ML20055C941
| ML20055C941 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Cranston A SENATE |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 CCS, NUDOCS 9007020116 | |
| Download: ML20055C941 (3) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION g
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May 7, 1990 l
The Honorable Alan Cranston United States Senate Washington, DC 20510
Dear Senator Cranston:
i I am responding to your,_ letter of March 30, 1990, which requested our consideration of issues raised by your constituent, Barbara L. Clutter, M.D.-
Dr. Clutter's concerns involve the disposal of low-level radioactive wastes i
and, in particular, those wastes characterized as "below regulatory concern" or "BRC."
Her concerns, therefore, are similar but somewhat more specific than 4
those raised by Mr.. A. W. Merrill, which you also forwarded for our review and
. consideration on April 4, 1990.
Because your letters were received so close together in-time, I'will repeat and add upon the views I provided in my earlier April 18, 1990 response.
I would again note that the Nuclear Regulatory Commislion (NRC) has not waste (LLW) y proposed regulations which would allow itisposal of low-levelunder th published an Amendments Act of 1985 (Pub. L.99-240). However, tho 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 again find useful in responding to Dr. Clutter (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 advance notice (Enclosure 2), would apply not only to BRC waste disposals but also to other decisions which would allownlicensed radioactive material to be released to the environment or to the general public. Thus, with regard to Dr. Clutter's concerns listed under Items 3, 4, and 5 in her letter, the policy
- would provide the basis for decisions regarding acceptable limits on the type and concentration of radioactive materials.that would be in consumer products, including the Commission's rationale on whether radioactive material, at any level, is permitted in items such as children's toys. The policy would also provide the framework for developing guidance on what quantities and concentrations of radioactive material could be subjected to incineration processes. And with regard to the contaminated sites, rather than preventing cleanup, the policy would provide the basis for determining if the necessary degree of cleanup has Q
'been achieved which would allow these sites to be released for public use. We I\\
9007020116 900507 PDR PR FULLTEXT ASCll SCAN \\
CHP1 53FR49886 PDC
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The Honorable Alan Cranston 2
believe the nation's best interests would be served by a policy that esteolishes a consistent risk f ramewor6 within which esemption cecisions can be made with assurance that human health anc the environment are protected.
Such e policy would also contribute to the focusinc of our limited national resources on thot,e risks with greatest potential impact on public health and safety.
U In addressing Dr. Clutter's specific concern regarding potential BFC waste disposals, I would point cut that any LLW considered to be 'below regulatory concern
- under the provisions of Pub. L.99-240 would only involve r%terials with the lowest level of radioactivity content, in f act, the leni of radio-activity for sorte potential BRC wastes may be such a smeli fruction of natural background radiation that it may not be reaoily detectabic.
As a result,19 response to Dr. Clutter's item 2 concern, any exposures received by sanitation, transportation, and waste treatment and disposal workers would la small eno not approach a significant fraction of the current public dose limit.
In response to Dr. Clutter's first concern, if any Jotential BRC waste disposals or other exemptions are approved by the Commission, assurance would be provided that when considered individually or collectively, no significant increase would occur in the background levels of radiation, finally, in response to Dr. Clutter's concern expressed in her item 6, the potential for multiple exempted practices, including any concentrations of BRC waste disposals at one landfill, would be an important consideration if and when such regulations are developed Md promulgated.
To further understand the levels of potential exposures which could be received from radioactive material exempted under a BRC or exemption policy, it may be helpful to summarize the typical exposures which we all routinely receive f rom a variety of sources of radiation, lhese exposures occur f rom radiation that is natural in origin as well as from sources which involve man-rede uses of radioactive material.
In total, as est1 mated by the National Council on Radiation Protection and Measurements (NCRP Report ho, 93), the effettive dose equivalent recehed by an average individual in the United Sta*ts population is about 360 mill 1 rem per year.
Of this total, over 83 perceM iabout 300 millirem per y"ar) is a result of natural sources, including redon end its decay products, while tredica l exposures such as x-rays, when averaged over the U. S. population, contribute an estimated 15 percent (53 millirom per year).
Other man-made sources, including nuclear fellout, contribute the remaining 1 to 2 percent of the total exposure.
The remaining 1 to 2 percent also includes the contribution from all nuclear fuel cycle plant effluents (conservatively estimated at less than 0.1 percent).
I believe this total exposure " picture" provides a perspective on the hypothetical risks which may be associated with potential BRC waste disposal practices. This perspecthe is one of several th6t the Commission belicves are relevant to its decisions involving regulatory resource allocations to control the potential r6diological risks associated with the use of radioactive materials.
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4 The rionorable Alan Cranston 3
in closing, I again want to assure you that we take our rnandate to protect the health and safety of the public very sericusly. 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,
%, W 4ks M. Tay r xecutive Director for Operations
Enclosures:
- 1. Final Policy (51 FR 30839) 2.federalRegister(53FR49886)
- 3. Package Incoming Material t
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A!.AN CRANS70N CALE O.Muea
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H aited S tates $ tnatt WASHINGTON. DC 20510 March 30, 1990 To:
Congressional Liaison Nuclear Regulatory Commission 1711 H Street, N.W.
Washington, D.C.
20896 Inquiry from:
Dr. Barbara L. Clutter 1941 Johnson Avenue, Suite 202 San Luis Obispo, California 93401 Re Please respond to me regarding my constituent's concerns about the policy to allow radioactive wastes to be classified as Below Regulatory Concern.
I forward the attached for your review and consideration.
Your report, in duplicate, along with the return of the enclosure, will be appreciated.
The response should be directed to the attention of Colleen Sechreat in my Washington office.
Thank you for your attention to this matter.
S elyA,t Enclosure a
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January 24, '390 State Senator Alan Cranston 112 Hart Office Bldg.
Washington, DC 20510 Dear Senator Cranston Recently I have become aware of a new policy by the Nuclear.
Regulatory Commission and Environmental Protection Agency to allow certain radioactive wastes to be classified as Below Regulatory Concern (BRC) and to be mixed with other regular wastes in landfills or dumped into sewage systems or incinerators or even taken to recycling centers.
The concerns I have are as follows:
1.
Mixing radioactive waste with our other waste products will itsevitably increase background radiation levels year by year and thereby likely increase risks of cancer, birth defects, and other healtr problems.
2.
Sanitation, transportation, waste treatment and disposal workers could come into daily contact with radioactive waste without their knowledge or consent.
l 3.
Incinerators could etart burning radicactive wastes, l
releasing radiation inte the air and generating radioactive ash.
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Radioactive materials could be reeveled and used in consumer products.
(Imagine having ' children's toys manufactured from radioactive recycled metal.)
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January 24, 1990 Tot Senator Alan Cranston Page Two 5.
Cleanup of contaminated weapons plants, nuclear reactors, and other radiation facilities will never be completed if the Beyond Regulatory Control (BRC) policy is implemented.
Instead, the government and the utilities will simply declare these sites clean--even though radioactive contamination will continue to exist.
6.
Even though the government has reason to believe that the amount of radiation in the BRC waste is at present not worth tracking, it is possible that such radioactive waste could be concentrated in one landfill or incinerate >r, etc.,
making the concentration high enough to be of considerable danger.
I would like to see this policy to deregulate radioactive waste rescinded.
I urge you to sponsor a bill prohibiting the reclassification of radioactive waste as "Below Regulatory.
Conce rn. "
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Barbara L. Clutter, M.D.
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