ML20044A742
| ML20044A742 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Gallegly E HOUSE OF REP. |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9007020163 | |
| Download: ML20044A742 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION n
h WASHINGTON, D. C. 205$5 May 3, 1990-l The Honorable Elton Gallegly United States House-of Representatives Washington, DC 20515-
Dear Congressman Gallegly:
I am responding to your note of April 3,1990, which requested our.
consideration of issues raised in a letter from one of your constituents.
.The concerns involve the disposal of low-level radioactive wastes and, in particular, those wastes characterized as "below regulatory concern"'or "BRC."
I would first note that the Nuclear Regulatory Commission-(NRC) has not:
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 t.mendmentsActof1985(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 your constituent (Enclosure 1).
Besides this 1986 policy, the Comission 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 advance notice (Enclosure 2), would apply.not only-to BRC waste disposals but also to other decisions which would allow licensed radioactive :naterial to be released to the environment or to the general public. -Thus,=the policy 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 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 focusing of our limited national resources on those risks with greatest potential impact on public health and safety.
FULLTEXT ASCll SCAM 90070?O 63 900503 l'
SOM YDC w
The Honorable Elton Gallegly 2
In further addressing your constituent's concerns regarding potential BRC waste disposals, 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 fraction of natural background radiation that it may not be readily detectable.
Your constituent's letter also refers to "... studies that show that so called low-level radiation is much more hazardous than previously believed."
This conclusion may be based on estimates recently made by the United Nations Scientific Comittee on the Effects of Atomic Radiation (UNSCEAR) and the National Research Council's Comittee on the Biological Effects of Ionizing Radiation. This latter Comittee has recently issued a report, " Health Effects of Exposures to Low Levels of lonizing Radiation," comonly referred to as the BEIR V report. The estimates made by these bodies were based primarily upon the Japanese atomic bomb survivors and pertain to the high doses and dose rates associated with those exposures. The dose levels, which would be associated with practices such as BRC waste disposal, are significantly smaller than those received by the bomb survivors.
In fact, because these doses are a small fraction of natural background exposures, there is no direct evidence upon which risk estimates at such doses may be based. As a result, the Comission has used advice from various scientific comittees, including UNSCEAR, BEIR, and the National Council on Radiation Protection and Measurements, to extrapolate the risk estimates applicable to the bomb survivors to the values used at low doses and dose rates for the purpose of establishing exposure limits to the public. The Comission is also using these estimates and other relevant information in formulating its exemption policy.
It may be also helpful to sumarize 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 an average individual in the United States p(opulation is about 360 millirem per year.about 300 millirem per year) is a result of natu Of this total, over 83 percent and its decay products, while medical exposures such as x-rays, wnen averaged over the U. S. population, contribute an estimated 15 percent (53 millirem per year). Other man-made sources, including' nuclear fallout, contribute the remaining 1 to 2 percent of the total exposure. The remaining 1 to 2 percent 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 Comission believes are relevant to its decisions involving regulatory resource allocations to control the potential radiological risks associated with the use of radioactive materials.
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The Honorable Elton Gallegly 3
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 your constituent are among those that we must carefully consider and address as we carry out our regulatory mission.
Sincerely,
/
i g
xecutive trector for Operations
Enclosures:
- 1. Final Policy (51 FR 30839)
- 2. Federal Register (53 FR 49886)
- 3. Incoming Material
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I Congress of tilt Entith 9tates-liouse of Espresentattues i
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Sir / Madam:
The attached communication is sent for
- your consideration. Please investigate the statements contained therein and forward me.
the necessary information for reply, return-ing the enclosed correspondence with your answer.
Yours truly, 4
M.C.
[
Congressman Elton Gallegly 107 Cannon H.O.B.-
. Washington, D.C. 20515 d
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E;To?the Honorable Elton Gallegly:
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Dear Mr. Gallegly,
1 I have just'been informed that the Nuclear Regulatory Commission liEi planning to reclassify certain low-levelLradioactive vastes.
Their new-listing would be "Below, Regulatory Concern" allowing the nuclear indust to dispose of them-like everyday garbage.
As my Representative in Congress I am urging you to protect people from this radioactive trash.
I have read reports recently which have o
p' included studies that show that so called low-level radiation-is much l
more hazardous than previously-believed.
Please do whatever you possib]
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can to stop this nonsensical plan.
Sincerely, N
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