ML20059G445
| ML20059G445 | |
| Person / Time | |
|---|---|
| Issue date: | 09/07/1990 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Norberg R AFFILIATION NOT ASSIGNED |
| References | |
| FRN-53FR49886, REF-WM-3, RULE-PR-CHP1 NUDOCS 9009120313 | |
| Download: ML20059G445 (5) | |
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NUCLEAR REGULATORY COMMISSION,j" WASHINGTON D. C. 20$55
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.Ms. Rose A. Norbergs 1617 South Beretania Street i
Punahuo Circle, Apt.:607 1
- Honolulu,' Hawaii.96826 1
Dear Ms. Norberg:
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.-i cI.am responding to your postcard of June '28,1990, which was forwarded to us-from the Department of Energy, and addresses concernsL pertaining' to the'.
disposal: of low leyel radioactive wastes (LLW). These concerns specifically e
relate to wastu cit.racterized as "Below = Regulatory Concern" or "BRC."
The Nuclear Regulatory Commission issued a Below Regulatory Concern-Policy Statement on 4uly 3,1990.
I:have' enclosed.a copy of tP ' 'atement and a
'a companion explanatory booklet (Enclosures 1 and 2) for yor
' tion.
The Commission. in issuing the policy. has acted in the belt J
m nation's'best-interests are served by policies that establis.. consistent risk framework within which exemption-decisions can'be made with assurance that human health and the environment are protected. L The policyfis nr o self-executing and. does not,. by itself, deregulate 'any? low-level radicactive waste..Rather the' policy states the principles and-criteria that would apply to Commission decisions which allow licensed radioactive material to'be
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. released from the full. scope of regulatory controls..my specific exemption decision would-be accomplished through'rulemaking or licensing. actions.-
In response' to your concern arding the potentia 1'effect of fais policy on human health, it may be hel d to summarizeLthe typical exposures that we all routinely receive from a var lety of sources of. radiation. JThese ' exposures:are also described'in the enclosed booklet.
In total'. as estir.ated by the' a
National Council on. Radiation. Protection ;and-Measurements: (NCRP Report No.- 93),
the dose received by an average individual in the United States population.is about 360 millirem per year. - Of this total.over 83 percent (about 300 millirem
'l per year) is a res' ult of natural sources, including radon 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 made sources, including nuclear. fallout,ccontribute the remaining
'l to 2 percent of the total exposure.
I am presenting, this informa *. ion' to.
provide a perspective on the hypothetical. risks which may be associeted with
. potential' BRC waste disposals or other exemption decisions that the Lossiission.
may make under the provisions stated in the policy.
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I also believe it is important to understand the nature of the hypothetical risks that are associated with exposure'to low-levels'of ionizing radiation.
I You will note that such estimates are provided in the policy statement. The projections of risk are based on estimates recently-made by the United Nations' Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) and the H
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- Ms; Rose A.: Norberg.
l National Research Council's Committee on the Biological Effects of Ionizing 1
Radiation. The 'latter Committee has recently issued a report, " Health Effects '
. of Exposures to Low-Levels of Ionizing Radiation," commonly referred to as the l
BEIR Y report. -The potential exposure levels which would be associated with 1
l BRC waste disposals are significantly smaller than those discussed in the J
l reports and would onlyLbe a small fraction of the natural. background exposures, discussed earlier.
On this issue, the BEIR.Y report states that the possibility cannot be ruled out that there may-be no. risks from exposures comparable to external backgrcund radiation.
JIn closing, I can. assure you that we take our.mandatt to protect th. health-and ss ; of' the public very sciously.
I hope the views expressed and the encloseo 'nformation are responsive.to your concerns, t
' Si ncerely, -
(SIGNED) PAULH.LOHAUS-Paul'H. Lohaus, Chief.
Operations Branch Division of Low-Level-Waste Management-and Decommissioning, NMSS
Enclosures:
BRC Policy Statement' BRC Explanatory Pamphlet cc: Jill E. Lytle Distribution: (LLWM-90-157)g"Centralq11e%~214 57'isNMSS r/f LLWM t/f RBangart
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- See Previous Concurrence SUBJECT AB A :
TEFORRATION ON LLW DISPOSAL, BRC
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- PLohaus bATEbbhbh)9b bbhbh)bb 09h)9b RH/R.NORBERG/8/22 0FFICIAL RECORD COPY-l
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-i 3-Ms. Rose.A. Norberg National Research council's Commiittee on the Biological; Effects of Ionizing.
Radiation. The latter Committee has recently issued a report -" Health Effects of Exposures to Low-leyels of; Ionizing Radiation," commonly referred to as the<
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.BEIR V report. The potential exposure levels which would be associated with BRC waste disposals arer significantly smaller than those discussed-in the s
reports andgould only be a small. fraction of,the natural background exposures, j
discussed earlier. On this issue, the BEIR V report states-that the.
possibility cannot be ruled out that there may be no risks from exposures-1 comparable to external background radiation.
In closing, I can assure you that we tak'e our mandate to protect the health-l and safety of the public very seriously..I hope the views expressed and the:
l enclosed information are responsive to your concerns.
L l
Sincerely,
[
8 Paul H. Lohaus, Chief
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Operations Branch t
\\ Division of Low-Level Waste Management-and Decommissioning, NNSS
Enclosures:
BRC Policy Statement k BRC Explanatory Pamphle't N
cc:
Jill E. Lytle Distribution: (LLWM90-137)
Central File i 14.5 NMSS r/f' LLWM t/f RBangart JGreeves JAustin JSurmeier PLohaus JKennedy RHogg WLahs, RES
..LLOB r/f LLOB't/f PDR' YES X
PDR NO Category:
Proprietary or CF Only
-ACNW YES X
NO SUBJECT AB3 TRACT:
TRTORRXTION ON LLW DISPOSAL, BRC W
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NUCLEAR REGULATORY COMMISSION 4
Below Regulatory Concern; Policy Staternent j
AGENCY:
Nuclear Regulatory Commission, waste in a manner commensurate with their low radiologi-cal risk; and (5) increased assurance of a consistent level ACTION:
Policy statement.
of safety for consumer products containing radioactive
SUMMARY
- This policy statement establishes the frame, material under the Commission's jurisdiction.
work within which the Commission will formulate rules or El/FECTIVE DATE: July 3,1990 make licensmg decisions to exempt from some or all regu-i latory controls certain practices involving small quantities of radioactive material. Opportunity for public comment ADDRESSES: Documents referenced in this policy state-will be provided with each rulemaring and each hcensmg ment are available for inspection in the NRC Public action where generic exemption provisions have not al-Document Room, 2120 L Street, N. W. (lmwer Level),
Washin .on' DC*
e ready been established. The exemptions may involve the release of licensee-controlled radioactive material either FOR FURTHER INFORMATION CONTACT:
to the generally accessible environment or to persons who uld be exempt from Commission regulations. Practices
'Ihe appropriate NRC Regional Office:
v D. which exemptions may be granted include, out are not
'imited to, (1) the release for unrestricted public use of Region I - Dr. Malcom Knapp, King of Prussia, lands and structures containing residual radioactivity;(2)
Pennsylvania; telephone (215) 337-5000 i
the distribution of consumer products containing small amounts of radioactive material; (3) the disposal of very Region II - Mr. J. Philip Stohr, A.lanta, Georgia, low-leve! radioactive waste at other than licensed disposal telephone (404)331-4503 sites; and (4) the recycling of slightly contaminated equip-Region III - Mr. Charles E. Norelius, Glen Ellyn, ment and materials. As described it.this policy statement, Illinois; telephone (708)790-5500 NRC intends to continue exempting specific practices from regulatory controlif the application or continuation Region IV-Mr. Arthur B. Beach, Arlington, Texas; of regulatory controls is not necessary to protect the pub.
telephone (817) 860-81'30 lic health and safety and the environment, and is not cost cffective m further reducmg nsk. The policy statement Region V - Mr. Ross A. Scarano Walnut Creek, l
defines the dose critena and other considerations that will California; telephor.e (415) 943-3700 l
be used by NRC in making exemption decisions. De Federal and State Govermuent Officials may contact:
policy establishes individual dose criteria (1 and 10 mrem Mr. Frederick Combs, U.S. Nuclear Regulatory Commis-per year [0.01 and 0.1 millisievert per year]) and a collec-sion, Washington, DC 20555, Office of Governmental tive dose criterion (1000 person. rem per year [10 person-and Public Affairs, telephone (301) 492-0325.
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sievert peryearj).nese criteria, coupled with other con.
l siderations enumerated in the policy statement, will be Questions may also be directed to the following nnjor factors in the Commission's determination on individuals at the U.S. Nuclear Regulatory Commission, whether exemptions from regulatory controls will be Washington, DC 20555.
granted.
Dr. Donald A. Cool, Office of Nuclear Regulatory The policy statement establishes a consistent risk frame, Research; telephone (301)492-3785 k
work for regulatory exemption decisions, ensures an ade-quate and consistent level of protection of the pubhc m Mr. John W. N. Hickey, Office of Nuclear Material their use of radioactive materials, and focuses the Na-Safety and Safeauards; telephone (301) 492-3332 tion's resources on reducing the most significaat radio-Mr. L J. Cunningham, Office of Nuclear Reactor f
logical risks from practices under NRC's jurisdiction.The Regulation; telephone (301) 492-1086 0
average U.S. citizen should benefit from inplementation of the BRC colicy through (1) enhanced a)ility of NRC, SUPPLEMENTARY INFORI'1ATION:
l Agreement States, and licensees to focus resources on more significant risks posed by nuclear materials; (2)
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timely and consistent decisions on the need for cleanup of N
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contaminated sites; (3) increased assurance that funds available to decommission operating nuclear facilities will 1.
Introduct. Ion.
be adequate; (4) reduced costs and overall risks to the Ionizing radiation is a fact of life. From the day we public from managing certain types of slightly radioactive are born until the day we die, our bodies are exposed to 1
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