ML20055H725
| ML20055H725 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Geoffrey Miller HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20055H726 | List: |
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9007270197 | |
| Download: ML20055H725 (26) | |
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'o, UNITED STATES
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NUCLEAR REGULA10RY COMMISSION e
WASHINGTON, D. C. 20566 f
Ouly 20,1990 CHAIRMAN The Honorable George Miller Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representa+ives Washington, D. C.
20515 t
Dear Congressman Miller:
Your letter of July 10 1990, requested the Nuclear Regulatory Comnission's responses,to a number of questions related to the Below Regulatory Concern policy as background for the July 26, 1990 Subcommittee hearing.
Enclosed are the responses to those questions.
Sincerely, J
Ws 2:
Kenneth M. Carr
Enclosure:
As stated cc:
Rep. Morris K. Udall Rep. James V. Hansen t
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9007270197 90072n PDR CORRESPONDENCE PDC D Fo 2-COMM9 NRCC ii il
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OUEST10N 1:
A listing of examples of specific practices that the.
.r Comission might decide to exempt from some or all regulatory-controls.
ANSWER.
The Commission has exempted specific practices on a case-by-case basis for over 20 years. The purpose of the BRC policy statement is 'to provide a basis for consistent exemption decisions. Examples of. practices and materials that the Comission might decide to exempt from some or all regulatory controls
'are:
a.
Release for unrestricted public use of individual decomissioned buildings or sites which may have very small but detectable levels of
' radioactivity. New rules will replace existing guidance and provide release limits based on_ a consistent 1evel of risk.
- b. ' Distribution of new consumer products which contain small quantities of radioactive material.
Smoke detectors and luminous wrist watches are examples of currently authorized produc.ts.
- c. - Disposal of slightly contaminated waste. Currently authorized examples are biomedical wastes containing slightly contaminated scintillation fluids and animal tissues from medical research.
The Comission also has petitions pending which request authorization for disposal of slightly contaminated wastes from medical laboratories and slightly contaminated wasto oil from nuclear power plants.
Such wastes may still be subject to requirements associated with their nonradiological properties.
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sQUESTION1.(Continued)-
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d... Recycle of slightly contaminated materials'. Limited recycling on a
- case-by-case ' basis has been authorized in the past. An example is the recycle of' calcium fluoride contaminated with slight amounts of l
uranium generated in the manufacture of nuclear fuel which.is subsequently used in a' steel-production process..The proposed application of the recycled material would be considered as part of.
.i the exemption: review.
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.,7 QUESTION 2.
'An estimate of the_ number ~of exempted practices that might f
be authorized pursuant to the BRC policy.
ANSWER.
The.anteer.to Question 1 identified exarapies of specific practices that the Commission might decide to exempt from some or all regulatory controls..
While it is not possible to estimate with any precision the number of requests for exemptions.and the number of practices that might be exempted under the BRC policy, we have no reason to believe that the need to make such decisions will cease or decrease in the near future. We have made a planning:
estimate that one new petition for exemption will be received in each of the 1
l next 5 years. On this basis, between 0 and 5 new exempted practices might be j
. authorized pursuant to the-BRC policy by 1995.
Of course.we will adjust'our resource allocations accordingly if the number of new petitions actually-l received is higher or-lower. Further, the Commission intends to define i
practices broadly, and thereby limit the potential for cumulative exposures f
l from multiple exempted practices.
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CUESTION 3.
Analyses that the Commission used.in balancing the
. decreased costs resulting from exempting certain practices from regulatory controls against the adverse health consequences specified by Comissioner Curtiss in his e
o Additional Views.
ANSWER.
U The basis for the BRC policy does not include' analyses. balancing the j
potential decrease'in costs resulting from exempting certain practices from q
regulatory controls against the hypothetical health consequences' associated with exemptions.
Rather the policy provides a risk level below.which the Comission believes.its radiaticn protection resources and those. of its licensees.can be better directed at more.important health, safety and environmental concerns.
Below this level, attempts to further reduce'the small levels of risk associated with an exempted practice are not.needed.
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i QUESTION 2:
A statembot describing the number of' agency staff-hours expended during FY 1988, FY 1985, and~FY 1990'on' regulation of practicet'and materials that could be exempt from-i 1
regulation under the BRC' policy.
ANSWER.
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The past resources that were expended on the regulation of practices'and j
materials that could be exempted under the BRC policy cannot be specifi-cally determined for the following reasonsi
'1 The specific practices and materials that could be exempted under th'e BRC policy will be based on petitions for exemptions, as well-as th'e review and i
revision as appropriate to existing regulations and exemptions.- At this time,_
we do not know the number or. type of petitions that the NRC will receive.
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s addition, it is difficult to determine what activities during this past period
' ould have been directly related to the new BRC policy since certain w
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. exemptions and activities, although BRC related, would have occurred with or without the BRC policy. For example, although the NRC will develop regula-tions and guidance for acceptable soil contamination levels using the new BRC pol!cy, such regulations and guidance would still need to be developed if the policy had not been issued. New regulations and guidance based on the BRC-policy will provide a consistent level of protection for decomissioning and other exempted practices. Also, current accounting of regulatory resources j
- does not permit a detailed quantification of resources that have spent for the specific activities that could be exempted from regulation under the BRC policy.
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-QUESTION 5:-
A statement describingLthe number of agency staff-hours.that, under pre-BRC policies, are projected to be expendedLin each
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Fiscal Year in the decade beginning in FYl1991 on the regula-tion'of practices and materials that could be. exempt.from regulatien_ under the BRC policy.
- ANSWER.
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In FY 1991, approximately 340,000 direct ~staffhours(160FTE)-areproject'ed to be expended annually for the entire nuclear materials regulatory program.-
Some percentage of these hours.would be'used for regulating practices and materials that could be exempt-from regulation under-BRC policy. As indicated.
in the response to Question 4, the specific fraction of these resources that could be affected by the BRC policy cannot be determined until implementing regulations'and guidance are completed.
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. QUESTION 6:
A statement, describing the number of agency staff-hours that,.under BRC policy, are projected to be expended in each Fiscal Year:in the decade beginning in FY 1991 on.
f the implementation of the-BRC policy and regulation.of practices and materials.that could be partially exempt l
from regulation under the BRC policy.
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. ANSWER.
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-i Over the first five years of the decade beginning.in.FY 1991, approximately 1
h 9,000 additienal staff hours (4 FTE) per year.are planned for BRC activities duc to the r.ew policy. Incse resources are planned to complete.a systematic assessment'of all existing exemptions to ensure consistency with the policy, development of. regulatory documents (rules, regulatory guidance) for b
consistent implementation of the policy, and evaluation of'at least one new
-l petition for exemption per year.
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It should be pointed out, however, that while difficult to quantify, costs i
would be incurred by continuing existing practice in the absence of a
- consistent, risk-based approach to guide decisionmaking. We expect the BRC policy to lead to a more efficient use of agency resources in reaching these decisions.
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- Additionally, it should be emphasized that because this Policy Statement provides a comprehensive, risk-based framework for reaching decisions, the l
g hoc practice of the past -- where individual decisions were reached, p
of tentimes without any agency-wide coordination or comon risk benchmark --
l will be replaced by a more coordinated and consistent approach, c
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i QUESTION 7 For each Fiscal-Year in the decade beginning in FY 1991-of.
c costs, an enumeration of costs that'might not be~ incurred-by l'icensees and others involved in handling lof radioactive-materials ~as a' consequence of promulgation of the'BRC policy.
.-r ANSWER.
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As pointed out. in previous responses, we cannot enumerate the resources that-o L
- might be' saved by licensees and others as a consequence of the BRC policy.
1 Such savings, if any, would be dependent on the circumstances' associated with t
the specific rulemaking developed for the exemptionlor those associated with' the license.for-which a specific exemption might be granted.-
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e QUESTION 8:
How many NRC non-react r licensees currently generate low-level radioactive waste? How many on-site inspections '
.did NRC personnel cor. duct of these licensees in 19897-How many of these licensees.have not;been subjected to an on-site inspection over the past two years, three years and 1
four years?
l ANSWERe i
.Anyone who.uses radioactive material is a potential generator of low-level radioactive waste.
Currently, NRC has approximately 8,000 specific licensees-and 35,000 general licensees.
NRC' inspects most of its-specific licensees on
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prescribed frequencies ranging from one to five years based on the potential-risks of their licensed activities. A few categories of specific. licensees are-inspected only.in response to problems.
In FY 1989, NRC conducted 2,740_
inspections of specific licensees. Of.the 8,000 specific licensees,.about 1,420 have not been inspected in the last four years, 2,360 in the last three' years and 3,750 in the last two years.
J General licensees are normally inspected only in response to problems because of the relatively low level of risk involved.
However, during the past year 22,000 telephone contacts were made with general licensees to obtain informa-tion about.the-status of material in their possession.
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'0UESTION 9:-
How many agency FTE were expended in FY 1989 on inspections -
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of non-reactor licensees to' ensure compliance with low-level waste disposal regulations?
ANSWER.
'In FY 1989 the NRC expended approximately-100 FTE for fuel facility and materials (non-reactor) licensee inspections. -Routine materials inspections cover a broad range of aspects, including review of low-level waste stort.ge, packaging, transfer, and disposal.= However, inspection resources are not maintained in such a way that we can determine the level of resources devoted specifically to low-level-waste disposal inspections. All three of' the licensed LLW disposal facilities are located in Agreement States, and NRC has issued licenses for the disposal of wastes containing special nuclear material at the facilities at Barnwell, South Carolina, and Richland, Washington.
NRC inspects NRC licensed disposal activities at each of these sites at least once a year.
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' QUESTIONS 10; According to the Environmental Protection: Agency's February 2,
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- AND 11, 1989;coments
- on the NRC's Advanced Notice concerning the BRC 1
' policy, the EPA, not the NRC, has' the p.rimary federal _
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- q responsibility > for regulating offsite levels of. radiation.
o In addition, it-is 'my understanding th'at' EPA, not the !!RC, m
has the' authority to determine acceptable levels of radioactive
- r contamination in soil.
In light of-the above, why has NRC i
issued the below regulatory concern' policy (BRC) without-4 support'of EPA?
How can the NRC effectively implement the BRC policy for
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wastes and decomissioning before EPA has determined "how~.
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clean is clean" as it applies to radioactive contamination-in soil? If the'NRC implements BRC before an EPA standard is established,.is it possible that materials and' sites-deemed BRC by NRC will;not meet EPA standards?
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g ANSWER l
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t' Under'the. Atomic Energy Act, as amended, the NRC has the authority to exempt.-
1 radioactive materials from regulatory control. Exemption decisions are:an essential-part of-our regulatory program.
In recognition of this, over the past seven years-we have pursued with EPA.the development of uniform federal standards to guide such exemption decisions.
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NRC has the authority and responsibility to establish levels of radiation that 4
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OVESTION-10/11. (Continued) ~ 57d,'62, and 81 of the Atomic Energy Act.
Additionally, section 10 of the Low-Level Radioactive Waste Policy Amendments Act of 1985 specifically directs the NRC to develop standards and procedures for making BRC exemption decisions for low-level radioactive waste.
Under Reorganization Plan No. 3l Lof 1970, the functions under the Atomic Energy Act of establishing generally applicable environmental standards for protection of the environment from
' radioactive materials was transferred to EPA. Ilowever, the specific authority to exempt' materials from regulation-in sections 57d, 62, and 81 of the Act was rot transferred to EPA. Any actions that NRC might take pursuant-to these sections would need to be consistent with any applicable general environmental standards that EPA may issue under the Atomic Energy Act.
NRC issfaced, on a day to day basis, with making the kind of exemption decisions covered by the BRC policy.
We have been making these types of decisions for the past 20 years and have no reason to believe that the need to i
make such decisions will cease or decrease in the near future. Such decisions are an essential part of a regulatory program of any agency charged with ensuring the safety of the American public.
Federal and State agencies have developed and implemented similar exemptions. The FDA, for example, applies risk-based guidelines in regulation of food additives and contami-nants. Similarly, EPA applies exemption or threshold levels in the regulation of pesticides, and other toxic and carcinogenic chemicals.
One-example is the need to make decisions on when to terminate licenses for activities that use radioactive materials. These decisions involve judgments
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. QUEST!0N.10/11.(Continued)' I t
on' "how clean is clean enough," for which uniform, generally _ applicable.
federal standards have not yet been established..'Despite the absence of such
- standards, the NRC has made cleanup decisions ' sing as benchmarks 10 CFR u
Part 20 " Standards for Protection Against Radiation;" Regulatory Guide 1.86;.
" Guidelines for_ Decontamination of Facilities and Equipment Prior to the Release for Unrestricted Use' or Termination of Licenses for Source, Special Nuclear, or Byproduct Material;" the "as low as reasonably achievable" (ALARA) principle; conservative, state-of-the-art risk assessments; and the sensi-tivity levels of radiation detection instruments. The BRC policy provides the basis for achieving a consistent level of protection for-such cleanup decisions in.the future.
At reflected in testimony last year before the House Subcommittee on Environment, Energy and Natural Resourc'es of the Committee on Government
.0perations, efforts to establish uniform, generally-applicable standards for-1 clean-up have been considerably delayed as-a result of higher priorities at EPA.
In~the meantime, we established and implemented general requirements'for decommissioningnuclearfacilities-[53FederalRegister24018].
In accordance
' with these requirements by July 27,1990, certain licensees will be required 1
to certify their ability to pay for cleanup and deccumissioning in proportion to anticipated costs.
In order to ensure the adequacy of these certifica-tions, we need to establish safe levels of residual contamination.
x; Accordingly, we have been working for the past several years to develop regulatory guidance and the basis for a rulemaking to establish these levels.
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- QUESTION 10/11.(Continued),
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-We recognize the possibility that EPA could set a more stringent standard than I
r the one used in past or current decommissioning projects and, therefore, that i
NP.C would have to revisit these decisions. However, we still need to'make cleanup and decommissioning decisions even in the absence of uniform,-
t generally applicable federal standards.
Based on current EPA projections, we i
do not expect that these standards will be established until the mid to late 1990s. We will, of course, continue to work with EPA to develop such L
standards 'to ensure protection of the public health and safety and the
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OUESTION 12.
What is the lifetime risk'of death-from a radiation-induced-cancer from an individual radiation dose of 100 millirem per year,10 millirem per year, and 1 millirem ~per' year?
ANSWER.
The hypothetical lifetime risks of death by radiation-induced cancer as a function of a continuous 70 year dose are estimated in Table 1 of the Policy Statement; namely,100 millirem per year - 3.5 x 10-3 (approximately 3 chances in a thousand); 10 mii14 rem per year - 3.5 x 10'4 (approximately 3 chances in:
d ten thousand); and 1 millirem:per year - 3.5 X 10-5 (approximately 3 chances in.one_hundred thousand).
However, as pointed out in the recent report,
" Health Effects of Exposure-to Low-Levels of Ionizing Radiation". authored by the. National.Research Council's Committee on the Biological Effects of Ionizing Radiation (oEIR V), "...epidemiologic data cannot rigorously exclude b
theexistenceof.athreshold[fordoserelated.healtheffects]inthe mil 11 sievert [(100 millirem)] dose range.
Thus, the possibility that there may be no risks from exposures comparable to external natural background W
- radiation cannot be ruled out."
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'QUESTI0fl13.
Please provide an estimate of~how many cancer deaths occur in the United States per year from exposure to background, radiation'(excluding indoor radon).
In addition, please
. provide an estimate of how many cancer deaths occur in-the; United States per year from exposure-to indoor radon.
ANSWER.
~ An estimate of the number of cancer deaths per' year in the United States attributed to exposure.to background radiation is highly uncertain. As stated in the BEIR V report, "No increase in' the frequency of cancer has been documented in-populations residing in areas of high natural background."-
Nevertheless, a conservative estimate'can be developed by multiplying the
-approximate U.S. population (250 million), the average background radiation; dose excluding radon (100 mrem per year) and the lat'ent cancer fatality. risk
' coefficient of 5:x 10 per rem for low doses and dose rates of low linear 4
energy, transfer radiation (derived from the BEIR V report using a dose rate-effectiveness factor of 2 for tumors).
Based on this calculation, a' hypothetical estimate of 12,500 annual cancer deaths would be attributed to.
background radiation excluding radon.
Radon has been estimated to cause an average additional exposure of 200 millirem per year effective dose equivalent. EPA has stated that, " Scientists estimated that from about 5000 to about 20,000 lung cancer deaths a year in the United States may be attributable to radon." BEIR IV provides an estimate i
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- I QUESTION 13.
of.13,000' deaths per year based on an extrapo_lation of information derived from uranium miners ' exposed to levels;much higher than background.
The estimates of death ettributable to natural background radiation including 1
radon would suggest that about 1 out~of every 15 cancer deaths in the United States could be caused by_ natural background radiation. To the best of our knowledge, no widely accepted scientific study exists which confirms this estimate.
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y, QUESTION.14.
The Comission's' letteriof June 29, 1990, states that the q-[
h individual dose criterion for the BRC policy was raised from-1 mrem per year to 10 mrem per year at the direction of Mr. Victor Stello, who was Executive Director for Operations-at the time this change was made to the draft BRC policy. LThe e
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letter states that Mr. Stello, "... questioned whether the,
.i proposed individual dose criterion value of 1 mrem /yr would provide sufficient flexibility in practical application of the i
poli cy. "
Please provide a full explanation _of Mr. Stello's. objections'to I
n; the 1 mrem /yr individual dose criterion and the rationale for i
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- increasing the individual dose criterion to 10 mrem /yr.
Please J
3 address the following questions in your explanation:
p At the time the individual dose criterion was raised L
rf l to 10 mrem, did the Comission share Mr. Stello's concern that the 1 mrem-individual dose criterion did n
not " provide sufficient flexibility in' practical application of the policy?"
a.
Why would an individual dose criterion of 1-arem/yr 4
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- not " provide sufficient flexibility in practical application of the policy?"
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-QUESTION 14. (Continued)- 4 Please identify what.if ~any, practices would be 1
more likely;to be exempted from regulation using-the 10 mrem /yr criterion rather than the-1 mrem /yr 1
criterion originally proposed by the NRC staff, if N
' ANSWEP.:
t As you are aware, Mr. Stello is presently employed by the U.S. Department of d
- Energy. :We did not' attempt to contact him to confirm the basis for his r
preference for the 10 mrem / year <criterico.
Based on our understanding of the-discussions surrounding the decision to increase the individual dose criterion-
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from.1 to 10 mrem /yr,.a 10 mrem /yr criterion was selected for several reasons.-
It-ensures'a safe and consistent level of protection for the-public.
It-is n
more consistent with-dose icvels previously established for site cleanup and 1
i decommissioning projects and it is feasible for implementatior in these i
applications;.In addition,- the cost of dose reductions below 10 mrem /yr may not be commensurate with the corresponding reduction.in risk.
At the time the decision was made in July and August of 1988, the staff had-developed a graded approach to guide regula+ory exemption decisions, including three individual' dose levels at.100, 10, and 1 mrem / year. This approach was based on the fundamental concept that the rigor of analyses required to t
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OUESTION14.-(Continued).
3-support an exemption would be reduced proportionally:as the individual dose decreases.
Between 100 and 10. millirem / year, exemptions would have to be
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. supported by a demonstration that both the individual a'nd collective doses were as low as reasonably achievable.
Below I mrem / year, the demonstration would be considerably less; demanding provided that the collective dose was I
below 100 or 1000 person-rem / year (both levels were considered in developing
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thepolicy).
Exemptions between 10 and 1 mrem / year wauld require an l
intermediate level of support.
-The 10 mrem / year criterion appeared to be the more appropriate value for the indivioual dose criterion because the distinction between exemptions at the-10 and 1-mrem / year level could.not be justified on a health and safety basis.
The level of effort required t', review analyses of dose reductions below 10
- mrem / year would not be babnced by the resulting decrease in risk considering the limited number of people who might'be exposed, let alone the effort required to assess the potential dose reductions and the actual implementation of the dose reduction features.
In addition, at the time-the 10 mrem / year criterion was selected, staff considered th'at a 10 mrem / year level would be more consistent with current practices involving the safe releases of radioactive materials to the environment.
For example, the 10 mrem / year value was generally consistent
'with effluent release guidance established by the NRC in 10 CFR Part 50,
. Appendix I for nuclear power reactor effluents, which was supported by a
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rigorous cost-benefit analysis. The 10 mrem / year level was also consistent 11
?, x QUESTION 14.(Continued) with cleanup levels used in decomissioning projects, such as the 5 microRoentgen/ hour level established for cleanup of reactor components containinggamma-emittingradionuclides(e.g., Cobalt-60).
Furthermore,-it was unclear whether cleanup levels based on an individual dose criterion of 1 mrem / year could be reasonably imposed on decommissioning projects because of technological limitations in the onsite detection and implementation of such' low levels, difficulties in distinguishing these. low-levels from natural background, large uncertainties associated with the health significance of these levels, and the large incremental increase in effort required to remove and dispose of such contamination. Translation of the 1 mrem / year or lower dose levels into the radiological field parameters used to guide decommissioning (e.g., microcuries per gram or disintegrations per minute per 100 square centimeters) would result in values for these parameters that would be difficult to detect and, thus, difficult to utilize and verify in cleanup projects.
This concern is exacerbated at sites with uranium, thorium, and radium contamination, where it may not be feasible to attain cleanup levels less than the 10 mrem / year criterion.
For perspective, EPA's cleanup criterion for radium-226 in contaminated soils at uranium mill tailings sites corresponds to a level of risk that is one hundred times larger than that associated with 10 mrem / year [ EPA 520/4-82-013-1].
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-QUESTION 14.=(Continued) Mr..Stello informed the~ Comission of his recomendation to adopt the ~
j 10 mrem / year criterion in a Comission paper dated September 9,1988
[SECY 88-257].. Even 'if he had not recomended 10 mrem / year, it is reasor,able I
to believe that the-Comission may have selected an individual dose criterion
. of 10 mrem / year considering the feasibility of demonstrating cleanup at lower
-levels and balancing the incrementa.1 reductions in health risk with'the large increase in regulatory burden.
In fact,'Mr. Stello provided=the recomendation specifically in response to a Comission request for " options for a Comission policy which establishes a generic number for exposures that are below regulatory concern" (see-March 30, 1988, memorandum from Samuel _
Chilk to Victor Stello). This Comission request'also directed the staff to consider "de, facto" BRC levels _ that appear in current NRC regulations, which have already been protecting the public for years.
No p actices wcyld be more likely to be exempted using the 10 mrem / year criterion rather than the 1 mrem / year criterion.
If the more restrictive I
level were established, it would just support lower release levels for exempted practices. However, as indicated above, the lower level may not be appropriate for such activities as decomissioning comercial nuclear facilities.
In addition, under the BRC policy, the Comission could approve l
exemptions in excess of the individual dose criterion provided that the proponent of the practice demonstrates that (1) the potential doses to individual members of the public are sufficiently small or unlikely,
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OLIESTION14.(Continued)
-6' (2)furtherreductions.indosesareneithersignificantintermsof. protecting the public health'and safety'and the environment nor readily achievable,.and
- (3) the-collective dose from the exempted practice is as low as' reasonably.
achievable.
Finally, it is important to recognize that the-final BRC policy does indeed adopt the 1 mrem / year criterion for practices involving widespread distribution, such as consumer products.-
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OUESTION-15.
The NRC's "Below Regulatory Concern" pamphlet contains the
-following statement:
l "Indeed. the NRC does not expect any measurable adverse impact on the public health' and' safety as a result of-the policy."
(underline added).
1 It is my understanding that the Environmental Protection Agency has estimated that thousands of:1ung cancers occur-every year in. the United States due to indoor radon exposure:
but no method has yet been devised to actually " measure" the number of dsaths are caused by radon exposure.
Does the use of-the word " measurable" in the NRC' pamphlet l-mean that the NRC expects that the policy will have adverse affects on public health and safety but that these effects will not be measurable?.
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. ANSWER.
The:BRC policy translates the Comission's judgement on acceptable risk into q
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explicit and practical criteria.
In developing.its policy, the Comission has
- j taken into account the views of the BEIR Comittee and other expert groups on
i OVEST10H'15..(Continued) -
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- the hypothetical' nature of the calculated health effects and the large t
associated uncertainties at these levels (see response to question 12).
In~ fact the recent report of the BEIR V Committee concluded that " studies of populations chronically exposed to low-level radiation, such as those residing in regions of elevated natural background radiation, have not shown 1
consistent or conclusive evidence of an associated increase in the-risk of
-cancer.
Notwithstanding the' uncertainty at low dose levels, the potential health L'
effects from any exemptions granted unhr the BRC policy would only'be a small j
. fraction of the hypothetical estimates of lung cancers resulting from radon
~l exposure. The 10 millirem per-year individual dose criterion represents i
1/20 of the magnitude of the annual average exposure from radon received in the' Ur.ited States, and an even smaller fraction of the total average exposure from all natural sources (300 millirer)..Furthermore, it is less than or comparable to variations-in natural background which individuals routinely'
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receive based on place of residence and daily activities and for'which no l.
quantifiable health effects have been observed.
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- Finally, it should be recognized that only a limited number of individuals are expected to be exposed at this level. The 1 and 10 mrem per year individual l
dose criteria would apply to the group of individuals with the highest l
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exposures, thus assuring significantly lower individual dose to the general population.
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For these reasons, we believe the NRC policy will not have any measurable l-adverse impact on public health and safety.
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