 300 millirem per year) is e result of na and its decay products, while medical exposures such as x-rays when averaged over the U. S. population, contribute an estimated 15 percent 53 millirem per year). Other man-mode sources, including nuclear fallout, contribute the remaining 1 to 2 percent of the total exposure.
The remaining 1 to 2 percent i
also includes the contribution from nuclear power plant effluents.
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 Coninission believes are relevant to itt, decisions involving regulatory resource allocations to control the potential radiological risks associated with the use of radioactive materials, in closing, I want to acsure you that we take our mandate to protect the health and safety of the public very seriously. As a result, the concerns expressed by your constituent are among those that we must carefully consider and address as we carry out our regulatory mission.
Sincerely, I
3 I
ecutive rector for Operations
Enclosures:
- 1. Final Policy (51 FR 30839)
- 2. Federal Register (53 FR 49886) l t
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