ML19261D597
| ML19261D597 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1979 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Sacco E AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19261D598 | List: |
| References | |
| FRN-44FR10388, RULE-PR-19, RULE-PR-20, TASK-OH-921-1, TASK-OS NUDOCS 7906200301 | |
| Download: ML19261D597 (3) | |
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MAY 2 21979 lis. Emma Sacco 63 Boon Street flarragansett, Rhode Island 02882
Dear Ms. Sacco:
Your letter to Chairman Hendrie dated April 25, 1979, has been referred to this office for reply.
Your letter asks for an explanation "why nuclear workers receive higher radiation doses," and "why the higher levels were set in the first place."
Your letter indicates that you have seen the February 20, 1979, notice of proposed deletion from the Commission's regulations in 10 CFR Part 20 of the long-sl.anding 5(f!-13) dose-averaging fonnula.
That provision allcws an individual worker to receive up to 12 rems in a year, if the licensee has obtained the individual's lifetime exposure history, and if that individual's total dose does not exceed the formula S(ft-18).
In the formula,11 equals the individual's age at the last birthday.
The provision assures that, on the average, and considering all previous employment, the individual doe, not exceed 5 rems per year.
The standards in 10 CFR Part 20 are based on recommendations of recognized scientific bodies such as the National Council on Radiation Protection and Measurements (I'CRP), the International Commission on Radiological Protection (ICRP), and on guidance for Federal regulatory agencies issued by the forrp Federal Radiation Council (FRC, the function of which is now incorporated into the Environmental Protection Agency).
These standards are amended as appropriate to naintain them current with the best information available on the health effects of iaizing radiation.
It is assumed that there is some risk asstciated with any ionizing radiation exposure.
However, as stated in paragraph 117 of ICRP Publication 26, " Radiation risks are a very minor fraction of the total number of environmental hazards to which members of the public are exposed.
It seems reasonable therefore to consider the magnitude of risks to the general public in the light of the public accept ~ nce a
of other risks of everyday life." The radiation risks are, of course, in addition to other occupational risks. However, since average radiation risks are small, the estimated combined average lifetime risks from both wholebody radiation exposures and nonradiation hazards in the occupationally-exposed work force are estimated to not differ significantly from those for comparable occupations not involving exposure to radiation.
Further considerations conclude that the level of acceptability of risk to the general public is about a factor of ten lower than for occupationally-exposed individuals because as stated in paragraph 42 of ICRP Publication 9, " members of the public include children who might be subject to an increased risk and who might be exposed during the whole 2310 050 7906200$d/
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of their lifetime; members of the public (in contrast to radiation workers) do not make the choice to be exposed, and they nay receive no direct benefit from the exposure; they are not subject to the selection, supervision and monitoring required for radiation work, and they are exposed to the risks of their own occupations." Efforts made by licensees to keep occupational radiation doses as low as is reasonably achievable ( ALARA, pursuant to 20.l(b) 10 CFR Part 20),
as well as below regulatory dose-limiting standards, have resulted in average radiation doses that are about one-tenth of the standards (see enclosed l'UREG-0419 and NUREG-0463).
Considerably less than one percent of monitored workers receive doses above 5 rems per ycar such that they would have needed the dose-averaging provision.
However, the notice of proposed rulemaking seeks comment and technical information on the value and impact of the proposed amendments.
The notice of proposed deletion of the dose-averaging provision from the regulations was based on a number of factors. Among them were assessment of the need for that provision in order to accomplish essential work, the Commission's continuing systematic assessment of exposure patterns, new recommendations of the ICRP that drop the dose-averaging formula, recently published interpretations of epidemiological data and associated recommendations for lower standards, and also petitions for rulemaking to lower the dose standards filed by the Natural Resources Defense Council and by Dr. Rosalie Bertell.
The proposed action is only one part of a broader action that involves reassessment of current dose-limiting standards and strengthened implementation of the ALARA concept.
The broader action involves not only the Nuclear Regulatory Commission, but also the Environmental Protection Agency (EPA) and the Department of Labor's Occupational Safety and Health Administration (OSHA).
The EPA, under the role of the previous Federal Radiation Council, is reevaluating the guidance provided to Fedcral regulatory agencies regarding standards for protection against radiation and is preparing revised guidance for the agencies.
The EPA has had a contract with the National Academy of Sciences - National Research Council for a detailed study of the information available on the biological effects of low-level radiation exposure.
This study has very recently been published as a third report of the Advisory Committee on the Biological Effects of Ionizing Radiation (BEIR).
The EPA guidance will reflect consideration of this information.
The NRC and OSHA are coordinating efforts with EPA on this matter.
Plans are being made for EPA-NRC-OSHA co-sponsorship of a public hearing on the draft EPA guidance and related matters.
NRC and OSHA then expect to promulgate amendments to their respective regulations to implement the new EPA guidance, with ample provision for public comment including additional unilateral agency hearings. The notice of proposed deletion of the 5(N-18) dose-averaging formula specifically invited comment on the desirability of including the proposed amendments within the scope of the hearing.
The NRC has received a number of comments on the proposed amendments and will probably include this action in the scope of the proposed hearing, or hold a separate hearing specific to this issue.
2310 251
, We believe that this infonnation is responsive to your letter.
!{owever, if you have further questions do not hesitate to communicate with this office again.
Sincerely,
%I 0.
b%vr Robert B. Ilinogue, Director Office of Standards Developnent
Enclosures:
10 CFR Part 20 fiUREG-0419 fiUREG-0463 2310 M2