ML19309H405
| ML19309H405 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML19309H406 | List: |
| References | |
| NUDOCS 8005130160 | |
| Download: ML19309H405 (18) | |
Text
' Q g0$130lW O fp UNITED STATES f
g
(
NUCLEAR REGULATORY COMMISSION T
W ASHINGTON, D. C. 20665 g
\\
gr April 24, 1980 CHAIRMAN The Honorable Morris K. Udall, Chairman Committee on Interior and Insular Affairs U.S. House of Representatives Washington, D. C.
20515
Dear Mr. Chairman:
This is in response to your letter of March 11, 1980 requesting answers to several questions related to the report of the National Academy of Sciences' Committee on Biological Effects of Ionizing Radiation (BEIR III) and certain aspects of occupational radiation protection.
We note that the BEIR III report has not been issued in final. A draft was released in 1979 that did generally reaffirm past estimates of the risk from exposure to ionizing radiation. A new draft of the BEIR III report is being prepared, but has not yet been made avai.lable to the NRC.
The Envirormental Protection Agency (EPA) is revising and updating the guidance to Federal regulatory agencies prepared by the Federal Radiation Council and signed by the President in May 1960. An advance notice of that work was published by EPA September 17, 1979 (44 FR 53785), and EPA is expected to publish draft revised guidance this summer. Following publication of the draft guidance, we are currently planning to hold joint hearings with EPA and the Department of Labor's Occupational Safety and Health Administration (OSHA).
OSHA and NRC would then develop appropriate amendments to their respective regulations to implement the revised guidance.
We anticipate that the findings and recommendations in the BEIR III report will identify issues about the risk associated with low doses and low dose rates of ionizing radiation, and that these issues will be considered in the hearings.
There is a consensus among scientific committees, such as BEIR, NCRP, ICRP, and UNSCEAR that, with the exception of natural background radiation, the largest contributor of radiation dose to the population is dose received by patients during medical X-ray diagnosis and therapy. The use of X-ray machines, whether in medicine or other fields, is not subject to NRC regulation pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, as amended.
Further, certain naturally occurring radioactive nuclides, such as radium-226, and accelerator-produced radionuclides, largely used in medicine, are not subject to NRC regulation. The regulation of naturally occurring and accelerator-produced radioactive materials was the subject of a special study conducted by the NRC staff, the results of which were published as NUREG-0301 in July 1979 and provided to you by letter dated August 15, 1979.
Copies of this report were also transmitted to all state governors. The governors were informed that the NRC intends to bring this matter to the attention of the Radiation Policy Council. However, NRC licensees must monitor doses received by a worker from the use of such sources of radiation if any portion of the worker's dose is received from licensed material.
P
The Honorable Morris K. Udall '
While the average of individual occupational dose is higher in nuclear power plants than in medical programs, there are many more individuals occ~upation-ally exposed in licensed medical programs.
It appears that, if consideration is taken for doses received by medical workers in programs licensed by Agree-ment States, the collective occupational dose to medical workers may approach or exceed that received by nuclear power plant workers.
Further, many of the medical personnel are young women of childbearing age, involving the additional risk associated with dose to an embryo or fetus.
As you are aware from NRC testimony previously presented and the notices sent i
to your Committee from time to time, the Corrnission has been very active in the area of prevention of risk from occupational radiation dose and has taken a number of steps to assure that such doses are maintained as low as is reasonably achievable (ALARA). A high percentage of this effort has been directed to nuclear power plant operation and very recently to medical programs.
In the case of the medical programs, investigational levels have been estab-lished in model programs at fractions of the dose-limiting standards. Doses exceeding any investigational level would require investigative and corrective action by the licensee, increasing in scope and depth as higher doses are experienced. These programs reflect a concern about the contribution of such programs make to collective dose, and is consistent with the draft BEIR III conclusions. While actions being taken would add little or no regulatory requirements for record-keeping, considerable effort is being made to assure that radiation protection programs are adequate. Some examples of the effort include:
special team appraisals v. the health physics programs at each operating nuclear power plant; current efforts to revise 10 CFR Part 20 to incorporate many of the recommendations of the International Commission on Radiological Protection and the draft BEIR report; consideration of requiring mandatory ALARA programs at power reactors and other major licensed facilities; and consideration of requiring power reactor licensees to submit a formal radiation protection program that includes commitments to many of the NRC's regulatory guides. Consideration is being given to requirements for the submission of certain reports of personnel monitoring permitting closer scrutiny of the doses baing experienced by many categories of licensees, including medical licensees, and the feasibility of using such data, with other data, for epidemiological purposes is being investigated.
Notable among the tasks that have been, or are being developed, are two of particular value to worker protection at nuclear power plants:
Revision 4 to Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable (ALARA)"; and a draft Regulatory Guide 0H714-4, " Application of Bioassay for Fission and Activation Products." NRC documents of particular pertinence to medical programs that have been or are being developed are: Revision to Regulatory Guide 8.20, " Application of Bioassay for I-125 and I-131"; Revision 1 to Regulatory Guide 10.8, " Guide to the Preparation of Applications for Medical Programs"; Revision 1 to Regulatory Guide 8.23, " Radiation Safety Surveys at Medical Institutions"; Revision 1 to Regulatory Guide 8.18, "Infor-mation Relevant to Ensuring That Occupational Radiation Exposure; at Medical
.--..-w-y.
~
i The Honorable Morris K. Udall Institutions Will Be As Low As Is Reasonably Achievable"; and NUREG-0267, 1
" Principles >1d Practices for Keeping Occupational Radiation Exposures at Medical Institutions As Low As Is Reasonably Achievable."
With respect to your question 3, NRC does not have any actions underway that would require additional measurement and record-keeping of doses received by i
patients undergoing diagnosis or therapy, or that would require summation of such medical doses with occupational doses for purposes of controlling the total. However, the Commission recently approved a final rule that would require medical licensees to report misadministrations of radioactive material.
The safety and efficacy of radiopharmaceuticals, including the recommended dosage range, is regulated in most instances by FDA.
Licensees continue to be required to maintain records of tha results of all personnel monitoring of occupational doses that is require' :o be performed pursuant to the regulations in 10 CFR'Part 20. Amendments thou were published June 6, 1979 (44 FR 32349),
and became effective August 20, 1979, related to the control of radiation exposure to transient workers, require licensees to take certain steps to assure that the total occupational dose is controlled, even if some portion of that dose is received from sources not in the possession and control of the licensee.
Further we have taken additional steps to assure that the evaluation of doses received by workers is as accurate and precise as is reasonably achievable.
An advance notice of our intent to require NRC licensees to use dosimetry services that are capable of meeting a consensus ANSI standard, was published March 28, 1980, copy enclosed. A comparable effort to assure that licensees use accurate and precise health physics survey instruments is being initiated.
Again, these actions do not require consideration of natural background radia-tion dose or dose from medical diagnosis or therapy, as a patient. Guidance to Federal regulatory agencies developed by the Federal Radiation Council and signed by the President on May 13, 1960, directed that the numerical guides set forth "are not intended to apply to radiation exposure resulting from natural background or the purposeful exposure of patients by practitioners of the healing arts." That guidance was implemented by 520.107, 10 CFR Part 20, which states that "Nothing in the regulations in this part shall be interpreted as limiting the intentional exposure of patients to radiation for the purpose of medical diagnosis or medical therapy."
In response to your question 4, occupational radiation exposure of those who work in uranium mines is under the regulatory jurisdiction of the Department of Labor's Mine Safety and Health Administration (MSHA). MSHA also has regulatory authority in this area. The NRC has signed a Memorandum of Understanding with MSHA calling for a trial joint-inspection program between NRC and MSHA with the intent of coordinating inspection efforts.
With respect to your question 5, yes, licensees are required to provide the same degree of training, personnel monitoring, and record-keeping for employees of subcontractors as for their own employees. The regulations pertinent to these matters (619.12,10 CFR Part 19; 6520.202 and 20.401, 10 CFR Part 20) are expressed in terms of individuals entering, working in or frequenting any portion of a restricted area of a licensed facility.
l P
~
The Hororable Morris K. Udall Thank you for the opportunity to respond to your concerns in this matter.
This letter covers much and, if you wish, we would be happy to provfde you with more detail on any item or to brief you or your staff.
Sin erely, 1
John F. Ahearne
Enclosures:
(See Page 5) 1 1
I s
1
.=
Honorable Morris K. Udall List of Enclosures 1.
Proposed Revision 4 to Regulatory Guide 8.8 (Task OH 507-4) 2.
Applications of Bioassay for Fission and Activation Products (Task OH 714-4) 3.
Revision 1, Regulatory Guide 8.20 5.
Regulatory Guide 10.8 7.
NUREG-0267 8.
SECY-80-26 (Final rule to be published in early May) 1 9.
Advance Notice of Rulemaking on Certification of Personnel Dosimetry Processors l
s 1
l 4
e
- 9
~
[7590-01]
NUCLEAR REGULATORY COMMISSION
[10 CFR Part 20]
Advance Notice of Rulemaking j
on Certification of Personnel Dosimetry Processors AGENCY:
U.S. Nuclear Regulatory Commissian ACTION:
Advance notice of rulemaking to improve accuracy in personnel dosimetry.
SUMMARY
Tests have indicated that a significant percentage of personnel dosimetry processors may not be performing with an appropriate degree of accuracy.
Alternatives for action to correct this situation are presented.
Interested persons are invited to submit comments on these alternatives.
1
. DATES:
Comment should be received by
)
ADDRESSES:
Comments or suggestions for consideration in connection with these alternatives may be sent to the Secretary of the Commission, U.S.
Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch.
Copies of comments received may be examined at the Commission's Public Document Room, 1717 H Street, NW.,
Washington, D.C.
FOR FURTHER INFORMATION CONTACT:
Mr. Robert E. Alexander, Office of Standards Development
.S. Nuclear Regulatory Commission, Washington, D.C. 20555, 301-443-55 1
[7590-01]
SUPPLEMENTARY INFORMATION:
Recent tests indicate that a significant percentage of the personnel dosimetry processors in the United States are not performing with a degree of accuracy acceptable to the NRC when compared against a consensus standard prepared under the auspices of the American National Standards Institute.* To the extent that these test results are representative of routine field conditions, the results indicate that the dose received by occupationally exposed personnel may often be considerably different from the dose reported by the dosimetry processor. Where complete reliance for individual dose determinations is placed on personnel dosimeters, control of individual radiation expo-sures may not be accomplished as well as is indicated, and compliance with regulatory dose limits may not, in fact, be achieved.
The test results indicate that individual doses may be over or understated.
Further, these incorrect measurements could become a source of error when the dosimetry data are used in epidemiological studies intended to investigate the dose-effect relationship.
The principal causes of the inconsistent test measurements that have been observed are not well understood.
There is some evidence that the inconsistencies are due primarily to differences between the dosimeter irradiation techniques used by the tester and the calibration methods used by the processors; this possibility is discussed in the following paragraph.
However, actual inaccuracies may arise because of inadequate quality control in dosimeter manufacturing or in a few cases because of ineptitude on the part of the processor.
These different problems would aPilot study conducted for the NRC by the University of Michigan.
2
[7590-01]
require different solutions, so that appropriate regulatory corrective action is very dependent on a better understanding of the causes of the problem.
Regarding the adoption of methods for correcting this problem, it is evident from at least two important considerations that caution should be exercised.
First, as previously mentioned, the inconsistent test mea-surements refer to differences between the amount of radiation delivered to a dosimeter, under highly controlled laboratory conditions, by the individuals conducting the test, and the amount of radiation subsequently i
reported by the processor.
These tests do not necessarily measure the difference between the radiation delivered to a dosimeter worn by a worker and the radiation subsequently reported by the processor.
For example, the radiation source used by the processor to calibrate the dosimeter may emit radiation of the same or very similar cuality as the radiation to which the worker is exposed, but may be quita different from the radia-tion used by the tester to irradiate the processor's test dosimeters.
Thus, standardization of calibration techniques among U.S. processors, which may be essential for achieving good performance in a test program, could in some cases produce apparent improved accuracy while actually introducing greater errors in the personnel dose measurement process.*
This consideration is an integral part of the personnel dosimetry problem and must receive full consideration in corrective action planning.
"For example, a processor may calibrate beta dosimeters for workers at a uranium fuel fabrication plant using a uranium slab; the tester may use a strontium-90 source.
The processor could then measure the workers' doses accurately but could fail the performance test.
3
[7590-01]
Secondly, any regulatory action taken must be handled in a manner to ensure that sufficient personnel dosimetry services remain available.
Unnecessarily severe or improper corrective action could reduce the number of available processors to the extent that the dose determinations for some workers could be adversely affected.
One of the major sources of error in personnel dosimetry is known to be the potential difference between the actual dose received by the dosimeter and the actual dose received by the wearer.
Such differences can, for example, be due to shielding of the dosimeter by the body when the worker is not facing the source of radiation or due to different irradiation of the part of the body on which the dosimeter is worn than of other parts of the body.
These sources of error are recognized but are not part of the dosimeter processing problem that is being considered for correction.
A Federal Interagency Policy Committee on Personnel Dosimetry Perfor-mance has been formed to guide and coordinate correction of the dosimetry processor performance problem.
Represented on this Committee are:
the Bureau of Radiological Health (HEW), the Department of Defense, the Depart-ment of Energy, the Environmental Protection Agency, the National Bur, eau of Standards (NBS), the Nuclear Regulatory Commission, the Occupational Safety and Health Administration (DOL), and the Conference of Radiation Control Program Directors (States).
Dosimetry processors and users have indicated agreement that some corrective action is appropriate.
A work-ing group of the Health Physics Society Standards Committee (HPSSC) has developed and the American National Standards Institute (ANSI) has pub-lished a draft standard for dosimetry performance (N13.11, July 1978).
This standard is considered to be the most important element in a corrective i
4 l
l
[7590-01]
~
program.
An industry committee (Personnel Dosimetry Overview Committee) has been formed to assist in ensuring that any proposed regulatory action is effective and appropriate to the need.
However, agreement has not been reached as to the specific action that should be taken.
Alternative corrective actions under consideration are discussed below.
Recent Federal Government Action Some time ago, on November 30 and December 1, 1976, the Nuclear Regu-latory Commission and other Federal agencies conducted a public meeting at which the personnel dosimetry performance problem was discussed in an open forum by personnel dosimetry processors, dosimetry users, and repre-sentatives of State governments and Federal agencies.
Other co-sponsors of this meeting were the Energy Research and Development Administration (now the Departm nt of Energy) and the Bureau of Radiological Health.
These discussions revealed general agreement that a personnel dosimetry problem does exist and that the problem is sufficiently broad in scope that it should be addressed by the Federal government.
However, many of the attendees cautioned against precipitous action and strongly recommended a pilot study (1) to evaluate the draft HPSSC/ ANSI standard and (2) to provide processors the opportunity to take any necessary corrective actions in their operations prior to the implementation of new Federal regulations on the dosimetry performance problem.
These recommendations were accepted, and the Nuclear Regulatory Commission (NRC) subsequently issued a contract to the University of Michigan (UM) to conduct a two year pilot study.
The objectives of this study were:
(1) to determine whether the draft HPSSC/ ANSI standard provides an adequate and practical test of dosimetry performance; 5
[7590-01]
(2) to give processors an opportunity to correct any problems that are uncovered; (3) to develop operational and administrative procedures to be used later by a permanent testing laboratory.
The study was completed December 31, 1979.
Conditions of the contract included a provision that any personnel dosimetry processor in the United States would be allowed to participate in the study on a strictly voluntary basis, provided only that the dosim-eters tested be restricted to those used to provide the permanent record of occupational exposures.
Processors were told that the UM would keep test results confidential (i.e., that no organization other than the UM would be able to associate specific results with the name of a processor),
that all results would be published (in coded form), that the UM would charge no fee for participation, that the new HPSSC/ ANSI standard would be used to evoh =te their performance, that each participant would be given the opportunity ?o be tested twice and would also be given an oppor-tunity to discuss with Uh personnel the possible reasons for any poor performance prior to the second round of tests, an,d that the accuracy of the irradiations provided by the UM would be verified by the NBS, and that UM facilities and equipment would be open to inspection by the participants prior to the beginning of the tests.
An open house was conducted for the latter purpose by the UM on April 20, 1978.
Fifty-nine processors participated in the study; it is believed that very few U.S. processors did not participate.
During the course of this study, the UM submitted monthly 6
m
-.,,.+,
~
1
[7590-01]
progress reports to the NRC.
These reports are available for inspection or copying in the Commission's Public Document Room, 1717 H Street, NW.,
Washington, D.C.
Copies may also be obtained by contacting the Public Document Room, (202) 634-3273.
The final report for the study, NUREG/CR-1064, may be purchased from National Technical Information Service, Springfield, Virginia 22161.
The draft standard allowed processors to be tested in eight different radiation categories.
The term " category" refers to the type of radiation being measured.
For example, Category 1 is gamma radiation, Category 2 is high energy X-radiation, Category 3 is low energy X-radiation, etc.).
I Within each category of the draft standard were several dose ranges called intervals.
The consensus standard used in the pilot study evaluated a processor's ability to consistently and accurately perform within a specific tolerance limit for each interval.
Failure to pass one interval within the category would cause a processor to fail the entire category test.
A performance index, P, was calculated for each dosimeter as (reported dose minus the delivered dose) divided by the delivered dose.
For each interval, I
the average performance index, P, and its standard deviation, S, were calculated.
The draft standard incorporated a statistical test, P + 25 equal to or less than a specific tolerance value.
The tolerance value for any given interval was a function of the average delivered dose and i
varied from 0.3 to 2.0.
A processor could only pass a given category if all intervals of a respective category were passed.
At the conclusion of the first round of testing, the results were examined by the NRC staff, by the Interagency Policy Committee on Personnel i
\\
7
[7590-01]
Dosimetry Performance, and by the industry's Personnel Dosimetry Overview Committee.
The results indicated poor performance on the part of many processors.
Only 23% of the category tests attempted by the processors were passed, using the criteria in the HPSSC/ ANSI standard.
None of the processors passed all of the tests attempted in the first round, but every category test was passed'by at least one processor.
These facts indicate that the standard is achievable and suggest that the problem may lie with the processor and/or with differences in i* radiation techni-ques used by the UM and those used by the processors during their calibra-j tion procedures.
The participants' performance in the first round was also evaluated used a simple percentage passed basis (as opposed to the mere complicated statistical formula of the standard).
Again, generally poor performance was indicated.
Using a simple 130% pass-fail criterion l
for each and every dosimeter in a category during the first round of tests, the weighted average of all the processors reveals 7% of the category tests were passed (i.e., all dosimeters tested in all intervals of the category fell within the 30% criterion).
Using a 150% criterion in the same manner, 21% of the category tests were passed.
Thus, the results using the draft standard are similar to those using the 150% criterion.
It had been anticipated at the beginning of the pilot study that processors who performed poorly during the first round of testing would be able to take corrective action prior to the second round and would improve their performance.
The second-round results did indicate improvement over the first round.
Approximately 35% of the category tests I
were passed.
Using a simple 30% pass-fail criterion for each dosimeter in a category during the second round of tests, the weighted average of all the processors reveals 19% of the category tests were passed (i.e.,
8
[7590-01]
all' dosimeters tested in all intervals of the category fell within 30%
criterion).
Using a 50% criterion in the same manner, 32% of the the category tests were passed.
Processor performance was not based on the percentage of dosimeters that individually passed the criteria set forth in the standard.
Of the 23,000 individual dosimeters evaluated during the pilot study, 85% of the dosimeters tested passed round one of the tests and 90% of the dosimeters passed in the second round.
Failure of the 15% and 10% of the dosimeters tested, to meet minimum tolerances established by the HPSSC/ ANSI in the stande.rd, is an unsatisfactory level of performance when determining indivi-dua' dose assessments.
In tk pilot study, for example, high doses (i.e.,
600 rads) delivered to some of the test dosimeters were actually undetected by some of the processors.
One processor, vnose results in the first round were very poor, worked with UM personnel to identify and effect the necessary changes in the process and then performed very well during the second round, passing all categories attempted but one.
Another processor passed all eight of the categories.
These facts provide rather strong indications that con-formance with the standard is attainable, but that many processors have not made the necessary changes in their operations.
After considering this situation, tae Interagency Committee on Personnel Dosimetry Performance made the following recommendations:
(1) The actual causes of the poor performance should be determined with a greater degree of certainty before finalizing plans for corrective action; 9
.. ' '.. ~
[7590-01]
(2) A notice should be published in the Federal Register for the purpose of notifying all personnel dosimetry processors and the public that the Federal government is determined to take action as necessary to correct the personnel dosimetry problem.
Subsequently, the NRC staff authorized the UM to conduct a series of site visits with eight of the largest processors to try to determine the causes of poor performance.
At the conclusion of these site visits, the l
UM personnel prepared a report which indicates four major causes:
(1)
Inadequate calibration sources, (2) Variability in the thermoluminescent dosimeter chips, (3) Clerical errors, (4)
Lack of effort on the part of the processors to make the changes necessary to pass the tests.
This report, dated May 1979, is available in the Commission's Public Document Room in the file on personnel dosimetry performance testing.
Future Action The pilot study was completed by the UM on December 31, 1979.
Future action will be based in part on the finai report.
However, it is possible at this time to identify the following actions that the NRC has under consideration.
Processor Certification According to this plan, the NRC would issue new regulations stating that personnel dosimetry results would be acceptable only if provided by 10
[7590-01]
a processor who is certified by a testing (i.e., certifying) laboratory approved by, or specified by, the NRC.
These processors would have to obtain and maintain their certifica-tion by passing, at a specified frequency, performance tests conducted l
by the certifying laboratory.
The certifying laboratory (s) would use performance criteria published by the American National Standards Insti-tute (ANSI) and referenced in the new regulations.
These regulations:
(1) would adopt, possibly in modified form, the final ANSI standard evolving from draft ANSI standard N13.11; (2) would specify how fre-quently processors would have to demonstrate, through testing, their l
ability to comply with this standard; (3) would establish the procedure to be used by the NRC to let its licensees know which processors have been certified as well as those who have lost their certification; (4) would (except for one possibility noted below) name the testing and certification laboratory (s) required to be used; (5) would stipulate that
'the laboratory (s) would be monitored for technical competence by the National Bureau of Standards; and (6) would specify the procedure to be used for reinstating processors who have lost their certifications and have appealed.
Subsequently, other affected Federal and State agencies would be likely to consider adopting similar regulations.
Although it is esti-mated that only about 15% of U.S. personnel occupationally exposed to measurable ionizing radiation (e.g., above 30 mrems per month) are engaged in NRC-licensed activities, it should be recognized that any NRC regulations in this area would affect a much larger percentage.
This is true because most commercial processors serve customers other than NRC 11
[7590-01]
licensees, and any improvements in their operations would be likely to benefit all of their customers rather than just the NRC licensees.
Several alternatives are possible as to the operation of the testing and certification laboratory (s):
(1) Unspecified Laboratory (s).
This alternative would require an amendment to the NRC regulations as described above but without naming the testing laboratory (s).
The processors and users would thereby be left to their own initiatives to establish one or more labor,atories, which would have to be monitored by the NBS.
The NRC would have no control over the laboratory (s),
except through regulations applying to its licensees.
- However, if it is stipulated that the licensee must obtain personnel dosimetry results under conditions as described above (except for naming the t,esting and certification laboratory (s)), NRC licensees could only use a processor who comr.iies with these conditions, including monitoring by the NBS.
(2) NRC-Operated Laboratory.
This alternative would also require an amendment to the NRC regulations as described above, but the testing laboratory would be a Government facility managed and operated by NRC employees.
By charging an appropriate testing fee, costs for establishing, maintaining, and operating the laboratory could be recovered.
(3) NRC-Contracted Laboratory.
Similar regulation amendments would be needed for this alternative, but the laboratory would be operated by an NRC contractor, using the contractor's facili-ties.
Funding would be provided by testing fees.
12
[7590-01]
(4) Federal Government (non-NRC) Operated Lab atory.
Similar regulation amendment. would be needed for this alternative, but this testing laboratory would be operated by an agency of the Federal Government other than the NRC, preferably by one of the agencies experienced in laboratory testing work.
Exist-ing expertise could be utilized, or qualified personnel could be employed.
The facilities'would be Government-owned; funding would be provided by testing fees.
Invitation to Comment Information pertaining to the personnel dosimetry problem discussed in this notice is invited, including comments on the alternative solutions described, suggestions of other alternatives, and estimates of costs anticipated in the process modifications necessary to permit successful passing of the ANSI standard criteria.
Comments should be received by
, 1980.
Dated at Washington, D.C., this day of 1980.
For The Nuclear Regulatory Commission.
William J. Dircks Acting Executive Director for Operations 9
13
. ~,.
~ - - -
e 8005130l13 6 '
MORRIS K. UDAL., ARIZ CHAIRMAN NINCTY-SIXTH " CONGRESS CHARLES CONKLIN ROBERT A. REVELES Poe*LLee sumfesa. CauP.
Do86 M. CLAWSEN, CAuP.
mooset w. uA&Ts.sentase, was.
esA=vtL LusAss. JR., M. asEM.
ASSOCIATE STAFF DIRECTOR 7".AY.'."s ".**.'".'.'."'.";.
- ',"" I,. * *"A ;'"a* "^"*-
COMMITTEE CN INTERIOR AND INSULAR AFFAIRS LEE uc ELvAiN Jo = r eruau o.s.o eTrven o. evuus. soAmo U.S. HOUSE OF REPRESENTATIVES GENER AL COUNSEL uA=obo nw==sts. =, was.
JAuss P. (Jim) Jon= eon. Coup.
STANLEY SCOVfLLE A=vo=io so=JA won CAT. auAM nascat c. i.Aeo=Ansino, cAur.
WASHINGTON, D.C.
20515 see acumAnot. Tax.
oAn man. ott. v?Aa SPECI AL COUNSEL 2;.'~';"';."";....
"*"0",.?? "*"'
ro"a='a =
- " "."".; "O' ou,.
"O'".". "1!"A4 Tour.
March 11, 1980
- ^",Yf,;",Ty,"C I,s
,C A.
JAMis J. F,maso. N.J.
posERT.W.MrTTAhim KApe$..
p^".'j
.A..o AT.
.A.
ooo m....
P tup St. SMARP. 44D.
MCLYtN M. EVA=S. \\ J.
.}
Spe&Ro J. M A#m tv, MASg.
PETRA M. FoSTMAvsm. PA.
py;_
SALTASAR ComeAoA. P.R.
AUTTtN J. MWAPMf. PA.
ee.Cet JoF AAetALL 08. W. WA.
DeuCF V. WE=To. hef.s94.
JENF.f teUCEAWV, LA.
LAMAN GUDGER. es.C.
JAtst S J. How Amo. N.J.
JEERY M. PATTEntope. CAuF.
RAT WoGOWSEK. CoLo.
PAT WILUAMS. booNT.
The Honorable John F. Ahearne Chairman, Nuclear Regulatory Commission Washington, D.C.
20555
Dear Chairman Ahearne:
The most recent report of the National Academy of f,7 Sciences' Committee on Biological Effects of Ionizing Radiation ("BEIR III") has reaffirmed past estimates of the most prominent man-made radiological hazards.
According to the report, "The greatest man-made contributor to population exposure (to radiation) is the medical application of x-rays."
The largest average whole-body dose rates for a group, however, continue to accrue to "the 30,000 people who are occupationally exposed in the civilian nuclear power industry."
Other medical treatment and diagnosis-related exposures to the general population and to workers present a very significant part of the problem.
I am writing to inquire regarding the status of the Commission's programs for health and safety in these areas.
E Please provide me with answers to the following questions:
1.
What has the Commission done since our authorization hearings last year to improve control of worker exposure to radiation, and to improve record-keeping systems for workers?
2.
Do you agree with the BEIR Committee's assessment of the principle problem areas in e
radiation health effects?
How do NRC priorities C
for standards development,' fuel cycle safety, L
and inspection and enforcement programs correspond y
to these BEIR report conclusions?
1
'1 e
l
~ - - -
h
? : ~.
4 u
5:;_
E The Honorable John F. Ahearne E?
Page 2 j.]
I
.....;M li? [
3.
What steps are being undertaken to provide for 5
record-keeping of radiological exposures received i;; =$
through medical diagnosis or treatment and related L:
occupational exposure?
What, if any, obstacles
- ~ 7 exist to implementation of such programs?
4.
Are current standards for occupational exposure for uranium miners under review?
What role does the NRC play in enforcing miners' health and safety standards?
5.
Are training and record-keeping requirements b
for radiological exposure control applied to fi.
subcontractors at NRC-licensed facilities?
~
Sincerely, MORRIS K. UDALL Chairman t
l-i:::
h:b.
b j
[c ll
- l?:{i y
==:
[5
=
E:::
W:
^
L".l.. _.
9
,