ML19261D869
| ML19261D869 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1979 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Paul R HOUSE OF REP. |
| References | |
| FRN-44FR10388, RULE-PR-19, RULE-PR-20, TASK-OH-921-1, TASK-OS NUDOCS 7906260582 | |
| Download: ML19261D869 (9) | |
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The Honorable Ron Paul House of Representatives Washington, D.C.
20515
Dear Congressman Paul:
Reference is made to your letter of April 18, 1979, that transmitted a copy of a letter from Walter P. Peeples, Jr., President, Gulf fluclear, Inc.
The letter from fir. Peeples coments on a notice of proposed rulemaking published by the flRC in the Federal Register (44 FR 10388) on Fnbruary 20, 1979, copy enclosed.
In brief, the proposed amendments to 10 CFR Parts 19 and 20 of the Commission's regulations would delete a radiation dose-limiting standard option from 10 CFR Part 20, and thereby limit individual workers at Commission-licensed activities to a quarterly dose of 3 rems and an annual dose of 5 rems.
Under the present option, certain workers are permitted to receive as much as 12 rems in one year provided that they do not exceed a lifetime accumulated dose exceeding 5(fi-18) rem.
In the formula, il equals the individual's age at his last birthday.
The proposed action is one part of a broader action that involves reassess-ment of current radiation dose-limiting standards and strengthens implemen-tation of the concept of maintaining all radiation doses as low as is reasonably achievable (ALARA).
The broader action involves not only the
!!RC 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 Federal regulatory agencies regarding standards for protection against radiation, and is preparing revised guidance for the agencies.
The EPA has a centract with the liational Academy of Sciences' flational Research Council for a detailed study of all of the information available on the biological effects of low-level radiation exposure. This information 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 f4RC and OSHA are coordinating efforts with EPA on this matter. Plans are being made for FPA-fiRC-0SHA co-sponsorship of a public hearing on the draft EPA guidance and relatc<i matters. flRC and OSHA then expect to promulgate amendments to their respective regulations to implement the new EPA guid-ance. with emple provision for public comment including additional unilateral agency hearings.
Following consideration of a staff paper discussing "Further Actions to Control Risks Associated with Occupational' Radiation Exposures in NRC-Licensed Activities" (SECY 78-415, copy enclosed), the Commission directed the staf f to issue a notice of proposed deletion of the 5(ff-18) 2159 146 7#Rh@$L
m Honorable Ron Paul dose-averaging formula, with confoming amendments to related sections of the regulations, without further delay pending resolution of other actions being considered.
The notice of proposed rulemaking specifically invited comment on the desirability of including these proposed rule changes within the scope of the hearing planned on the broader actions, including the EPA-revised guidance for Federal regulatory agencies.
The fiRC has received a number of comments on the proposed rule changes, including the comments from Mr. Peeples, and will probably include this action in the scope of the proposed hearing, or a separate hearing specific to this issue.
We would like to respond to the specific questions and comments in Mr. Peeples' letter.
1.
For many years, our regulations have specified a basic dose-limiting standard of 1.25 rems per calendar quarter, with a provision that a licensee may permit an individual to receive up to 3 rems per quarter provided that the licensee obtains the individual's occupational radiation exposure history, and provided that the individual does not exceed the 5(11-18) dose-averaging formula.
If an individual receives a dose in excess of these dose-limiting standards, the licensee has been required to ensure that ra further dose is received for the remainder of the quarterly period.
Under the proposed amendments, the basic quarterly standard would be raised to 3 rems, thereby pro-viding the flexibility in the use of skilled workers needed by some licensees, and establishing a 5 rems per year limit.
The proposed amendments would, as Dr. Peeples notes, require licensees to ensure that any individual receiving 5 rems or more will not receive further dose for the balance of that year.
We recognize that this situation could, in a few cases, result in employment hardship and we will be carefully studying this aspect of the proposed amendments as we finalize the action.
2.
[10 thing in the notice of proposed rulemaking should be interpreted to imply, as Mr. Peeples does, that the liRC supposes that "no one tries to control levels" of radiation exposure.
Rather, the fiRC rectgnizes that licensees have made efforts to control doses within the regulatory limits.
1he efforts made by licensees to maintain radiation doses as low as is reasonably achievable (ALARA), pursuant to 20.1(b), 10 CFR Part 20, have resulted in most individual doses being well below the limits. This means that the deletion of the 5(l1-18) dose-averaging formula will have little or no effect for a high percentage of licensees and employees).
3.
The data on individual doses received by individuals monitored in the four categories of licensees that were considered to represent the greatest potential for significant doses (power reactors, industrial radiographers, fuel processors', and certain large commercial suppliers 2159 147
Honorable Ron Paul 3-D J
J individuals monitored by these licen<,ces received doses in excess of 5 rens during 1977 (the nMt recent data available at this tine). Of the 319, 270 were enployed by paver reactors,15 by industrial radiog-raphers, and 34 by the large comaercial byproduct material suppliers.
With regard to fir. Peeples' suggestion of establishing tuo divisions in !!RC, one for power reactors and the other for byproduct raaterials, the I;RC already has recognized a separation in the licensing process by the establishment of the Office of I'uclear Reactor Regulation and the Office of fluclear liaterial Safety and Safeguards.
As I.ir. Peeples correctly notes, current fiRC dose-limiting standards apply equally to all licensees, irrespective of any particular nuclear occupational fiela.
These stsndards are anended as appropriate to naintain them current with the best information available on the health ef f ects of ionizing rcdiation.
4.
Yes, en are including consideraticn of the petitions from the f!atural Rescurces Defense Ev~il 'nd from Dr. Rosalie Bertell in this natter, as well as fcetors relating to the health and cafety of workers and the public.
Our effe-ts to assess the value and impact of proposed anhents are reflected in the preparation of value/ impact statcoents such as tFe one set forth as Enclosure "F" to SECY 78-415.
lhat statenent prinarily considered petitions for reduction of the dose-limiting standards and further actions to be taken to control risk. 3ssociated with eccupational radiation exposures, but supported the proposcd deletion of the S(N-18) for.nula.
Ubile the somewhat limited infonnation available to the Comission indicates that the impact of the proposed deletion would not be significant in vieu of the efforts to maintain occupational doses ALARA, one purpose of the published notice of proposed rule naking was to elicit coments and infonaation on the value and impact of the proposed amend.nents.
We assure you that all ccments and information submitted, including f4r. Peeples', will be carefully considered.
Sincerely, r
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Enclosures:
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44 FR 10388 KRGoller OCA 2.
SECY 78-415 RAPurple PDR TM 3.
10 CFR Part 20 REAlexander WSCool SD:DD RGSmith 2159 148
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