ML19249D589
| ML19249D589 | |
| Person / Time | |
|---|---|
| Issue date: | 02/26/1979 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Moeller D HARVARD UNIV., CAMBRIDGE, MA |
| Shared Package | |
| ML19249D588 | List: |
| References | |
| NUDOCS 7909250019 | |
| Download: ML19249D589 (14) | |
Text
.
c:1TEo STATES
- ~
d NUCt. EAR REGULATORY COMMISslON
{[l ]
j usmucTon, o. c. :esss t M' v g /
5 t
FEB 2 51979 ms Dr. Dade W. Moeller Member Committee 4 International Commission on Radiological Protection Harvard University School of Public Health e.
Kresge Center for Environmental Health
[
665 Huntington Avenue Boston, Massachusetts 02115
Dear Dr. Moeller:
By letter dated June 30, 1978, you invited Mr. Robert E. Alexander, Chief, Occupational Health Standards Franch, NRC, among others, to provide identi-fication of those recommendt... ions contained in ICRP Publication 26 "which may be difficult to implement in practice."
A comparable invitation was extended to all members of the Health Physics Society by an announcement published in the Health Physics Society NEWSL:TTER, Augus-t 1978.
I a:::
=
aware that Mr. Alexander has submitted individual comments in response to those invitations.
Enclosed are comments that reflect the coordination of en:isiderations by the several Offices within NRC.
The enclosed comments co not reflect formal consideration by the Commission.
No proposed amendments to the Commission's regulations have been recommended to the Ccmission by the staff to implement the recommendations in ICRP Publication 26.
The ICRP recommendations are under study, but implementation has been delayed pending resolution of the problem areas identified in the enclosed cc::ments.
Note, also, that tne Environmental Protection Agency has not yet provided any changes to the (Federal Radiation Council) guidance on radiation protection to Federal agencies as a result of the publication of ICRP 26.
We antici-pate the develocment of proposed amencments to NRC regulations soon after the new EPA guidance is issued.
Sincerely,
)
t (stgned) Let V. sassick Lee V. Gossick Executive 0">: e for Operations
Enclosure:
Comments
~
70092500% ;
i i
Enclosure A )
4g
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RECOMMENDATIONS IN ICRP PUBLICATION 26 THAT MAY BE DIFFICULT FOR THE NUCLEAR REGULATORY COMMISSION TO IMPLEMENT IN PRACTICE Ip if Chance in Internal Dose Standards The United States Nuclear Regulatory Commission (NPC) regulations regarding exposure to radioactive materials, as set out in Title 10, Code of Federal Regulations, Part 20, are expressed in terms of intake.
They are based on the calculated committed dose equivalent to the " critical organ."
For example, iodine intake is limited so that it does not result in a dose greater than 300 mSv (30 rems) to the thyroid in a year, at equilibriua,
[
with no consideration being given to the lower doses received by other organs or the whole body.
~
The control procedure recommended in ICRP Publication 26 would limit internally committed dose equivalent on the basis of overall risk to several affected organs.
This risk must be no greater than that assoc.iated with the recommended external whole-body dose standard.
In order to u
calculate the concentration value for an airborne radionuclide, the committed f
dose equivalent to each of the several organs is determined, each sucn dose is. weighted by a factor W according to the relative risk, and the 7
results are added.
The sua must be less than 50 mSv (5 rems) whole body ecuivalent risk per year and the (unweignted). committed dose equivalent to Enclosure A l023 i70
I each organ must be less than 500 mSv (50 rems) per year.
This technique recognizes that a given radionuclide may contribute dose to a number of
~~
organs and provides a mechanism for summation of those contributions.
The technique also provides a mechanism for summing the doses that would be received in the event that a number of different radionuclides are taken
.}
Z.
into the body.
Most importantly, this technique provides for summation of L..
a
" risk" due to internal and external dose.
The dose limits for stochastic effects are based on summed risks.
In principle, we consider this approach useful and logical.
The relative risk factors W. are based on new biophysical data which are i
to be presented in subsequent ICRP publications.
In the absence of the cetailed biophysical data (discussed below), it is difficult to determine whether the procedure recommended in ICRP Publication 26 is more or less conservative than current NRC requirements for control of internal dose commitment.
It appears that the effect of the ICRP recommendations could be to increase slightly the amount of many radionuclides that may be taken into the bocy.
Sucn a change seems unwise at a time when present limits are achievable and the numerical values of risk associated with exposure to ionizing radiation are uncertain.
We do not expect the impact of this change to be great in the working areas.
However, the need to calculate committed dose equivalent and total risk, rather than MPC-hours or intake will create problems.
We believe that many NRC licensees may not have the technical capability to perform tne requirec calculations and probably would have to be proviced extensive
~
2 Enclosure A 1023 iii
~
?00R BR W L i
~
guidance or have to hire someone to perform the work for them.
It may be feasible to incorporate the recommendations into our regulations in a manner that wculd permit the continued use of intake or MPC-hours by these licensees.
Presumably such use could be somewhat more restrictive than the ICRP recommended action.
Further, depending on the guidance that may be developed for Federa1 agencies in the United States by the Environmental 3
Protection Agency and the resulting implementing amendments to 10 CFR Part 20 of our regulations, we anticipate that these ICRP recommended actions s
may re::uire significant increases in air sampling, in bioassay programs, and in record keeping.
In the procedure where W values are estimated by summing all organ risks T
and normalizing this total to 1.0, adjustments may be recuired in the future on the basis of new risk assessments or new risk estimates for crgans not prevously considered.
If these W,. values are internal to the i
calculations of the annual limits of intake (AL ), the ALI values ri:ay nat be reacily mocified to accommodate such changes.
Also, the risks uncerlying the W v: lues are primarily the induction of fatal cancers.
- cr thyroid T
irradiation, the low mortality rate may not be an acequate measure of the cetriment.
Further, only about half of all cancers are fatal; thus, postulated nonfatal cancers constitute a substantial additional risk.
Considerable concern has been expressed regarcing the societal acceptabil-ity cf certain implied organ cose limits whica may be derivec using the weignting f act::rs.
As noted acove, those f actors a:: pear to allow increased 3
Enclosure A 1023 D3
200RORGNAL dose to certain organs, when irradiated individually, which in practical a: plication does not appear necessary.
It has been suggested that the bicphysical data being prepared by ICRP should be used to derive values for annual intake or limiting concentrations in air that would result in annual committed dose equivalents no greater than those currently permitted.
In view of the ability of the industry to meet the existing radiation il standards, and the continuing question as to the risk associated with the cases at the existing stancards, it would appear unwise to implement less res rictive control values.
Concern has been expressed about tne availability of new cicphysical data on some (large) fraction of the nuclides tha. may be in use.
We feel that.
all of these data must be available to the public prior to the promulgation cf NP,0 regulations implementing the ICRP Publication 25 recommendations.
Summation of External Ccsa and Internallv Ccemitted Dose Ecuivalen:
Eecause of the technical difficulties involved, the regulations in 10 CFR Part 20, give one set of dese-limiting standarcs for expcsure to radicactive materials (s 20.103, in terms of intake or M C-hours) and anctner for external dose (s 20.101), with no provision or requirement for summation.
ICRP Publication 26 provides a technique for the summation of external case and the weignted internally c:mmitted dese equivalents and recommends cne limit for the sum.
This change is very cesirable in principle.
h: wever, Cased on experience and tne infcrcation available to us at this time, it apoears that tnis enange siil be re'.atively unimoortant frem the 1023 174 Enclosure A
stancooint of limiting the activities of individual workers.
Apparently w workers receive significant doses from both external arzd internal exposure.
t.owever, a potential prcblem could develop in the implementation of the ree..(..dation into the regulations.
Again, the potential problem is one of raded burden on licensees of additional monitoring (air sampling and bioassay), additional capability for personnel needed to perform the h.
~
calculations and summations, and additional record keeping.
+
ICRP Publication 25 reccmmends that records be kept only of' those doses that exceed 10% of the annual limits.
The use of such a criterion for the recording of daily, weekly, or even monthly accrual of exta-nal dose and internally committed dose equivalent would neglect a very high percentage of deses that are relatively uniformly distributed over ti=e.
Additional guidance is needed regarding increments of dose that may be neglected from day-by-day records.
The regulations in 10 CFR Part 20 (! 20.202) currently require the provis-ion cf monitoring ecuigeent if it is likely that an indivic':.:al will exceed 25% cf soecified quarterly standards, i.e.,1/15th of the annual dose stancards for external exposure.
When assessment of an inciividual's i--
intake of radioactive material is necessary, the regulatiors (f 20.103(a)(3))
provide that intakes less than those that would result frc=r inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day or for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in any one week at MPC need not be included, proviced that for any assessment in excess of these amounts the entire amount is incluced.
1023 175 5
Enclosure A
y J
Deletion of Ouarterfv Dose Limitino Standards ICRP Publication 25 does not recommend any quarterly dose 1 imitations.
Informed members of the scientific community believe that there is little or no biological advantage, except for an embryo or fetus, -in limiting the dose rate for annual doses on the order of 50 mSv (5 rems).
However, we are concerned that, in the absence of quarterly limits and :the associated regulatory overexposure reporting requirements that give ear ly indication of possible loss of control by a licensee and the opportunity to require correction of an undesirable situation, a potentially inadec;uate safety program may be allowed to continue for a year or until a rcuJtine inspection occurs.
Also, the absence of quarterly limits, while proviciing aidditional flexibility tc ' censees to use their workers, increases corxern for the pctential overexposure of transient and moonlighting workern duri ng multiple employments.
ICRP Publication 25 would permit planned special exposures r.'esult.ing in doses of up to 100 mie (10 rems) whole body or equivalent pr' ovide:d that the situations occur infrequently, that only a few workers are so exposed, and that no worker receives more than 5 such special exposu:ces in the worker's lifetime.
This provision would be useful on occas' ion tc; licensees in that it would permit the kind of flexibility to use empl:oyees to accomplish essential work that involves relatively high doses that is icurrently available under the dose-averaging formula 5(N-18).
The pr ovision for special exposures would present cc:alications for a regulat.ory agency in cevelopir.g regulations anc standards to implement the recer.mendation.
1023 176 6
Enc ~iosure A
I Occucational Exoosure of Women of Reoroductive Caoacitv and Preonant Women Paragraph (115) of ICRP Publication 26 states that when women of reproduc-tive capacity are occupationally exposed to radiation within the 50 c:5v (5 rems) per year dose limit, and when this dose is received at an approxi-mately uniform rate, it is unlikely that the embryo could receive a dose of more than 5 mSv (0.5 rems) during the first 2 months
- pregnancy.
ICRP indicates that this will provide appropriate protection during t.he
~
essential period of organogenesis.
From the standpoint of a regulatory agency, it is also necessary to consider conditions in which a woman of reproductive capacity may be exposed at a very non-uniform rate, e.g., a transient worker at a nuclear power plant.
Thus the ICRP recommendations appear to be incomplete.
Paragraph (115) continues by recommending that, when a pregnancy has been 1
ciagnosed, arrangements should be made to ensure that the woman can ccntinue to work only in Working Condition B, that is, where the annual doses are cost unlikely to exceed three-tenths of the annual dose-equivalent limits.
The icoact of these recommencations will depend on the way they may be implemented througt. regulatory requirements, if any.
If licensees es.tablish Condition A zones und exclude women from them during pregnancy or other times, this could have a significant impact on the employability of women and will constitute discrimination on the basis of sex.
While recognizing tne need to protect the embryo and fetus, the NRC has been acvised by the United S;ates Office of Equal Empicyment Opportunity that establishing 1023 if7 Enclosure A
?00R ORGEL dose standards for women that are lower than dose standards for men would violate existing laws.
Following long and careful consideration of these matters the NRC has advised licensees to instruct women, their supervisors, and the co-workers of the risk associated with exposure to embryos and fetuses.
It has also b
provided in Regulatory Guide 8.13, " Instruction Concerning Prenatal Radiation Exposure," the information that the Commission staff feels should be a
presented on this matter.
The Conc.ission has carefully avoided any cifferentiation between women and men in its regulations.
ICRW Erenasis on Occucational Radiation Protection The ICRP's emphasis on occupational radiation protection does not provide sufficient guidance for application to protection of the general popula-tion.
For example, the stochastic risk values in Section D do not provide guidance related to the possible variation of biological sensitivity with age.
This emphasis on the adult also influences the definition of the committe' dose equivalent.
For infants and other nonadult members of the general population, the 50 year committed dose equivalent may not be appropriate and longer-term values may be required.
Hopefully, the forthcoming annual limits of intake (ALIs) and associated uptake and retention data will permit age-dependent committed dose equivalents to be readily calculated without having to resort to the original literature.
1023 173 5
Enclosure A
P00R ORGINAL
~
In paragraphs (43), (50), and (80), consideration of the genetic risk is limited to tne first two generations.
We do not agree with the rationale for this limitatica (copy enclosed) set forth in paragraph (43)(a) of ICRP Publication 27, "Preblems Involved in Develeping an Incex of Harm."
It is cur opinion that tne genetic risk should consider the effects that may result in all subsecuent generations.
The ICRP indicates that this would require doubling of the risk assigned.
5: Units I:RP Publication 25 replaces the so-called "special units" (the rem, rt.d anc curie) wita a new set of units (the sievert, gray and becquerel, respectively).
These new units are, and probably will continue to be, a source of irritation to many and will ccmplicate cetmunications for years.
We are uncertain as tc the extent of the impact of the new units, but serious concern has been expressed regarding the potential for misunder-standing anc cverexcosure of patients in medical ciagnosis and therapy.
hoever, it is the intent of the NRC to convert to tne SI system at a rate at least paralleling that being achieved by United States incustry in the varicus cisciplines.
1023 i77 C
Enclosure A
/
^
?0CROM m_
14 A REPORT OF THE INTERNATION AL COMMISSION ON RAUiOLCCICAL ?ROTECTION of: C:cadi:n nucle:r f::ili:y. and it se:ms to be relatively slight. For :hy <d. the same is miei lik:iy :h:: ef:he ceder of 50% of:he full risk like!y to :pply :o sy=pterns and :o cperation be ll wi!! be ex:r:ssed fellowing expcsure at in most e:ses, and :he risk :f ei:her su bstantial T.s..
working ages. (!t may be :=ph:si::d that or prolonged c!!ni:2! disability is proifably w or'-
~
th::: at: a;: weighted m:2n values. The ecmpars le witn th: risk cf fatal rn:dignancY abh-vari: tion of risk wi:h the 03: cr sex of the in this org:n (510" r:m-8). For breast, th:
mdiviciu:/:re discuss-d in paragraphs 63-67, total average frequen:y of non-fatzi cance.-s is pos::
and Tabi: 13.)
lik !y to be abcut e:;ual to the.t of fatal ones, l
ee:u (40) Th: centribution to harm by indue: ion (2510* rem-'), but there will be periods of fore :
of malignancies in:!udes a number of tre:tmen in all cases and of additional rezuir F components:
disabili:yinsomeof:h =.
(a) Th: 10-15 years loss of life due :o (42) It is obviously impessible to give any two fa:al malignan:les as discussed above exs:: weighting to the thre: cornponents cou--
(:e: partsraph I3);
descriced in paragra;n 40, but seme approxi-r:q2 (b) in: ;: nod of illness prior to d::.th m:: ices se:m ;ossib!:. The first :ceponent to th:
from a fa:ai malignancy. T : median involve: a !O rem risk of a cornpie::less of c:: ;
p:-icd of surviva! from diagnosis :c 10-15 years oflif:. rd :he s::end :arrie: an death f:r can:: s of allsites,in:!uding c:;ual risk of abcu: ! year's !:ss of heaJth. The
- u>:::mir., is quoted is 26.4 men:hs third prebably invches an averag: risk in :he harm whor -
fc abeu: 7 CCO pa:ients in whem ::di:1! order of 10 ' rem
- of sev:re.1 years of dis-
- men: was possibic:nd 5.3 months acili:y. and of a rather higner risk cf a scrae.
"c3".E.
in !! 000 in whem it was no: giving 2 wha:!cng: pe-icd ef:.nxie:yaftera:paren:ly value fer z!! patients of accut l! sue::ssici treatmen:. It s::ms reasonsb!: to men:h!." ' Tais iigure should pr0babiy suppose th.t mos: people would regard :he tn fa"-
w..p
be in ::ased slightly :o enpr:ss me:n. firs: : mponen: 25 d:rninant in its impac:,
g "ge,
rather tran median survival; with mere im:Or:an:: 2::2:hing to 10-15 beln*e-(:: Th: period et :llness or c..:sa:mty, in-yes s tess of life :han :o the :ctres;ondm.g fro-
- !udin any operatica. :n e:n::-s : hat periods of 1 ye:r's t:r nmal illness or sub-
- re no: fata!. and the.tnxie:y as to a stantially sma!!:r chant:5 of rather longer with.--
re:urrence ci the can::: af::: treat-perieds of::mper:ry filness or of continuing men:.
anxie:y in som:::ses. !f sc. :n..ts wou!d suggest mjur.- -
t"b..
p:) The -isk of cen. fatal: n:::is likely:o that the to:al imp::: Of sem::i: effe::s cf
'f b: ::.::mbie with :h:t for '"-'------< : : radiation wou'd. :s re;2rds dura:!cn cfloss
- I" gre:: majori:3 be:ng : nose of Air. :hyrcid er of life or healtb. !!: in :he re;ien of 1.5104
$,p.;.
tre ::. i cr skin. :he sever:ty et symptems, rem '
malizr c;:=:10r. anu. probably, mi::y an all h.. su.y (c) Genef.:
ation -- -
-if s:
RADIATION-INDl!CED GENETIC EFFECTS men..
fe:-
(2.2)The h r.a::-ibumble:c gene:ie:ffe: s
- inc: from :hn:centribu: d to me ; cpu-
-b? D -
of c:uic:ier m:he des::nd:nts ef:h :.cesed lation as :. wne!:1. shou!d 2 : cunt be Ofa:
- en n d
- :enui :- ::::ily upon a numb:r of
- aken onlyof;:ne:ie:: mage e pressed
-per-c e:m e-3 w ni:n re essenti:!!y m:t:ers of in his :hildre.. er Of m:: in his gt:nd.
l 2nd c: in e.-
children ise. er Of m.: in :1: future
" na: -
t:, In e<:ir-::ing the narm c.:erien::d by gene :tions?
.: worke 's cwn experi.
I to ther.
- vorier ex;csed :o r:ul:::0n as dis-en of:en;; :::i:;m.crm hties ahich t
enec a 1023 i80 w
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P00R ogjyg,
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PROBLEstS INVOLVED IN DEVELOPtNO AN INOEX CF HAR5:
25 t,
mi;nt be due to his own exaciere will U.:) The cpinien eculd be held : hat the first 1
be limited to the first :wo generations. tu o oithe:::endi.icns inveived a gt::ter Icss I
The worker's anxiety and that of :he of ;c::mi:1 life than the :nird, and should be werker': ".ife (or husband) will prob-sis en gre:ter weighting. E;us!!y, and perhaps ably.lscr be lars:!y in re;ard to these mer: probably, the vi:w might be taken that gener:tions rather than to a.ll their injury ex:::ssed :nd experien :d in the live-f pesterity. In considering limits for bcrn only should be :aken in:o a: oun: :nd j
o: upation:1 radiation ex;csure there. tha:. to :h: worker or :o his wife, t."e failure of 5
t fore in terms of the harm that maf impian:atica is recognia:d caly as the missing i
reult, it may seem reason:ble to ine!ude of a mens:rual period. and : hat an early and
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g:ne:i: harm expressed wi:hin the irs: non.viabi: abortion ::u!d b: reg:rded as :he
{
r two generations only, although of failurc cf adisabled life:o ce:ur.
course the total harm to all generations N5) Tner: is clear!v consid:rable latitt:de re:uires :o be included wnen :he harm for differ:nces of 0;inien en thes: poin:s.
i to :h: whc!e popu!r. tion :: suiting from which re:uire discussien.N!eanwhii. hew-
{
c::upational ex;csure is considered.
ever, i: wculd be valuzhie :: ob:2in es:ima:=s p
Of d: N:03:::Y * "5 EW5d j
(w) p...,.,..w.;
.a..i..g weg;.a s. $ v..,.w, im w
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" q.
w..... - w... r~..s a.d....c*. i n t h.a. w o r k-.,_'",",'j
", ",. ' ', ' ',, ' " " ",,, ' ~ '
f,
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..-.c
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4 w.'.o r*... *..'..-*.s so u.*. r *.*. sC..al initiatiVC ',,, ', ' ' " ',,, ", ' " ' ', ' ', ', ', "
- g in t..,[vi.,
i.
..- r. i. -
e
.,;oym..;.7..
g-
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- cssibi
- harm :o.1=se!!. :u:in his et f.
to tne harm cf cc:u;r.:icn:! c.pesure essen:i-s ;-* n t who
'**.av be harmed fr0rn al.o Ov the !:. su:n ma;ct cc::::s a arc ex;tesse :n inf.ncy be::use of.,,.:.s ex;0sure an.s vecc n of th: Ers: two gen: rations of wi:hout tneir personal en.o::: m :ne ot: 5:rms of : : e.x;csed. dividuals.
t in.,
m::t:r, _i ne ;cssicti.ttv et such har:-.
N6) _t ne ns,,. or su n de:.:::s :s esumated J
bein-expressed :.n his own :.u.ildren frem th.,requen:ies :: serve: m :n: c ffs pring i
frem th:.:r birth mt;n: :.,early u. ave a
. or ;rractated am.mals ;ar:icular!v mic:. wi:h mu:n heav:.er w::;nung u::n h:.= anc
- ,=igc3 ;g 3g 3w f he 3 cf the hut.
- n r
- w...g
. s w i..., a. w u !w" ',. -l v. '.o.~.. - !
e.
.......,s u, t.: _ u.. s... :. a.Cw,
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....4 3.
e 3. C.
injury expressed m. himselt-It migh:, pg.,
t
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.w,..r....,. r..aser.a.". P.r.a - r. a
- tv a
-.1 ::.. is n,.
.....cf
....... is
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we: nun: :c each con.ta:a! bu: sub.
- s ex:: sse.a. :n 21, ;teg:ny cc:urring 6
s e
r 5::nu:: tent::::::en. u h:en we.s :ua subuquen: :o the irracia:ica of fer:n-.=
to :hr.: Of a loss of life from a fa:al a m.:Is. i ne :Or es;:n, :ng c:sxs m::rred ior s.
... -.%-...y in t.w.. w e r k. '.t..s.' f.
=an. et 10 rem- (:f sericus h: :di:ary IE-
[
(:) Genetic abncrmalities indue d by radi-heahh dur;ng :he firs: two ;:n: ations,iin is
[
- icn m:y:
therefor: the.: which would 2;;iy :o a popuia-
[
ii
-if severe, cause failure of deve!cp-tien of fertile incividuals i. adiat:d prior to L
m:n: cc of impiantat:en of the cene ;tienof:heiroffspring.
)
feruli::d ovum;
(). or working ;0;ula:icns of ages !S-
'f
-be seser: :nough to cause aber:ica 65. mes: ::;cseres wi:1 he re::ived 2: a; s at cf a non-vi::ie fe::us:
which the sutsequen: :hild ex;::::ney is
-;:::-h d:v::c; men: to : s i:bie s:ag
- duerd, and some ex;csure w:11 have no a nd :e esernsed in a live:cen child.
3:ne:i:im:an b:::ese o f :he i::k of :hildren l
Y..:: :::::ve wc:;n:s shecid :: giv:n ::ne::vec su sequ:n:N: a!:ncugn 2: young j
- o:.:ne; ssi:ili:ies?
ages, wh-n the subse:uent :niid expen:n:/
.i 1023 101h i
11
- .nClosurei n a
- a..
t 16 A REPORT CF THC INTERNATION AL CO.stMISSION ON RACIOt.CCICAf. PROTECTION T4st t 10. CtstitCALLY sicsarocsNT compost 37 av co.ssTAsr s3su^t LNPC5c:E or 5couNC.Pw-1. Artes.
slight.
Actst$.65 tIw.
M:les Females ghe g re of tare 5l~
Ret:tise child re of R:Istive child Ace group exceet:nv
= cpu :: ion P-:cuct
- .:ce:sney*
pe:ut:rien Preda::
g 13-0.934 7.1 7.0 0.931 17.2 16.0 cr:pos
- 0-0.366 12.2 10.6 0.D0 22.7 16.6 g[gy".
25 0.334 10.3 6.3 0.401 10.3 42 in Sim R
30-0.293 10.1 3.0 0.!!$
6.3 1.0 -
35 0.121 9.7 1.2 0.016 6.4 0.3 par !: h-
.t0 0.%t 10.3 0.3 0.003 7.3 0.1 lation 43 0.015 11.0 0.2 0.0 1 3.9 fore.::...
30 0.005 9.4 invo[*
23-0.002 10.0 t.s.
2,3 60-0.00 t 9.4 100
- 3.s too 3s2 Table Genet:c:lly signific:nt ft:::icn 029 0.33 appr
'Mean suo e uent ehild c.s:c::1.:y in age 3r:u:. reistne to salue of unny at :st before ::rer.c.ced.
Sr0c; I:ste ;
remains near!y maximal, the ri5k of im; air-to dif merc in offspring will a;;rca:h th: figure of be:we 10" r:m-'.
The a5 erage fra:: ion ci00::;ational radia-3::ter-TAALF. ti. CtstT!C4LY 3IONOC.LNT ratac :c3 CF Sta It O n,.X.,..,5 u r., t..
5.
.,1'0., {ly r 3.,.;.r: 4.
% 1......
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12 EnClos6 A.1023 j2
!i OPTIMIZATION
/
There are four difficulties with " optimization" that, from the staff's viewpoint, are collectively prohibitive:*
1.
Selection of a dollars per-manrem criterion would be arbitrary; the value selected would be tied inextricably to a monetary value for numan life, e.g.,
510,000,000 to si s
- 1;re is associated with 1,000 S/manrem, 51,000,000 with 100 S/manrem, 5500,000 with 50 $/manrem, etc.
2.
The establishment of a dollars per-manrem criterion by the Federal government would likely result in hazard pay for workers based on the numcer of rems received; this situation could promote a non-cooperative attitude from workers regarding their own protection and could lead to the substitution of premium pay for protective measures that are more expensive.
3.
Wnatever the value selected for the dollars per-manre:a cMterion, implementation of the " optimization" procedure would eliminate the use of some protective measures that have been commonly employed by
- The term " optimization" refers, for all practical purposes, to a procedure for decisionmaking, on questions of occupational ALARA, which requires the use of a collars per-manrem criterion.
The term was first introduced in ICRP Puolication 26, al hough the report does not suggest a value for this criterion.
1023 133 1
Enclosure A
licensees for many years on a voluntary basis; in these cases, the Federal govenment would be taking regulatory action that would reduce the degrae of worker protection now provided.
4.
To implement the " optimization" concept, it is necessary to calculate the number of manrems that will be saved, to divide this number into 7,.
the cost, and to compare the result against the dollars per-manrem criterion.
Example calculations performed by the staff have revealed (a) that a pre-selected value for the number of manrems saved rnay be cbtained by varying the assumptions used in the calculation, and (b) that values selected in this manner for the assumptions can usually be made to appear reasonable.
The " optimization" concept does not, therefore, provide a sufficiently sound technical basis for a r egulatory program.
1023 101 2
Enclosure A