ML20058N478
| ML20058N478 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/1990 |
| 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 CCS, MILLER-900726, NUDOCS 9008140155 | |
| Download: ML20058N478 (2) | |
Text
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OUEST10N 15.
The NRC's "Below Regulatory Concern" pamphlet contains the-i following statement:
"Indeed, the NRC does not expect any meailirable' adverse-impact on the public health and safety as a result of l
the policy."
(underlineadded)
It is my understanding that the Environmental Protection.
l Agency has estimated that thousands of lung 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 deaths are caused by radon exposure.
Does the'use of the word " measurable" in the NRC pamphlet 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?
3 ANSWER.
1 The BRC policy translates the Commission's judgement on acceptable risk into explicit and practical criteria.
In developing its. policy, the Comission has taken into account the views of the BEIR Comittee and.other expert groups on 4
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QUESTION 15..(Continued) j i-the hypothetical nature of the calculated health effects and the large 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 consistent'or conclusive evidence of an associated-increase in the risk'of cancer."
i l
Notwithstanding the uncertainty at low dose levels, the potential health l
effects' from any exemptions granted under the BRC policy would 'only be a small fraction of the hypothetical estimates of lung cancers resulting from radon exposure.
The 10 millirem per year individual dese criterion represents.
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1/20 of the magnitude of the annual average exposure from radon received in the United 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 receive based on place of residence and daily activities and for which no quantifiable health effects have been observed.
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.
dose criteria would apply to the group.of individuals with.the highest.
exposures, thus assuring significantly lower individual dose to the general population.
1 For these reasons, we believe the NRC policy will not have-any measurable l
adverse impact on public health and safety.
JUL !! '90 13:02 FROM SUBC WATER AND POWER TO NRC CONGR PAGE.002 I
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Honorable Kenneth Carr Chaiman United States Nuclear Regulatory Commission Washington, D.C.
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Dear Mr. Chairman:
I am writing to request information concerning matters that will be addressed at the July 26 hearing before the Subcommittee on Energy and the Environment.
While I appreciate the considerable effort expended by the Commission and its staff to explain its policy concerning.
exposure to relatively low level sources of nuclear radiation, I do not understand significant aspects of the Below Regulatory Concern (BRC) policy.
In order that we might properly prepare for this hearing, please provide the following information no later than Friday, July 20:
1.
A listing of examples of specific practices that the Commission might decide to exempt from some or all regulatory controls.
2.
An estimate of the number of. exempted practicos that might be authorized pursuant to the BRC policy.
Analyses that the Commission used in balancing the decreased J
3.
costs resulting from exempting certain practices from regulatory controls against the adverse health consequences specified by Commi,ssioner Curtis in his Additional Views.
4.
A statement describing the number of agency staff-hours expended during:FY 1988, FY 1989, and FY )90 on regulation of practices and materials that could be exempt from regulation under the BRC policy.
5.
A statement descz:ibing the number of agency hours staff-hours that, under pre-DRC policies, are projected to be-expended in each Jiscal Year in the decade beginning in FY L
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.c o Le JUL 11 '90 13iS3 FROM SUBCLWATERLAND POWER:
TO NRC_CONGR PAGEiOO3
. e-Honorable Kenneth Carr July 10, 1990 Page12 l-1991 onithel regulation of: practices and mater'ials that couldi l-L be exempt from regulation-under the BRC policy.
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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 the.
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-implementation of the BRC-policyEand regulation ~of practices-and materials that could be partia11ytexempt.from regulation i
under the BRC policy.
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7-For each Fiscal Year in'the decade beginning in FYJ1991 of.
L costs, an' enumeration.of costs that might not be incurred by; licensees and others involved in: handling'of radioactive.
materials as a consequence of promulgation of the1BRC i
policy.
8.
How many NRClnon-reactor licensees currentlyJgenerate low-level radioactive waste?
How many on-site inspections did l
NRC personnel conduct of these licensees.in 19897 How.many of these licensees have not been subjected to an i
on-site inspection over the past two years, three yaars and four years?
9.
How many agency FTE were expended in.FY-19bV on inspections of non-reactor' licensees.to ensure compliance.with low-level-waste disposal. regulations?.
L 10.
According to.the Environmental Protection Agency February 2,
~
1989 comments on the'NRC's' Advanced Notice 1concerning the; BRC policy, : the EPA, not the NRC,'has-the primary federal-responsibilityz for regulating offsite levels of radiation.-
c In addition, it.is my understanding that EPA, not the NRC, has-the authority to determine acceptable levels ofL radioactive contamination in soil.
'In light ~of'the above, why has-the NRC issued.the below regulatory concern 1 policy-(BRC) without the support:of EPA 7 11..
How can the NRC effectively implement'the BRC' policy'for-wastes and decommissioning before EPA hasidetermined "how i
l cisan-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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(JUL 11 '90.13 93
-FROM SUBC WATER AND POWER.
TO NMC CONGR PAGE.004'
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3..
Honorab'le.Kenneth Carr
-July 10, 1990' Page 3 t
12.
What is the lifetime risk of death from a radiation-induced l
cancer from an individual radiation. dose of 100. millirem per.
year, 10: millirem per year, and 1 millirem per year?
13.
Please provide an estimate 1of how many cancer; deaths occur-in the United States.per year from exposure to background radiationJ(excluding indoor radon).
In addition, please provide ~an estimate of how:many cancer; deaths occur in the-United States.per year from exposure.tolindoor' radon.
' 14.
The Commission's letterfofEJune 29, 1990 states that the individual dose criterion for.the'BRC' policy was raised from L
1 mrom.per year to 10' mrem per-year at the direction of Mr.
Victor Stello, who was Executive Director for Operations: st L
'the time this change was:made to tne. draft:BRC. policy.
The letter states that Mr..Ste11o, "... questioned whether the-proposed individual dose criterion-value of 1 mrom/yr would provide sufficient flexibility in practical applicationiof the policy."
Please provide a full' explanation Mr.LStello's" objections to the 1 mrom/yr individual dose = criterion and theLrationale a
l for increasing the individual dose; criterion"to 10.mrom/yr.-
Please address the following questions in your' explanation:
4 o At the time the individual dose. criterion was raised to 10 mrom did the Commission share Mr. Ste11o's' concern that--the 1 mrom individual dose criterion-did not " provide: sufficient i
flexibility in practical' application of.the policy?"
o Why would a individual dose criterion value of 1 mrem /yr; 4
not'" provide sufficient flexibility in practical application-of the policy?"
o Please identify what, if any, practices would more-likely u
be exempted,from regulation using the 10 mrem /yr criterion i
rather than the 1 mrem /yr criterion originally proposed by the NRC staff.
15.
The NRC's "Below Regulatory Concern" pamphlet contains the following statement:
l "Indeed, the NRC does not expect any measurable adverse impact on -he. public health and safety as.a result of the policy.'" (underline added)
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JULJ11 '90 13:04:
FROM SUBC WATER AND, POWEft d
Honorable Kenneth Carr July;10, 1990
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-1 It is my understanding that the~ Environmental Prot $ction
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. Agency has estimated:that' thousands of lung cancers occur every~
year in the United States due to: indoor redon exposure but no method-has.yet-been devised to actually " measure" the number of L
deaths that.are caused.by redon exposure.
y Does the'use of the word " measurable" in'the NRC pamphlet.
.mean.that the NRC expects that the policy will have; adverse.
_ effects on public health and safety but that these effects:will
.not be measurable?
Thank you.for your consideration.
I I
Stincur'ely, i
lh Geo f
er.
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Subcommittee on-Energy and.
i the Environment i
t cc:
The Honorable Morris K. Udall-The Honorable James Hansen.
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