ML19248C490
| ML19248C490 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/1978 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Dingell J HOUSE OF REP., INTERSTATE & FOREIGN COMMERCE |
| References | |
| NUDOCS 7810050183 | |
| Download: ML19248C490 (9) | |
Text
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n>W) 3 c#.%k UNITED STATES
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?g NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 l
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- &h] /_i September 22, 1978
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CHAIRMAN
(;The Honorable John D.
Dingell, Chairman Subcommittee on Energy and Power Committee on Interstate and Foreign Commerce United States House of Representatives Washington, D.
C.
20515
Dear Mr. Chairman:
I am pleased to respond to your letter of August 16, 1978, requesting a status report on the Nuclear Regulatory Commis-sion's efforts in regard to petitions to lower the Commission's dose-limiting standards for occupational exposure to ionizing radiation.
Two petitions that relate to this matter are pending before the Commission.
One, filed by Dr. Rosalie Bertell on July 18, 1978, is referred to in your letter.
The action to be taken on that petition is under consideration by the NRC staff.
The other petition to lower occupational radiation dose standhrds was filed by the Natural Resources Defense Council (NRDC) on September 25, 1975; the staff recommended that the Commission deny the NRDC petition on September 28, 1977, but before Commission action was taken on the petition, it was supplemented by the NRDC on November 7,1977.
In a meeting held on August 17, 1978, the staff briefed the Commission on the general topic of industrial radiological health, including the NRDC petition on occupational exposure.
The question of lowering occupational dose-limiting standards along with other alternatives available to further control the risks associated with occupational radiation exposures in NRC-licensed activities was discussed.
The Commission is now considering the staff recommendations as described in the enclosed Commission Policy Paper (SECY-7 8-415 ).
The paper includes a detailed discussion of the staff's consid-erations of the NRDC petition, data on occupational radiation exposures, the staff's risk reduction efforts, and other information directly involved in the consideration of these matters.
A chronology of the action taken on the NRDC petition is enclosed.
The petition from Dr. Bertell was not received in time to be included in SECY-78-415.
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Honorable John D.
Dingell The status of the action on the NRDC petition is, in summary, that after careful consideration of a number of alternative further actions to control the risk associated with occu-pational radiation exposure in NRC-licensed facilities and the associated costs and benefits,-the NRC 4
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.1 staf. h24 ts., stively concluded that a reduction of the dcse-limittag Jtandards is not the alternative of choice and
" be counter-productive in terms of collective (man-rem) n A
de-A summary of the staff's present considerations rt_arding the risk of occupational radiation exposure is 7
enclosed.
The staff has recommended to the Commission that prior to making a final staff recommendation on the NRDC petition a hearing be held in conjunction with this petition in order to emphasize the importance of the issues, to obtain broader public participation, and to achieve more probing, in-depth discussion through the question and answer process.
As further recommended by the staff, the hearing would follow receipt and evaluation of an expected report to the Environmental Protection Agency from a National Academy of Sciences committee on low-level effects.
Currently this report is expected to be published in draft form this fall.
If it is delayed any substantial period, the Commission would probably reconsider whether or not to hold its hearing without benefit of the report.
The petition from Dr. Bertell would appear to be sufficiently related to the NRDC petition that NRC action on the latter would likely affect its action on the former.
Both of these petitions relate to the broader issue of the protection of workers from exposures to ionizing radiation.
The pace of resolution, while reflecting the complexity of, and the scientific uncertainty associated with, this issue, is by the same token, consistent with proper and definitive resolution of the issue.
It is also important to note that the fundamental issue of the biological effect of low-level radiation is not resolved and is carefully being addressed not only by the National Academy of Sciences committee, but also by a government-wide study being conducted under the aegis of the Department of Health, Education and Welfare.
The Commission has recently taken several actions to further worker protection.
These include, for example, issuance of proposed amendments to 10 CFR Parts 19 and 20 intended to assure control of exposure to transient workers, amendments to 10 CFR Part 20 designed to obtain better data on occu-pational exposures, and issuance of Regulatory Guides 8.8 179' 038
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Honorable John D.
Dingell and 8.18 providing information relevant to encuring that occupational exposures are as low as is reasonably achievable I
at power reactors and at medical institutions.
In addition l
the NRC's Office of Standards Development is about to contract for a review of the much discussed Hanford mortality data.
We will keep you informed of developments in these matters.
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Sincerely, I
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Joseph M.
Hendrie
Enclosures:
1.
Chronology of the NRDC Petition 2.
Summary of Staff Recommendations SECY-7 8-415 - Copy of enclosure in SECY Records 3.
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CHRONOLOGY OF ACTIONS TAKErl Oi!tlRDC PETITION l
On September 26, 1975, the flatural Resources Defense Council (flRDC)
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f filed a petition to amend 10 CFR Part 20. That petition stat.es tha'
- The objective of the preoosed action is to reduce the genetic risk I
associated with radiation exposure at the current occupational exposure level by a factor of 10 and reduce the somatic risk by a factor of 6."
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The tiRDC also requested that "The flRC institute hearings to determine the Jas low as practicable' extent to which the exposures can be J
maintained below the proposed new regulations." The t;RDC proposal would 1
f result in reducing the occupational dose limiting standards to 0.5 rem anntally; somewhat highe. exposures might be permitted workers more l
l than 45' years ola.
The t;RDC filed an almost-identical petition with the Environmental Protection Agency (EPA). The EPA denied the petition on August 10, 1976.
The !!RDC petition was published by the t;RC in the FEDERAL REGISTEP, on The comments October 29,1975 (40 FR 50327) to permit public comment.
received included three letters supporting the petition, one proposing an alternate set of reduced limits, and 52 opposing the petition.
The staff submitted its recommendation regarding the petition to the Commission on September 28, 1977.
On October 17, 1977, members of the staff met with Drs. Cochran and Tamplin of the l!RDC to discuss the status of the peti. tion; at that time the petitioners were told that the staff had i7p1 040
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recomended denial of the petition.
On flovember 4,1977, prior to a decision by the Commission, a supplement to the petition was received In this supplement the t'RDC requested th'at th'e Commission from the f!RDC.
l consider evidence not cited in the original petition, viz., interpretations l
of two epidemiological studies, one performed by Drs. fiancuso, Stesart, l
l and Kneale and another performed by Dr. Irwin D. J. Bross and Mr. N.
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The NRDC, on flovembei 7,1977, also submitted a similar 1
l flatarajan.
In a letter dated December 2, 1977, the EPA advised supp]ementtoEPA.
the' NRDC that the EPA staff was already exam ~ning the submitted stu: ~ es in connection with a comprehensive review of occupational exposure standards, and agreed to reconsider the denial of the petition.
On December 7,1977, the staff advised the Commission that staff assessments of the tuo epidemiological studies were already in progress when the NRDC supplement was received, and that the most straight-forward and least time-consuming approach would be to defer Commission action until the assessmeats have been completed and incorporated into a staff paper which would also contain the staff's recommendation regarding the ffRDC request for a hearing.
the staff briefed the Commission on the NP,DC petition On August 17,1978,
, risk associated with as one part of further action to be taken to con.
The staff occupational radiation exposures in f;RC-licensed activities.
recommenced in SECY-78-415 that no action be taken on the NRDC petition at this time, but that a hearing be held to consider the question of 94;
,ns reduction of individual, dose limiting standards following publication and evaluation of the new (third) report of the fiational Academy of Sciences (ilAS) Advisory Co:rmittee on the Biological Effects of Ionizing Radiation (BEIR Report). That report is expected to be published by the !!AS later this year.
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SUMMARY
OF STAFF CONSIDERATIONS REGARDING THE RISK OF OCCUPATIONAL RADIATION EXPOSURE Prior to the receipt of the NRDC petition the Commission staff was acutely conscious of the trend toward increased collective (man-rem) doses to workers in the nuclear industry, particularly in nuclear power plants.
Staff study of this problem indicated a number of alternative methods for reduction of the overall risk of radiation exposures.
One of the alternatives involi/es reduction of the individual dose limiting standards, as petitioned by NRDC.
However, a question arises as to whether lower dose limiting standards for individuals would decrease or increase the collective dose, and thus the overall risk.
It has been the policy of the NRC/AEC since the initial publication of 10 CFP, Part 20 in 1957 to assume the hypothesis that the biological effects of ionizing radiation, delivered at low doses and low dose rates, can be conservatively predicted by linear extrapolation (to zero dose) of effects that have been observed following exposures at high doses and high dose rates, i.e., the linear hypothesis. According to this hypothesis, some degree of risk is associated with any radiation dose, however small, and the risk is directly and linearly proportional to the dose.
Acceptance of this hypothesis essentially dictates that an effort should be made to control both the individual worker's dose and the collective (man-rem) dose to all workers, and since 1971 the Conmission's regulations have included both of these concepts.
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,. Recently, several members of the scientific community have published information which suggests that the lindar hypothesis may be ir correct.
Certain of these scientists (Scientific Committee 40 of the fiational Council on Radiation Protection and f4easurements (fiCRP); United flations Scientific Committee on the Effects of Atomic Radiation, in " Sources 1
and Effects of 16nizing Radiation," 1977) maintain that the linear hypothesis overestimates the risk from exposure to radiation.
Conversely, two.recently completed interpretacions of epidemiological data (Mancuso, Stewart and V,neale; Bross and flatarajan) indicate that the linear hypothesis c.
underestimates the risk by a factor of ten or more. A further study of this risk of exposure to innizing radiation is being conducted by the Advisory Com.71ittee on the Biological Effects of Ionizing Radiation (BEIR Committee) of the fiational Academy of Sciences - fiational Research Council, and a report is expected later this year.
It is the f!P,C staff's opinion that major changes in the basic dose standards should not be considered until there has been opportunity for evaluation of the neu (third) BEIR Report.
The staff has been advised that the EPA also does not plan to take a position on this matter without benefit of the new BEIR report.
Confronted with present uncertainties regarding dose-effect relationships, some of which are not likely to be resolved for many years, it is necessary for the Commission to consider further regulatory strategy to assure the workers are adequately protected.
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'O The staff's analysis of the problem includes consideration, as two separable matters, of basic dose limiting standards arid the concept of maintaining occupational radiation exposures as low as is reasonably I
achievable (ALARA). The staff believes (1) that lowering the dose limiting standards as requested by the flRDC, and Dr. Bertell, would increase the collective dose, at least initially, and that for licensed activities other than nuclear power, the higher collective dose would not be sub-sequpntly reduced, and (2) that the costs for effecting subsequent collective dose reductions in the nuclear power industry would be unreasonably high.
The staff has recour. ended to the Connission that (1) a reasonable additional effort should be made to control further the overall risks associated with occ spational radiation doses, and (2) appropriate control of risk can be achieved through regulatory action which places additional emphasE on maintaining occupational doses as low as is reasonably achievable (.ALARA) by making individually developed ALARA programs a regulatory requirement and making these programs inspectable and enforceable.
It should be noted that such regulatory action is being recommended by the staff irrespective of the dose limits question.
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