ML20004F913
| ML20004F913 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20004F911 | List: |
| References | |
| REF-10CFR9.7, TASK-PINV, TASK-SE SECY-81-232, NUDOCS 8106260171 | |
| Download: ML20004F913 (96) | |
Text
.
,,-i.
J
. O pa"%
April 10,1981 SECY-81-232 POLICY ISSUE (Notation Vote)
For:
The Commissioners prom:
William J. Dircks, Executive Director for Operations
Subject:
COMMENTS ON THE EPA PROPOSE 0 FEDERAL RADIATION PROTECTION GUIDANCE FOR OCCUPATIONAL EXPOSURES Category:
This paper addresses a major policy matter.
Purcose:
1.
To obtain Commission approval of comments to EPA concerning the proposed EPA guidance.
2.
To inform the Commission regarding the views (majority and minority) of the staff concerning the proposed EPA radiation protection guidance for occupational exposure.
3.
To provide the Comission with current staff recommendations I
on the Commission's interim position regarding limits for internal radiation exposure in the workplace.
Background:
1.
By memorandum, S. J. Chilk to L. V. Gossick dated May 7,1979, the Commission requested to be informed of the staff's input to the development of the EPA's proposed radiation protection guidance so that there would be adequate opportunity for the Commission to forward its views.
2.
In SECY-79 ~', dated September 18, 1979, the Commission was informed of the development of the proposed EPA guidance on occupational radiation protection and of the position taken l
by participating staff members regarding dose limits for internal organs.
Commission views were requested.
3.
By memo from S. J. Chilk to L. V. Gossick dated October 30, 1979, the EDO was advised that the Commissioners concurred with the staff's recommendation, as an interim position, "to retain current NRC limits for internal radiation exposure in the work place."
Contact:
J. Guibert 443-5855 8106 260 l@
a.
==
=
- =
i The Commissioners 2
. Discussion:
The proposed EPA guidance was published on. January 23, 1981 (46 FR 7836) for public comment (Enclosure I).-
It reflects endorsement of the Commission's interim position noted above.
A copy of the Backgruund Document published by EPA in support of its proposed recommendations is provided as Enclosure VI.
Technical staff members from all major NRC~ offices have completed their reviews of the EPA proposal.
Because the EPA guidance has a direct and substantial impact on NRC regulations, the ad-hoc technical staff group working on the comprehensive revision of 10 CFR Part 20 has also completed a review of the EPA proposal.
Enclosure II-is the proposed Commission response to EPA as requested 4
by EPA in 46 FR 7836.
EPA requested comments by April 24, 1981.
The comments to EPA (Enclosure II) ider,tify areas of substantial l
disagreement between the proposed EPA guidance and the current staff views.
The rationale and technical reasons for the dis-t, agreements are included in the comments.
A more complete dis-cussion is provided in Enclosure III which also addresses the i
current staff view regarding the Comission's interim position on limits for internal radiation exposure in the workplace.
Among l
the features considered by the staff to require change are those tentatively endorsed by the Commission in its interim position concernirg internal radiation exposures in the workplace (Item 3 l
of" Background".)
In addition to comments provided to EPA staff by NRC staff who participated in the development of the EPA pro-l posed guidance, the staff has recently advised EPA staff informally of its current views on the principal areas cf disagreement on the proposed guidance, but has indicated that the Commission has not yet reviewed the staff's proposed positions and comments.
l-The EPA proposed guidance includes many of the concepts embodied in the ICRP recommendations published in 1977.
However, the proposed guidance includes a number of departures from the ICRP system of dose limitation which, in the NRC staff's view, would significantly impair its usefulness.
Since publication of the ICRP recommenda-tions, additional information regarding the bases for these recom-l mandations has become available.
Open discussions of those bases have led to a more complete understanding of tne ICRP system which, l
in turn, has resulted in a more complete endorsement of the ICRP system by the international radiation protection community and the l
NRC staff.
As disciased in Enclosure III, the NRC staff believes that the ICRP system is based upon the best scientific information I
and methodology currently available and that the ICRP's general approach is consistent with the Commission's policies regarding (1) the appropriate application of risk-based methodology in regula-tory decision making and standards setting and (2) the necessity of vigorously applying the ALARA concept in radiation protection activies.
I The introduction of quantitative risk estimates into the system of dose limitation and the abander. ment of the critical organ concept "v9
=+ww,-www v--wy-waisw+ow---wwiewe-gowe--we--e,9
-e.mg,-wy
,-gyyg
---,rgvpggw g -+ v wy,..pq,.v.=-pug-.
gmy-w qr-w,,,-qy--g-,ww, g
,iv-T-
--e 9
=-4--,
y-
~
s--
=-
w-4
o, The Commissioners' 3
in favor of the whole body dose equivalent concept are major steps toward a risk based system _of radiation protection.
Such a system will allow quantitative evaluation of risks incurred by workers under different conditions of exposure and will facilitate compari-sons of risks encountered in various industries Movement toward such a system is a necessary step in the implementation of tne Commission's policy regarding the appropriate applications of risk assessment methodology.
l NRC staff recommern adoption of the ICRP system of dose limita-tion as the priccipal Sasis for the revised 10 CFR Part 20.
How-ever, complying with the guidance proposed by EPA
- would require NRC implementation of a system which differs substantially from the ICRP system.
In light of the.1RC staff's current understandino of the ICRP system of dose limitation and the consideration of the pros and cons of alternatives and modifications to the system, including those proposed by EPA, staff proposes that the Commission recon-sider the interim position adopted in October 1979 and endorse the position reflected in Enclosure II.
l Staff endorsement of the "syrcem of dose limitation" recomended by_the ICRP recognizes that che system:
(1) is based on a contemportry radiation protection philosophy that would require (a) justifying why persons are to be exposed to radiation (b) ensuring that any exposures are as low as reasonably achievable, and (c) using appropriate dose limits,**
(2) is based on an " acceptable risk" rationale that is derived from the statistics of job-related risks to workers in the
" safer" industries, excluding nuclear, (3) provides a method (a) to combine doses to multiple organs, doses from multiple radionuclides, and doses from internal and external exposures and (b) to express these doses in terms of a whole-body effective dose equivalent on the basis of risk considerations, which may be compared to the dose l
- limits, (4) incorporates the state-of-the-art knowledge of biological, physical, and dosimetric information in deriving " annual limits of intake" (ALIs) and " derived air concentrations" (DACs),and, i
"As a matter of policy and past practice the NRC, like its predecessor agency, the AEC, has considered the guidance issued by the President as binding upon it although such guidance is not, in the opinion of OELD, binding on NRC as a matter of law.
- See Attachment A to Enclosure III.
_,_p, y,
,g,,_
%g,p,,,,.,
_,,,,,,.y,,
,,,g, 9
,g.p,
,__.,,.9, a-w
.gy,,,..
u.
The Commissioners 4
(5) provides appropriate dose limits for normal working condi-tions which are generally more restrictive than previous limits, but provides flexibility for exceptional operational difficulties when it is in the public interest to exceed the primary limits.
~ Many of the quantities (such as ALIs and DACs).needed to implement a radiation protection program have been provided by the ICRP-and the remainder are being calculated at the present. time.
The new calculational models are so complex that sophisticated com-puters are required for the calculations.
Owing to the complexities of the calculations and the interdepend-ence of the features of the ICRP system of dose limitation, it is not possible to arbitrarily change some' selected parts of the system without destroying the continuity and coherence of the whole which would be the effect of the proposed EPA guidance.
If the proposed EPA guidance is promulgated in its present form, all of the calculations and tables provided by the ICRP must be replaced, and implementation by U.S. agencies would be mada extremely difficult.
In addition, communication with scientists of other countries, could be extremely difficult because the U.S.
would have different definitions for the same concepts.
The ICRP system has been adopted, or is in the process of being adopted, by the IAEA, the Commission of European Communities, the OECD Nuclear Energy Agency, and most countries with radiation programs.
The selection of a specific system of dose limitation has a direct l
impact on international agreements, cooperative efforts, and guide-lines related to radiation doses to workers and members of the l
public.
The proposed comments to EPA represent the consensus of the major-l ity of the NRC staff.
Minority views do exist, however.
The l
minority views and their supporting arguments are ~esented in i
Enclosures IV and V.
The minority view expressed in Enclosure IV is that the EPA's proposal for a lifetime dose limit is too stringent and the staff's.sajority view based on worker informed consent is too l
lax.
The view is expressed tnat an informed consent procedure l
should be used including mandatory notifications to workers when l
their lifetime theoretical risk reaches a pre-set value.
It is l-further proposed that the interim position (Item 3 of " Background")
be retained.
The minority view expressed in Enclosure V is that i
the NRC should oppose implementation of eithea the EPA prepsed guidance or the ICRP recommendations without a full evaluation of the potential costs and the potential benefits.
Attachment A to Enclosure III is a brief summary of some of the principal features of the ICRP system of dose limitation.
This l-
The Commissioners 5
attachment explains some of the complex issues that are discussed in Enclosure III.
Attachment B to Enclosure III is an article from Nuclear Safety that discusses the recommendations of the ICRP as presented in ICRP Publication 26, including the system of dose limitation.
Recommendation:
That the Commission:
(1) Aporove and transmit the written comments on the proposed EPA guidance set out in Enclosure II; (2) Support the implementation of the system of dose limitation recommended in ICRP Publication 26, and (3) Note that the 10 CFR Part 20 Revision Drafting Group will use the proposed EPA guidance, as modified oy the Commission's comments, as a principal input in_ drafting a proposed rule change to 10 CFR Part 20.
YL William J. Dircks Executive Director for Operations
Enclosures:
Federal Register Notice on "I"
EPA Proposed Radiation Protection Guidance ~for Occupational Exposures (46 FR 7836)
"II" - Oraft letter to EPA for--
warding NRC Comments "III"-
Supplementary Information in Support of Proposed NRC Comments to EPA "IV" - First Minority Opinion Second Minority Opinion "V"
- "VI" - Background Report--Proposed Federal Radiation Protection Guidance for Occupational Exposure" (EPA 520/4-81-003)
- (on file in Office of SECY - copies previously provided to the Commissioners)
O s,
..n~
-ew yg ew q grvy v--y-m-gww.ieygmv-v--,g-+ir--
9-y=w-yyw y.
ww-ya ygr wyy-y--Www---y.-m->%-graw---
v% wr,.
.i.a,,
6 Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Monday, Ar~il 27, 1981.
Commission Staff Office comments, if any, should be submitted to the Commissioners
.NLT April 13, 1981, with an information copy to the Officc of.the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of
- when comments may be expected.
4 DISTRIBUTION:
t e
d._
r_
(,-
2
)
9 o
e O
l ENCLOSURE I i
f
?
w-Friday l
~
January 23, 1931 s-
=
w,,,een _a g
gR
~
hw y g --_.
a
.w.--.
5h w ang q gy-
~~
E.a_
t mm 1
a wy=
i m sm,y
- =_
=
.a
-_,_~
se seer Part XV
.a i
(
n 1
EnyjronmGntal 4
Y TO GCu.ie,I a 1
A m
a a
v.
ci
===es Y
Federal Radiation Prctection Guidance 8
for Occupational Exposures wm g g
r1
.=
6 c=-+=
y M
6 E.
EE
, s g_==,=:,.
.:n,.,
M sr--J i
-J
=
.me &= -
t 5 88 h-
- q l
y
=w='
y
. 5 5
^
. f e
en 1ne... T
. ~
.. - ~
7338 Federal Register / Vol. 46. No.15 / Fr! day, but:arv :3.1991 / Notfess (nH-PnL 1722-41
. than so days following publication of sumausstrany inconseaffoNt this notice: Washington. D.C Cteago.
SW Authority Federal Radiation Protect!on Guidance minois. San Francisco. California.
for Cccupational Exocsures: Proposed Houston. Texas. We will publish the ne Administrator of de Recomrnendations, Request for ti=es and addresses for tese heartngs Enytronmental Protection Agency (EPA)
Wntten Comments, and Putsinc shortly.
is charged under Executive Crder 1c831.
Hearings 3.Instruedons ofInterest to those who Recrganization F'.an No. 3 of 1970. and wish to appear at the public heartngs Puolic Law 86 373 to ** *
- advise the
- Aeamcv:1J.5. F.nvimnmenta1 Protection are given below under the heeding President with respect to radiation Agency.
"Public Hearings."
matters directly orindinctly affecting AcTioec Proposed recommendadons for acorr30aA8.*FC#58ANC We will h palth. Including guidance for all radla' ion protection of workers.
happy to send a copy of a backgr:und rederal agencies in the formulation o racianon standards and in de report which provides additional suanasany: We are ;roposts to make informados on these proposed establishment and executica of recotr.mendations to se Pasidant for recommendaticas to anyone requesting programs of cocperation with States.,
new guidance to Feceral agencies for it. P! ease send aquests to Mr. L;is F.
.nis gudance has histencany taken de the protecton of workers exposed to Garca at is address below. nis report !ct-n of qualitative and quantitative
" Radiation Protection Caidance." The Ioni=ing radiation. These proposals a2e is also available !ctinspection and based on a review of ex: sting guidance copying at EPA's Central Docket Secten neemmedadons we propose swa
~ !n de !!sht of scientific knowledge of and ten Regional CCces (addnsses would replace $ose ;cru,ons of uisung radiaden risks and of experience in de below).
Federal guidance dat apply to radiauon control of occupational exposure. Le aconessss: Written comments should protectos d wodan. p:en. wue adepted in IS60 (*3 FR ec 1 proposed reco=mendations include both be addressed to de Cirector. Catana qualitative guidance on radiation and Standards Civision (ANR-460). U.S.
Previous Acdons by EPA protection and sumerical 3mdes for FavtronmentalProtecten Agency.
We Wgan thb rettew d S 1980 max: mum allowed dose eqtuvaients Washingtoo. D.C. :04ec. Attention:
3d I
f,*,". g7['
e [csfr$e#f notice (RPC's').no = cst ugr.iilcast changes Cocket No. A-Nd.nese co==ents he n
proposm! 2n (al ist a graded set of and 6 pubuc hear ng record wtil be of dis activity listed te ;nscipalissues minimur's radiadon protec fon Sled t rsier the above docxat numcer being addnssed and announced our requtaments be inccduced in dree and will be available for inspecton and intent to hoid public hearings on levels:(b) dat de RPG for eunt copy.=g at de U.S. Environ = ental proposed accumudadons W FR whole-body :bse equivalent be reduced Protecuca Agen:/s Castral Dcciat 5s?85. Sept.17. *53).
l from dree res ;er quar er to Sve tem Sectics. Room 3c33. Mall 401 M Street.
We have soonsored two =aior studies 8
per year. and dat regulatory agences S.W., Washington. D.C. 20460. and at Se 6 suppcrt of'tais program. Erst. Se establish lower lisuts !ct specile t/;es Agency's !!brary !n each ofits ten Coc=uttee on the Sicictical F.ffects of of work situations:(el that umitacon of regional c5ces Regica h [7K 3W.ing.
I:+. g Radlauens. National Academy 5 aka in:o acccunt de Rocm 200-B; Scsten. Massachuatts of Sciences-National Rosearea CouncL laternal dous t
sum of de risks to all cessas, rsther c::=3 pel $17-:=-5751) Regica if :S has reviewed the scentile da:a on the than continue to be based cruy on de Federal Ptaxa. Room 1002. New Ycek.
heald nsks oflow leveiionizing most signiEcantly enosed organ:(di New York 10: 3 (Tal 20-m-231%
raciadon developed since as 137:
that the RPCa :or the whob body apply 3,gion Sh Curtis Builciing. och & Wainut report. Second, we have carried out a CD the appropnateay weigsted sum of tse Streets. Philadelphia. Pennsylvania study of occupadenal radiation doces from both Intemal and extemal 1910e gel 5-397-cEa0% Region IV: *AS exposures and published our !L.ndings in exposures: and (e) that 2,e dose to to Courtland Street.N.E., Atlanta Georgia a nport mutled:"Cccupaconal embryo and de fetus be a=uted drou82 30385 (Tel 404-o81-4261: Repon V: :.3 Exposure to Ionizing Radiation in the
- one of several alternauve South Dearborn Street. Room 1417.
Un2ted States: A Comprehensive recoma sudations.
Chicago, minois $0004 Ret 312-053-Senary for the Year 1975.* We have We welcame written comments on g=g g,pon VD First Intemational also considered recsnt l
these proposals and will hold public Buildias.1:ut Elm Stnet. :52 Floor.
recomt.sandations of de National l
heenngs as discussed below. We wtII Dallas. Texas 75-O Gel 24-75 -7 Ath CouncI on Radiation P octacuca and can!uily censider all oral and wntien g,pon Vlh 24 East 11th Strat. D"
Measurements.
comments in pnpanns our Saal Cty. Missouri 5410e (TeL sis-374-3497):
In developing these ;roposals. we recommendaeces to e President.
3,gion V2h Radiacen Program CSce have also consulted wits $e tech:ucal carts: t. 8d1 written comments in (in Ueu of library).1880 L ncoln Street.
sta:Ts of the Federal agences that response to tis notice must be received Second Floor. Denver. Colorado ac:03 regulate er influence tne resulaton of l
by us by Apnl *4.1981. in order to be peL ac3-837-:*th Regica IX: 05 occupational expcsure. and will used.
Fremont Strat. Sth Roor. San Francisco, continue Wis consultanen in developing
- 2. P2bl!c hearings will be held at the California 94105 Cel 415-556-1941:
Snal m adaticas. Dese agencies following locations beg:nning ::o eartier 3,gion X;1:00 Sixd Avenue.12ta Fiocr. an the Occupational Safety and Healts Seettle. Washingten 98101 Get 006-.42-Administration. de Nuclear Regulatcry
- "**P C ui tagg).
Commission. de Mine Seiety and I
, j j g"H*cces(C d*** M' #*
F04 FURTNEM WFoMAffCN CoMTAc?:
Health Administration. Se Capar =ent Contact Mr. L us c. Carca. U.S.
cf Cafense. $e Cecart=ent of Ener;y.
ama.naat.
ms.2..n.
ny
.a rs.e & c.
maca = =.
Enytronmental Protection Acency tne Copar* ment of Yransportation. tae n
- 2. mune.r at nos. n sm..sim n one.
(A33 ;ect Wasninaten. D.C. 2460 Food and Drug Administrot:en. Se uw for =
- *j 'jQy*$*'O ",*,'*,
pelephone 703-337-a=4L about tese National Aeronautics and Space y
- t, se none.
a.ncoraria m Ja Ma m a prCCC8*d recommencations or de Admtnistratton. the Nat:enal Institute s.. i.*
pablic hearings.
for Cecupation41 Safety and Health, ana
_ Enclosure I
l
~
f Federal Register / Vol. 48. No.'15 / Fridt.y. Ianuary :3. S981 / Notices
- 337 l
the National Buneu of Standards. nese dose equivalent (measund in mal? It radiation dose. Details of these and agencies which have not formally so, should this be developed now or other nok estimates we use are provided endorsed these recommendations. will lasued later as supplementary guidancef in the accompanying background formally review !bal preposals when
- 9. What guidance should appiy to report.'
they are developed fadovdag puhile workers who do not use radiatou A worker who received the larpst sources, but who are exposed to lihue dose allowed under present review.
radiation due to the activities cf werkers gates (3 rem per year hm sp is to Isenes Addassed undar the control of other employersT assumed retirement at age 65, or 233 De principalissues we addressed!n
- 10. Are dare situations that =ay rem) would have a Iffetime risk of about formulating these reccmmandations reqmre doses higher than nor=aHy 3 to 6 in 100 of dyt=g ' rem rad!ation-were identined in de advance notice permitted? Should we provide special
!=duced cancer, anc numericaHy cited above.ney were:
guidance for de=1 comparable chances both ei:enfatal
- 1. Are the doses curantly receivedby Many of deseissues are addressed cancar and for male workers. of workers and the mi um doses below. However. for a = ore ecmplete mutational effects in his descendants.'
l pernutted under existing guida:ce and extensive discussion please refer to Risks of mutational effecu hem I
adequately !aw? In dia regard. a) how the background n;crt etad scove under ex;osure of female workers are adequate is de basis used for esti=ati=s the heading "Addhnal hfer=atics.'
assumed to be dras to fcur times smaHer. However. in our Mcent saticnal risks to health from raciation ex;osure.
Risks From Cccupational W survey of ex;csures fer the year 1375.
and b) what are the appropriate bases here are dres kinds of risks Sm the 99% of all workers received.ess dan for fudging maximum individual and collective radiation deses in de work low levels of !c+"3 rsd!atica half c4 and only 0.13% exceeded. as force and the tradeoffs between dose charr.cteristic of occupatienal an=ual dose of 5 rom. Hased on dese exposures,ne =ost im;crtast of dese and oder data, we believe dat c=!y a two bdices of de health impact of is cancer, which is fatal at least half de few workers it.volved in ac= dents have occupational exposuret
- 2. Should de same guides apply to an t!me. Another risk is the indueden of ncalved close to de current =ax:=um catercries of workers (e.g dental hereditarf efecu m desce: cants of allowed ufetime dese.
worxers. nuclear =e%s technicians.
ex;osed;ersens.no seventy of these ne average worker exposed to suc!est =aistenaces ;ersensel.
etfeca reages Sm fatal to indiation sustaiss aniy a s=ad risk cf Industrial radkysphen}? Sheuld incensequential. We assume that at low death from radiatica.De estimated specille guides be developed fer levels of exposure de ask of case r and average ask ci death due to radia2n.
prepant women. female workers who henditary effects is in pretwnics to de
!nduced cancer is sma!Ier, fer exas;Ie.
could bear children. and/cr =ent dose received. aM La me severity of than de risk cf 'ob.related accidental
- 3. Co what t!=e basis shed.i de any induced effect is != dependent of de death in de safest of all =ajor guldet v expressed? Quareriy?
dose 'evel, nat is while de probabint7 cecupational categories, retall trades.
Annual? Should de lifeti=e of a given type of cancer ecc= =g fer which is annual dead rate was $0 occupational dose he Ii=ited? Should
!= ceases wid desa, suca a ca:cer
- er =dHon werkers in 1973. We esti= ate the age of de werker be a facter?
!=duced at one dose is equally as dat the coi!ective dose to de =cre man
- 4. Shculd is guidance reflect er cover decintsting as *at sa=e type of es=cer c a =duen werkers poteadaily sx;csed medi.al, accidental. and/cr accrgency bduced at anoder dese.Dus, for dese to raciatics is deir werk;isce he sat effects we assume mat dere is so same year wtH not lead to =en das 15-expciures?
- 5. :s existing gu:, dance for situatas ccmpletely nsk Ine level of radatica 38 premature cancer deat s. Cther ways that In roive.ex;csure of.ess than the execsure.
of expresamg das r'.si are taat.se l
i whole body adequate? !s dis respect, a)
The third type ef risk.mcluc.es a ex;csure cf an average worker to wee' organs and parts of de bccy vane;y of other effecu on werkers and radiation in 1975 r=;nsented as average i
i sisculd have desipated ilmits, and b) cm on de ehddnn ci wcmen exposed lifedertenmg of abcut two to drev and what bas:s should guidanca he dun =3 prepancy. nase effects ranse
, 3,;g,3,,,3,y g,3, 3 expressed for exposua of =cre dan one kom sencus efects en caddren. sucs as his chance of cancar death of about ene
=entai retardation. to less senous to thres in 100.000. Is 1975 about one orgas er por*1cs of the bcdy?
S. How should de radiation protection efects on workers. such as opacuication sixth of L*nited States deaths were hem principles regtiring al jusuf!catica cf of the f ans of de eye and temporary g,gg,3 any exposure, a=d b) nductics cf de impair =ent of farttuty. Fer dese edacts na ecmparative ti=e-less assecated dose Sm !ustiled ex;csures to de we believe de degee of damage (La wtth sentatal cancer !s also esc =sted to i
' lowest practicaole or as low as is the seventy) de; eses to some extent en g, y,,7,,,1g, n,,y,,,,, g;=,,,,,g 3y reescr. ably sentevde :evel be a;;Iled de dese leves. At de dose leve:s t
to exposure of werken? Shcuid the allowed by current radianen ;retec:ica g g gg,
. i cancept of!cwest faastble level be guides. we behave dat scne at de
. doe 4 a.
as4,,s.u, u., m, edcets on werkers de=selves occurs to modets und sy en :src su caeunaun and 2e applied to ex;csure of workers?
sammenea 24: ce us d se rns sesi 7.What. if any relationship should be a depte sui!!cient to be cH=ically maintained between permissible levels detecuble. At dese Ievels, however.
"g'7j"',",",**",,***3,"J"',"",'
l of risk to beeld.* rem radiatica ex;Csure effec'.s on children exposed m utt:0 =ay wu manusa, pves esumates sued os a and oder resulated hazards of disease be sencus.
vency at== macata.
- m. w =a:ca vie:4 tower De risks af edeCis on heeld IrCm Iow aae scene hgr.er vatwo. 3ased on our preuaunary Additional!ssues suggested si:ce
{evelic*- g radia ca were revtewed g "g " Q []*j',j",p(*u*lg Cr accidents?
.cr EPA by ta Natienal Acacer=y ef 3
,oge,,,,,,,,, 3, puel! cation af de adva:ce notica Scar. css (NASl in re;crts ;uclianed in
'Wr.aueana eifecs sere==eaa..cse aerocatary includet
- a. Should de guidancs ::chde is?: and in 1280. We have used dese efeas.=c:=cea sy a su caamun.a mar x:
"S*" " """* '8 8 5'""* **S 8'" '"
tumerical values for de fac*ers (called studies and othen to estimate de esks E"', ****[***,",", *["CQ,
/
' quality' and *=odifyms
- factors) used usocated with de current and 1
a convert dose (=easured in radst to preposed yederal guides kr li= sting abama caoet
.caan,nneta. me.,ue,sy.
l Fnclosure I
s o
Tederal Register / Vol 46. No.15 / Friday. ianuary :3.1961/ Notices 7838 II.S. workers due to all occupational!y-supervision, and monitoring for that "The maximum permissible related injuries and illanses over a reciation protection. Marty also woric in prost getive dcse equivalent for whcle working Ilfotin.e is one month. For situatio'ts whtre then is no need for body irradiation from sil occupetional rad;ation. induced non!atal cancers it !s exposuits to ever approach the exis:ing sources shall be 3 rerns !n any one year
- estimated to be about four days for a or the proposed new RPGs. On de other (NCRP Report Fo. :9. Tan.15.1771).
hype'hetical individual receidng de hand. some exposures at higher dous
!.;kewisa 'he laternauunal Commisuon lar13est Ilfetime dose allowed (235 teml. are justifled.ne prepceed on Radiolog: cal Fratect on in 1977 i
and for me average worker it !s abaut ncoaucer daticas. therefore. provide a recommanded a basic dose-eqaivalent annunillmit of 3 rem fer whole body two hours.
graded system of radtarter p.otecton muns 'o kat:ing radiaden GCRP which woiJd estabush mimum I,lmitation of Whole Body (External) radiation pratection aquinments Ive holication :S. Ms. ty.177T). In support
- P**""
each of $ree dilhnnt ranges of of its recemmencation me ICRP stues that "The Commtssion believes that for Based on these observations, risks exposure within the bas!c guides for to forsseeable.'uture a valid method for due to occupational ex;osure to maxunum aucwed dose to all workers, judg=g te acceptshdity of 'he level of radiation do not appest to be We enticpete cat maximu=1 esposure esk in radiativa werk :s by c.cmpanng unreesceably high for te 2 terage of de vast maiorit/ of werxers would be this risk with dst for oder occupatiens worker.ney are comparab;e to nsis of ei! actively !!mitsd to de lowest of mese recogmced as havmg high smedards of accidental deatn in de least hazardous ranges (!esa han approxi=etely c.3 rem refety.' ' *. De radiance t sk factors occupations. However. a worker to tne Whole bodt ;er year) through the given in !CRP Pubilcadon :s ;n artmng exposed to the current max: mum deterrent of requirements krinenssed at tts necm=encacen won reviewed allowed dose year a!*er year would jusnacation. en the-!ob radiation by !CRP b.\\tay :373 and no enanges sustain substantial risxa. De ; reposed protecuen superviston. and monitor =g wers made I'.CRP Publication :3. Im).
radiation protection pidance contains in de two higher ranges. In addttion, tne Nevertheless. these neom=endaticas isions to avoid the accumdation of recommendations encourage regdatory are all value Judg=ents: $ cts is not now e lifecne doses droupt reducson of agencias to establish mere natnctive compd;ng evidence for sny ;articdar the maximum 4Howed annual dose and regulatory II=uts for werk situaticas not value and tt is hard to get such evidence.
throcah specinc =inimum esciatica aquin=3 the maximum dous aHowed In judsteg 8e acceptabdity of me nsks rctectics aquin=ents for workses in under te basic pides.
involved. it is :ecessary to idanu!y (a)
[tish dose werk situanons. nese ne prepond addance haves activities dat cannot be perfarmed at laciude en de-tob radiation protectics agencies considuable dbenuon in partiedar maximum dose !aveis (b) maintenance of Lgh.dese !cbs.
supervision fet hi g, % ;,, g,,,
.skaned peciessionals and worxars in ei!=e dose records.
rotecton mquina. nts kr iM.Scaden
.itnited supply whose numbers wou;d be and an admonitha &at exposure of
'g I the werkers should be managed so that their
- ",", [,g }['" in es difHcult to quickly incnase in order to annual dcas. and (c) nduce antage,ditional werken and lifetime ecses do not exceed 100 rem.
addidenal guidance which would te costs for ac Existing i ederal guidance per=uts neemmend de estabHah=ca,t of =cre
,g g
g doses up rJ 3 re s per quarter (or 1: rem expucit nquincents kr me mgnest tfferentI!=uts. For ex. ample we are
' per year), within an overall cumulauve range @ange C).nese requirements g,
. g g
limit of ?(N-tal rem, where N is de age couldin=ude establishment cf enteria of the worker.nts !!exzbdity, wettch for use of Ranga C. ce ;not ap;I!catics atacons sat could not be done under allows annual doses greater dan 3 rem.
to ami apprcvai by da regdatory.
some limits less than 3 rem / year. Dere
. does not ;e=ut specfic tasks tat agency of Range C exposure (eteer ter 9 3gy 3,,,
- ,,g
, require doses to IndMduals of more specHe or men gyneralich situations).
pfesskes. Ady Wid than 3 : m (since to 3 rem ;er quarter We aquest specac comme,nts on dese s e Md WW mk Wu limit prohibits dis), but it does permit and similar approaches to turther iMude cardbbm perhm the same werker to accomplish several natnctons,on de exposure of workers cadetenzations using Sucroscopyt and tasks requiring doses at or neer this at tese higne levels.
raatelogists, neuro-radiclegtsts, and quarterly !!mit in a gtven year. In view Ne have censidend both higher and nuclear medicine technologtsts with of the risks. It is eur judgement tat
,cwer alternatives to de precosed 3
!arge patientloads for spec:al npeated ex;osures ta a year at such preceduns. F'nally st acies by te rem / year RPG for whcle-cocy expueure.
levels should not occur. and taese his value is proposed because (al it ts Depcrtment of Ener;y and de nuclear recommendacens would eiiminate dis de cunent internationa'Iy-acce;ted powar mdustry report mat !a.ge costs Sex 2ility. C e appregnate soluden in value. ib) there appear to ce essantial and many scre werkars would be cases where werxt:s wita scecde skdla
- obs requiring near 3 rem per year. and
=eeded to gnatly reduce te dese Linuts are in short supp'y is to ::ain addit:onal workers. rather ;3%n to impeu higher (c) Se nsxs to the few worxer in Gese ice =eny creraticas. neir projections risks on a few Individuals.
jobs are not hign compared to oder of costs and persennelrequirements mdustrial hazards. In addition. te costs. Inenese expotentially with decnasing Because we assume dat any exposure carries some risk. we believe tuat it is for levels sigmficantly lower (one rem /
II:mts. We thenfon request. !n addition important to avoid unnecessary year er less) appear to be unwarranted.
to comment on reduction of the current exposures at any exacsure level both in terms of incnased collective RPC of 3 rem / quarter to our proposed Although =on than M cf all workers dose to the entire workkrce (!n return recommendation ef s rem / year, in car survey received annual deses '.ets fer a few !cwer individual doses) and in comment on te acovo facters for
$an one rem. dese same worxers ter=s ofincnased economic costs-reduction of de current RPC to 0.5 rem /
occumulated about half of de coilective In 1975 the National Counca en year.1 tem / year, and 3 nm/ year.
dou receivedby the en: ire wors force.
Radianen Protectiert and.\\teasure=ents I. Imitation of Partial Body Exposuns Many of these worxers, because taett tocx Se position tat no change was doses are low e=mpared to the ilmits.
required m de recommendation given Expcsure of ;ortions of de body cr.n i
may receive acly =mu-ml traimag.
by it in 1971. nat recoctmendatica is occur through !ccall:ed irradiatinn of Enclosure I
0 Fedeal Restister / Vol. 46. No.15 / Friday. Nnuary :3.1981/ Notices 7813 extr mities (such as hands in glove Itis usually impractical to d! reedy whole body.ne proposed new guide for boxes). or by breathing er swallowing monster the dose received by a worker goneoal dose is therefere identical to radioac'ive =atenals which then who broades or swallows radioactve ttsat proposed for de whole body. This migrate to diferect organs of the body.
=atadals. but it is useful to be able to guide is ssecfled secarately and not Current guidance linuts such
- realet doses that may be received from inciudad in the scheme ; reposed above exposures drough separate numencal breathing contar.ruted atmcspheres or for weighting parual-bcdy deses guides for organs and for individual swallowing contaminsted matenals. To because tse risks involved are of a parts of de body dat a e essdy make decisicas about radiation fundamentally different naturer me exposed such as hands and feat orlens protec
- ion of such workers possible. Itis afected indhtdualIs act the one of the eye. Ecme crgans recognized as necessary to calculate de amcunts of ex;osed to radiation and de eEscts essdy subjected to hith doses er as d!Earent kinds of radioactfve matenais faciude diferent types of harm.
~ particulariy sensitive to radia:ica have which. when broaded in er swaHowed.
Umitation of R!sk to the Unborn speci!!c gui. des.
gne the maximum dose allowed by de FernHaed Qcyte. F.mbryo. and Tetus These current guides are appiled RPGa. nose calculations require Protection of de unborn has separately. For example, even South a complex models of =etaboilsm and realaden is an altesdy ned-estaclished worker has recesved de =a;cmum dosimetry. We propose dat dess
- nnetple
- de purpose of de pine far al!cwed dose to his thyretd. ha =ay also !! siting a=ounts of radioactytty be receive doses to his lungs. sx:n. cr any designated the " Radioactivity brake genadal exposure is to I! nut muta:1cnal.
other organ, as icos as no single organ Fac: ors * (RITs), and dat day n;iaca effects in chddren conesived after de, exposure. However. dose conceived :ut receives more dan de dese specfed by de c.rren:!y used " Rad!cac::vity its guide. We assu=a dat de risks Cancentnuca Ceides.*
not yet bem. de "unbcrn.' are also at associated wid such =ultiple doses are Recent advances in =cdeilng nsk.Their nsis are pater, kr a pen metabousm and desa=ecy have dese, than de rtska to these not yet additive.
An altemative approach !s to !!=it the produced signtficant changes in &e conceived. Current guidance does act.
contain a dose !!mitadon to ;tetect de total ttak of fatal cancer in all ex=csed ecses calculated for radioac:ive organs.nis =eded has been adepted
=2tenels 6 de body. For many unborn &cm dese nsks.
by the Internationai Cam =istica en
- dioactae matensis the chenees in de ne nsk of seneca harm feilowing 6 Raciclogical ? otecten (ICRF). !! is also R Fs due te changes in me mecels are utero exposure requires canful attannon adopted in dese ncommendadens, but considersby !arger than the changes because cide mag:utude and diverst:y only when it ! ands to a greater degree of cue to the proposed :ew RPGs. These of de efects, because dey ec:ur so.
protec:fou dan :imi:ing de dese to saw =cde s =cre often reduce ear!y in life, and because cose who cntical organs.Speci!!cally, the accwable $ takes dan nise de=.
suder de harm an =volustanly recommended guidance provides dat (a) However. Se dose cases where de R:7 exposed.These risks are ::ct as weil either de c==bined nsk of fatal cancer for any specfic rad!cnuc!!de wcu!d be quant: fed as dose to adults.
ham all deses to individual organs act inceased. de quescon anses whether Neverdeless, ava21able evidence incicates dat at entical;enods in the exceed the risi per=1tted = der de npladecs adacted by != pie =enting develep=ent of ma =be._ icr de same agences snould retatn exisung values.
whole body guice er (b) de dose to de^
mest siga.i!kantly ex;csed :rgan not in ac: rdance wid ;r::esed dose. nsks :i#y :n many * =es neater exesi.G pdde, whichever is core Rec:=mendadens : and S. We be.! ave C2n dose :o ada;:a.
There are several factors which restrictve.E:e ree:--=-da: ens also dat. for existing a;;i!cadena.
provide. when werkers receive botn
.expenance gsined :ver de past :wo
=:tigste dis situad:n. First. ia enternal doses from who!e.bedy decades shows dat c:rnst va!ues can expcaure of =ost w:fxen = der annual exposure and intemal deees &cm be ressenably achieved. Ac::rdingly.in li=its is relatively evenly dsm::uten I
radionue!! des, dat de sum of the nsis cases whers e F.IF fer any speed:
- ver de year. so dat sniy a quarter of a of fatal cancar from external whc!e-racianuc!!de would be increued und:r werkers annual dnse is delivered to de
}
body doses and those due to breathing de pr:pssed guidance. we reca==end unbern during any==es:er. Sec:nd. de i
or swallowing radioacuve =atenals not that the value adopted in replaticas
=others body prov' des c:nsidenble shielding of de unbern i r =:st y;es :(
eueed de risk of fatal cancer aI! awed governing existi::g apeiicatzens he no exposure. Finally. de total ;ened of by the whole.bcdy guide.
h:gher dan dat now in ass. A s
-ary
- orential espc,surs is s= ail Sr de The nu=erical weighting factors of the changes due to the naw =edais chosen to re!sta nsks to $div
- dual and to the preccsed new guides is unborn compared to dat kr a werker-I
. orgens to whole.bocy nsk are discussed provided far de =cre siguficant a pened of =cc:ns c==;ared to a I
in de background re;crt ::ted above. In racionuclides in the backg:=d report, worxine lifetime.
It is ciU;cuit to provice for prote:uon l'
general they are censistent with recent Urnaadon omsk Fmen Mutations cf de unborn witnout affecteg de deter =irations of risk of fatal cancar by national and intemational scenunc ne c=ent guides !st :I=1: fag dese to r ghts of warnen to equal job
)
bodies such as the NA3 and de ICRP.
de genacs are identical to those for de opperrunities. nis 6!!!culty is We have chosen the linuting annual whole body. For a given annual dese.
c=mpounded beer.use de :nt: cal ;eded
?j dose to mos' single organs to be 20 rem.
de risk =f mutational efects in all of a for =ost harm to the =bcm oc:urs seen rather than the intemationally.adepted
= ale werkers descendants ce=bined is after c=nception-dunng the second sad value of 50 rem.because we do not see a baileved *e be numencally :ompancle Strd = cath after conception. when a need for a value higher than any now to his t!sti=e ask of fatai cancer. ne woman =ay not know cat she is
/
used in dis c:unt.y. The nsk asscciated dsk to a fema!e werief s descendants is ;res:: ant. 34 sed on :ur assess =e::ts :f' de..sks and ce other facters acted with 'io tem to any of dese :rtans is s=ailer. The medical seventy of dese I
equal to or!ess Was that of 5 rem :o de hereditary ef'ests is usually !esa dan.
acove. we heileve mat the =ax=um 1
}
whole body. Additienal dEerences item and. at worst. :=mparacle to. death from dose to de = born snould be a fact:r :(
t intemationally.used values for ganada, cancer. F r dese ressons we co not ten beicw de maximum per=tttec aduit 2
tens of eye. and handa are discussed believe that a =cre restnetive guice is workers in any year. nts is also de below.
required for de genads dan for de current recommencation of de National
(
Enclosure I i
- - - - _ ~
Federal Reitistse / Vol. 46. No.15 / Friday. fanuary 23. 1981 / Notices 7840 examinations. Some of these Couned ou Radiadon Protection and adequate protection against nonfatal
' examinations are a condition of Whde adequate protection against employment and some are not. Federal Measurements. In Recornmendation a cancers.
we propose four alternativu wiuch cataracts of the lens of be eye cugnt be radiation protocuan pidance on use of would. wita varying demos of certainty, achieve tais ooiecuve.
provided by a higher maximum averse d! agnostic x rays was issued by se ne first two alternatives rely upon annual dose than the 3 rum now Pruident on February 1.1773 (43 FR silowed, no operational difSculty is 4377), neee recommendations provide voluntary compliance and. taerefore, reported with use of 3 rem as an annual that. in general use of such x. rey should have less impact on equalich Unit.Dat value is therefore retained in examinations snould be avoided unless
' oppcrtunities for women. ne drst a medical benetit will result to a worker, assumes a woman knows she ts these proposals.
ne maximum annual dose fer skin of considering the impcrtance of the x.rsy pregnant within six weeks of the whole body is maintained at :o rem.
examinatica in preventing and conception, and will den. along with her since a need be allowing higher doses diagnosing diseases. de nsk from employer. take appropriate protecuve has act been demonstrated. However.
radiation. and te cost. Aldcugh ai! of sedon. It brefore den not parsatee that doses to de unborn dur:ng the de current guide permits 73 m to the recommendations ut dat guidance critical eerfy stages of pregnancy willbe hands and forear=s. or fut and acx!ss.
may be uu!udy appiled to x. cay because of the assumed kwer risk wnen exacusadons of workus.
less than o.nas De second alternadn adds a only these perucas of the sk:n and Rec =mmendadans 1 through 4 an voluntary!!=it en dcss rz:e to women underlying ussue of these extremities particularly per* Ment. Secause dis who enn beer children in orcer to are involved.We agne that at !aw dos
- matter sas been addressed by separate protect de unborn whose existance is rates te ruk depends in some degrw cn redersi pidance, ex;osure Sm such not yet known. !! permits wcmen to hold de a= cunt of skin and
- issue u;osed. diagnostic x.rsy examinatons is not any job, but encourages women able to and t st exposure of the ex:remities is inciudadin tis guidance fer bear childan act to take base few joi:s enefore less dangerous 6an of the occupatfocal exposure.
whi,A potential!y invoin 5:gn dose wnole body. However. fer forverms.
Car ent Federsi radance provides feet. and ankles such a hign value is not dat occupational doses to miners (icse rates.
needed and we propose taat :he rudes bdow S ne :( eigh* sa) e um:ud *o ne third alternaun Insures protection :f all unborn taroughout for sain and is whole body a;;iy to 33,,md 5 RFCa !st sider workes.
bn ex:remites. For de hands a nigher We propose no cha:p.
gestation by making de volun:ary value appears to be justiSed fer wors :n No other gueral types of exposed requtremects of &e second mancatery.
c.,acie u m u se!ewioes - ch me uma recommeneed by 2e ag.
- p,;=1 r;;*&,d=;,b',1al it would bar women of chdd.cearms glove boxes. It is proposed tis be 30 res g
However, one special class of worken-Other Consideratfons e!
a ter a e would restrict underground urantum =iur3+s nose reco=mendaticas a;;ly to aLudy suciect to a sepa-ste Federal the exposure of all worken. male and workers ex;csed to che San normal 7.ttde (:6 FR 1:3:11.Dat ptde !Lmits female. to a !avel which wou;d protect the unborn at b lavel of de Srst background racianen on ds joo. It ;s ex:osure of theirlangs to rscicacuve someumes hard to.denn!y suca
. decay products of nca gas.De Mne alternative.nas altsinseve ;rtserns workers. because everyone is uposed equal!cb oppcrtuntity kr women at so S'I'tY
- E* *16 Ad "*' d "
coat of causing mors !ctsi narm. Stucies to natural sources of nciacen and many ngulaus u;osun of a3 unnamound of several hign exposure acu*.. ties show occucanonal ex;osures are small.
mmers in accordance witn its pide.
that decressing the dose 'imits to this Regulatory agencies wt!! have to use
- ' "P*ct to review the rade on the extent would sismi!cantly menase se care in selec:ing dasus of workers decay products of ex;osure elminen ;o,sposun ciminus collective dese to workers. 4nd cat whose exposure does not need :s be raden in de future. -
some current activides would not be regulated. In u!ecnns such dasses we to other raciation is governed oy the recommend that de agency :onsider Tsdatal radiation protecnon pidance in possible.
both to cellective dose wnich is likely dese proposed neem =edations.
None of these alternativesIs completely satisfactory: they each to be avoided through regulation 4cd tae We have not addressed de !ss*1es of Involve eiSe varying co;rns of maximum individual doses possible.
amery.cy exposurs cr of,whether ne queston often at:ses whecu or overnoses in one yur snoutd lead to adequacy of protecton at ce unborn.
not exposen fer medical purposes and adcinoaal astncuotts on doses in future some sacnfice of equal job opportumty other nococc=sadenal ex:osures should years. Suca situations must be daalt for women. or causing men total har:n.
be considered in ceJculat=g de doses wtth on the ments in esca case 4nd or foregolag scme of the bensiits to dat workers receive within to pides.
under the regulatory mandate of de soc! sty from ac:ivities using raciatico.
If ene were e ireshold for ask of controlling Federal agecy. We do not We Invite ;ubile comment on $a hesid effects hm raciation. this could consider it ender practical or reasonacle
' relatin importar.co to be attached to each of these factors in formulating be an important consideraden, to preiudge or prucnbe gueral However since we assume that the risk guidance, and on whether or not the at !aw doses is proporncnal to tae dose, conditions for suen situancas beyond the genersi princ!;les which apply to all guidance should addnss this matter now.We would also be happy to receive ' each exposure must be justif!ed on its radiation exposure that an set forth individn! ments. For cis reason. In below in Recommendations 1 and 2.
suggesticas for other altunauves, Note I to $e recommendation? -re We reccgnize. !n adcit: aft, that seme umitation of Othw Riu.s exclude medical and other situations may ex:st wruca justify i
The risk of confatal cancer is not only noncccupaconal exposure from de total
!ntnnsically less !mocriant than that of calculated occucace=al raciadon planned exoosures exceecing the guides.
Recommendatton 9 provtces for this. It fatal cancer. but is very :nuch smailer ex=oeure of worxers.
requires dat the contrailing Federal than other nonfatal ocnupational rtsks.
In many joos ciagnosne eray exactinattons are a routine part of agency fully consider and disclose the provided agamst fatal cancers tecludes penodic or pre employment pnysical reasons for sny sucs exposures.
Thus, we believe the protecnon 1
- - _ _ _ - - - ~ -, -
~
Federal Register / Vol. 46. No.15 / Friday. January :3.1981/ Notices 7841 Estimated Impact of These Proposale cost of about 5:13 ou11 Ion per year. We be maintained as far below these RPGs believe the ac:ual cost of meeting de as is reasonably achievable and We estimated above that the aposure new RPC will be muca Iess.
consistent with Recommendation L of 1.1 mdI!ca workers in 1975 (the latest.
We have also attempted to craluate
- g.jg,,,
,, g.g, year for which we have ccmpicts costs 4 a seg weden no9ceteng statistics) will lead to IMS addinocal.
,ower doses are retrained to co argn-s.ne sum of the annual dose pnmatua cucu hams ud dose ichs insteed of hines new workers. equivalent
- from uternal exposure and comparable numbers of serious Some workers are very discult to the annual committed dose eqsivalent '
mutational ellects and sonfedal replace (e.g., medical professionals. such f.-om Internal uposure saould not
- cancers. If tis new gtndance is adooted, as careologists and ndskgtsts: and aceed the fadowing values-worksrs should be harmed less in the
,peken !n smau entergsu md my Whele body--3 rea future.We are not able to quaanly de mitadlabor pools).Howeve we cy%,,,
bng-nent because we cannot predict beUm dat most wer' sus can be tone of eye-s rem how e5ciently the guidance wul be eas@ n e d(e+ m M Mu mm a
!mplemented and we do not "unow how ans any sh Monn. M as AaMer W nu e
much of existisg sxposurs is unMst25ed. weiders and ptpe Stters) to hassle taska b.Non-umform exposure of 6e body However. de proposed
,cic3 e, p
omu, w, should also satisfy tae cund:ca en me recommendaticas provide a framework eetmate that weriars dat can be weighted sum d annual dose of graded minimum requirements to cut reassigned to thew jobe would mquire equivalents sad emmtad dm down the amount of miustified training varying from a few days to a equivalsats.
exposure, and a recommesdaden $at fm mends. Fw dose workes, de c=sts E., that implementing agencies estabiisit:ower an expected to range fr:m a few regulatory '.lmits for workers who can
- wcast to a few tens of per
- ent of te
- g.. g.,g,ce.n.
operste signffcantly below t e new a:nual cost of am hins. 6 sddicen.
when wi s a wetgnti:3 acter. K Is de i
f maximum '.1: nits. We beueve dat most
$ese costs are tscurred c=ly sect annual dose equivalent and : mmitted workers can.Se proposa:s also recuce instead =f an=ually, as 's de case of dose equivaient to orjas., and $e sum the maximu=2 annual and lifetics dose aew h We derefere asumate $at excludes te gent.ds..e:s of eye. and det any worxers can get by accut -m.
de c=sts based on the above :ew hires hands. Recommended values of wi are:
We have =ade ordy a ilmitad model.. y be as much as en 'd=es '.co u
assessment of the ecsts ofimpiamenting high. br tre ".rst year. and an even 5:eesw
. this preposed guidance. We do not gneter msdma's in succeedhg W te Red bene marrow-cas believe it wou;d :s prudent to ttempt a years. We wele:me comments on t e detailed analysis, because asences cents ofimplement=g sese proposals.
S Feid-4 04 same sunaceedes devotopmg ngulaticas to es. y cut dis on whoder er :ot =e cesu an "I
guidance may use effarent means. and reasonable, and way.
Cther organs Mce their specac proposals wd! be Proposed Recomrnendations c.When both :atferm whcie-bcdy subjected to ;ubi!c nytew and economic analysis wnen they are We propose nine recemmendadens as exposure and ::nu=ler:t ex;cours of developed.,
guidance to Federsl a;sacies is de de body occur. 2 addtten to de ne princ:;al cost wt!! be dat fer=ulation of Federsi radiauun requtrements of Ja. da annualsathrm asacciated wid nduced RPGa. !n order protection standseds be werxus. and 3 whole. body dose ecurvaient zuded :o-to comply with a reduced RFC an dett utabashment of ;regrams of de sum of weightec annuai dese equivslents f. s acdtuon4 senu.ahr=
enterprise can hin =en worxers.
c= operation wid States. ;n all cases but renseign (and. if necessary. rettsm) cae we have made singie exposurs. H., shculd set exceed 3 n=.
present employees. !=tprove Its recotamendacens kr puclic com=ent, t ne hikwg F-rum Rada: en procedures or techneicgy, or cartati ce ne excepden. Racommendatoa &
Protecten Requirements should be activity. In general, a mix or these wdl accasses ;tetecten et tse u= corn established by appropriate nudenties j
he used. depend!=g on :ce value of de dunng gestation. Because mis and carried out a de worxplace, on tce redaced RPC. on te cast of esca recommendauen invotves issues dat go basis of the tsage el deses anticpated alternative, and on other factors. Since beyond simple rediauca proteccon cf 6 Wdual werk situatiens. ne we do not know w:st mix wul 5e used.
worxers. !=ctuding equegity of.
sumericalvalues specir. q me dose for de ;urpose of devoicping recan emeleyment rtgsts are tre ::qnts of de ranges may be adjust:d to dt de needs numbencal estimates et de u:;er uncorn. we have ; reposed tour of spectSc, situstens by i=piemenc=g bounds of : sts we aave useo a stmpte alte aatives for puo!!c cess:cersuon.
"8'# ' **
model based :n the ecsts for hinns new ne recoc:mendacces foilow:
- 1. All occupational ex;osure should From me distnbudou of doses hund be iustined by Se net benefit of :te w D
- Y **,'~,'.3N g*j " d" 'j "
workers caly.
f In our natienal survey of exposures fer acuvsty causms $e ex;csure. De
- c.,
gg... t,
.n
.the year 1973 we computed the total justtScatica should include comparsble
.. w,,,,,,,g 4.,,,,,t., o g.
I excess cellective dose between the old considerstica of alternauves not ami, to do.wva ais f.as rananw.t.tn mmde l
m necy.a muss e swa. a.t son.ava;.ats RPG of 3 rem per quarter and te requirms radiation exposure.
su mar oram;m ew an end are e,-.~e proposed RPG of 5 rem per year.
1 For any fusit!!ed acuvity a sr.um. N 4y.
a so yurii'r==
l
- Civuiing this excess by te value of de sustamed eifert snould be made to
- '***"Y ~58' ' *^** * ** b**7 '"
- 3'""
assure tag tne ceilec::ve dose ts as low i
proposed new RPG gives me auntmum 7"*-
l number of werxers rest must be hired 'o as is reasonabiy aca:evabfe.
f
,3.no radiation dose to aidividua,s
(
i i
m
{
absorb this dose. De average labor saould certform to de numencal 3,,,,,,,g -,,g,,,.,, go, y,,
ccet, includag overneed. for esca Radiaden P otecton Cutues (RPGs1 ma u arc. au, n:4.: arc. zane c. u-t.:
additional worku was assumed to be specfled below. !ndividual doses snould i
arc.
$u000 ;w year.nis method yteids a
{
i Enclosure I
i 7ac Federal Resister / Vol. 48. No.15 / Friday. January 23. 1981 / Notices l
Afin/ mum Radledon Protect!on maximum annualIntake (In chnes) for involving whole. body dose rates ! ass which the committed dose equivalent to than a.: rem per month. Total dose to Requirements a reference persen sacsfies the the unhora during any known perted of g##I'3 Radlatica Protecdon Ceides in pregnancy should be limited to 0.3 rer
- s. Determine that execsures result Recc=mendation 3. RiFs =4y be or only from fustified activities and are as denved fer different chstmeal or d.ne whole-body dose ta bad male low as is reasonably achievable. These physicalforms and forintake by and female worn +: should not exceed determinadons may siten be made on a breathing. swailowtag. or for external 0.3 rem during any Ox month perted.
- 9. In exceptional circumstances the genette basis. that is, by considering exposure from a:r cataining a groups of similar work situations ar.d radioactive gas. F.anosure regulated RPGs may be exceeded, for cause. but protecdve measures.
through use of the RITs shoaid =eet the acly if de Federal agency having
- b. Morutor or otherwise determine same Mirumunt Radiation Protection junsdiction carefully censiders the individual or ares exposure rates to the Requirements as equivaient exposure specfic reasons for doing so, and extent necessary to give reasenacle under de Radistica Protection Guides.
puhuc!y discloses dem unless dis assurance that doses are wit in de
- b. When a RIF fer a soecific would compro=tse nation ! security.
6 I
range and are as low as is reasonably radionuclide in a specule cherucal or ne following notes c!ar 'y l
achievable.
physical form deter==ed on is basis of appilcation of tae above
- e. Instruct werkers on basic hazards part (a)is larger dan that curnady in recommendations:
of radiation and rad!atien protection use. a value no greater than that in
- 1. Occupaticnal exposure of workers princ1;tes and on de leveis of risk from curnet use should be adopted in does not tachde that due to (a) normal radiation and appropriate radiation regulations goveming worx situatiens background radation and (b) exposure l
protection praedcas fer deir specfic identical or simdar to those c::rnntly in as a ;stient of practitioners of de work situations. De degne of existence.
heaung arts.
instruction appropriate wdl depend on S. Federal agencies should establish
- . When de uniform extemal whole-the potential exposure involved.
Emits and ad= sistrative levels dat are body exposure cccurs in additten to below the RPGs c.nd de RIES. when this exposure from radioccuve =aterials A#"I' I
!s sp;ropriate. Such !!=tts or levels =ay takan into tne bccy. the requirement of ne above require =ents, plus:
appiy to suectic catagenes of workers Reco==endatica 34 =ay be satis!!ad by
- d. Provide professional radiation or work situations.
the concition that protector supervision in de work place
- 7. In addition to any other Federal suf!Icfent to essure dat both Individual restricticas de occupaticnal exposure
.and collecuve exposures are justifled of Individuals younger than eighteen g
achievable.
Rad!atica Protecnon Guides for adult IM.3, 4 y: j "
and are as low as is reasonabiy should be Um:ted to one tents of the
. ext:
e g'
4.
3
- e. Provide individual monitoring and workers.
recordkeeping.
- 8. T.xposure of de unbom should be restricted more dan dat ei workers.
Racge C
- nis should include svecial where N !s de annual external whole-ne above requirements. plus:
consideration of ALAM :nctices for body dose equivalant. PJC is 3 rem. I,
- f. Justify the need kr worx sin:stions woman. Wo=en abis to bear chddren is de intake of rsdier.uclide J. 4::d RIF, which are expected to =aie a should be fully !nlarmed of currce:
Is deilnad as in Reco==encation 5.
significant contribuuca to ex;csure in knowledge of risks to the unborn from
- 3. De values currently spectied by Range C and provide prelessional radiation. In addition. e=picyers snould the ICRP for quauty facters and cost =etric convenuens tor =easurement radiation ;rotectica supervision befcre asrure that protecton of tne unbomis and whde such jobs are undertaken to achzeved wiscut !oss of job secunty or of 6e vanous types of sdiacu =ay be assure that collecuve and individual economic penalty to women workers, used for deter = meg coruar=ance wita de RPGs.ne model for a nferenes exposures are as Iow as is reasonably Due to the complexity of tne issues achievable.
involved. we propese four alternante person and the metabelle =cdels
- g. Carry out suf!!cient additional recommendations on nu=st: cal currentiy specfled by the IC?J =ay be monitertng of workers to acnieve umitation of dose to de unbom for used to Wate de RIFs. We wd!
recommend other facters. conventions.
Rece;nmendation 4f.
puhuc comment. We would be glad to
- h. Cnce a worker has been ex:csed is receive ette reco==ennanons for and models when and af day ars =cre Range C. maintain a 11 red =e dose dealing with exposure of tne unhom.
appreonate.
record,inchding at least au subsequent
- a. Women are encoursged to
- 4. Numerical guides for e-tergency annual doses (as specfled !n voluntanly keep total dose to any exposures are not providt.1 by tais Recommendation 3cl!n Ranges 3 and C.
unborn :ess dan 0.3 nm durtne any guidance. Agencies shou'd foHow de L Maintain ufetime doses as low as is known or suspected prey:anc n or general principles established by reasonably achievaole.De
- b. Women able to bear cruldren are Reccmmendations L 1. 7. & and 7 la occumulation of doses (as recorded encouraged to voluntar:!y avoid job dealing with such situations.
under Recommendation 4h) by situations involving whole-body dose
- 5. Procedures for handlir q Individual workers should be managed rates greater dan o.: rem per mond.
overexposures are not addressed by this so dat their lifetime accumulated dos' and to keep total dose to tne unbom !sss guidance. no equitable hancling of le less than 100 rem.
dan 0.5 rem dunng any known such cases !s de respensddity of :he employer and the Federal agency having L a. ' Radioactivity Intake Facters*
regnancy: or (RIFs) should be used to ngulate
- c. Women able to best chtidten reSulatory furisdictica.
occupational radlauen hazards from should be limited to job situanons iI; nuts for penods other than one breathing. swallowurg. or tm=ersion in year may be denved by Federal media contaimag escianuc!! dss.ne RIF
.-t.e.ni.s men.ui.temia.4.am 3.
agencies from the annual RPGs and RIFs
.for a radionuclide !s defined as de
,y., anw.e weten necessary for admmt.muve t a rl w e v.o i
t j
7543 Federal Resister / VoL"40. No.13 / Friday. January *3.1981/ Notices l
b Issues reised in kw peutions (Sw
- Deso, ao ! ster than :s days prior to the purposen. Such !!mits should be consistent with Recommendation 2 and 40 FR 3at:y of Cc:ober:s.1973),
senedated date of a hearms.ne nonce should include:(t) We name. address.
to three ranps In Recommendation 4.
'I and telephone numoer of de partiegant:
,f 7.De exisung guide for Ilmiting ne hearings win be conducted by a-(2) the heartag at which dey wish to t
exposure of undart:ound urantum presiding omeer. A six metacer panel testifyt (3) the orpmzanon (if any) that miners to reden decay products is not consieung of representauves of EPA.
they wdt tepresene (4) de amount of chanpd by &en recommendadens.
C5HA. and NRC wdl antst the tkne requested: and (3) whien of the These propowd recommendations prestding ofHeer. A prinepal
!sesse they want to address. Oral i
wond provide peeral guidance for tne asponsibtuty d de panel mH be to presentations mH generaHy 'oe restricted to 30 minutes. Cetailed or i
radiadon protecton of workers. They clardy ce testimony by elletting vie,ws.
Ieegthy material should be summat=ed would replace dat part of exisens comments. and factual informacon trom guidance (see :s FR 4402 of May 13.
participants. Members of the panelwdl orady and presented in fullin wntten 1960) which applies to workers.
sot present mws or respond to subminions. Requests for f anger times
!adividual Federal scenefes, with soft ques.fons on behalf of their agences.
for oral presentacons wd be
'anowledge of specide worxer exsosure ne membenhip of tne panel =sy vary condsidered only on the basis at a detaded summary of t:e matertal to be situations. wcuid use this guidance as front use to time.
~
het hich ne pnyding c5cer and;4nel shan presented.ne Agency mu sadiy ded a aa tog uans :o have the joint responstbuity to assure a partictpants in anvsace if dett adocated "J'.*Me';"rJaML e.
rair ad t== r'i t h r=*==* t=
ti=e is tess than ihat re,u ted-at d 'au-r
^ = - ttv ~S * >== *d ach
--a * ****=iermed day of the hearmas far ;ersons who mees d es rekru agencies a eer
- ' *U '**tnbute to m decision.ma. mg. It m11 not be de have not submitted a socce as specfled lmplement de unal Guidance. to issue x
any necusary clanacadens and func:fon of de presidics cincer or the above to make beef oral statemects. A
!nterpretations, and to promote the panel to tasue se opinten er to make register wul be provided at the coortiination necessary for an effective decisicas at de conclusien of de beginmag of esca heen:4 or tis f
Federal program of worxer protection.
hearings.no presiding cificir shall purpose. A m um paned wu! he set conduct the haan=gs b an ceceriy. far.
asico for suca statea::::s in de apaca i
Pubus Hearings and expeditious manner and maka
!ct each heartng. and te ;nsiding Public hearings on thee proposed proced:eal decisions. His functions shah omcer may adocate addticnal::me as recommendations wih be held as Isclude, but not be umsted to. We necessary.De maximum sme anowed for such statements wd1 depend on te indicated above un6r de heading foHowms:
-Cates. Because of taetr maio' a.Reguladng the ceurse of de sumhr of agtstracts and de responsibihties to replate radiation hearmgs a:d the conduct of availability of time, but wd! 3enerally be exposures in worn places. the Nuclear participants. includhg estabitshing Hmited to ;enods of no scre thas 3 to Regulatory Ccamtssica (NRC1 aan me nosenable ticle !!=uts for ce hennngs.
10 minutes each. !s :rder'.o assat tre
" * *
- I
- 9""**
- 3* * '
- "'8"'""
- * ##8'E*" "
t a en {CSM.
Partic:pate
- tesentations and questiorung, aan wisning to maae sucs stata=ecu an in sponsot-bg dese hesnazs. ne openmg and closmg eacs hear =g encoursged to regtsur ;r r
- ;dy at ce I
begianirg of t e neann2.
following conditiens sad ;roccnuns sessica:
Attenca ce at me haanags wd! he 3, y,. ing deter inattens :encerning willgovern the concu : of te heanags:
- 2. Purpose. Type, sad Scepe procedure and si=dar matters:
open to ad memeets of ::e puclic, and s
- c. Assurmg dat questaning of seanng wd1 h made avanable en a first-Dese harings are to provide speakers by ;ssel mambers and others c me first. served hasts.
additional appertunity for ;ecote to is consistent with te natun and A TesdmonM hen h..nen express opinions and prende : actual purpose of these hear 5gs:
information to aid EPA.CSHA. a:d
- d. Mak:ng deter =unatices on 6, a.no oral pecceedings wt!! he NRC in carrying out deir respecttre relevance of oral testimony and recorded verbacm and a tanscnpa made availabe promply !ct i= spec:ica responsibiuties for g Wr.e on and quesdons to de is4ues identified as and copyttrg, as spec:iled below under regulation of occupational exposure to widin tre scope c( de heartsgs. or. in the heacing "Tr.e Pubil: Heans toniang radiation.The heannzs wd1 he consulation with the pasel, to adcitional Recort:."It wu! help de :anet J informal and !egistaeve in naturs estser issues pertinent to de precuci=gs: and.
speakers suppiy copies of deir oral than adjudicat:ry or for=al nuectasin4 as secessary, ter=usatzg irrelevant testimony before may 3:ve it. However, heenngs.Te:snicairules of evidence.
-resentations:
discovery. subpoena ;owers, testimony
" e. Ruling on late requests to
&is in act required.
- b. Fourteen copies el any wntres under oed. and simdar fermalities will participatr.
statements and documents on which not apply.
L Ceciding how locg de hearing speakers intend to base tett oral ne issues to be covered by these record will remain open !cr wntren heartags are ten 11sted above under contrits and additional data after de statements :nust be subcutted to de Director (s*e "Addnsses* above) no the heading *lssues Addressed" Dey end of de oral;rocudings.
!ater tan 14 days before de bettnaing Include dose Usted in our advanes
.r. P:st!cipotron m the Rectings og g,9,g,3 wgi,3 3,y.,yg.,gy, I
nedce of September !?.19M (4 FR 33735) and additiertal issues suggested Porscus c.c orgsnizations who wish to We would appreciste !! speakers would l
since then. As cdicated in dat notice.
give presentaticas '.:nger tan tsa also provide et;ht acditicnai:: pies for both EPA and NRC have burt getttiened minutes or ;-esent ex:ensive data and te use al de panei.
, i by the Natural Resources Defense endence =ui.e ;tve wr:tten notice to de
- . Quescons may be directed to Couned. Ise to revue occupanonal Direct:. Catena and Standards speukers by de heareg ;asel. by other Wance and standards.ne suciect Civision (ANR-aGo!. U.S. Esvtreamental speakers, and by otter r:temcers of de
'er of dese hearm;s encompasses Protection Agency. **/ashtngten. C.C.
- uotic. Speakers tay respond r set. as t
I e
reelnenro T i
7344 Federal Redster / Vol. 48. No.15 / Friday, fanuary 23. 1981 / Notices they wish. Questions should be designed S.W Washington.D.C.:04eo, and at (3 elicit relevant information and should each cithe Agency's ten regional omcas act be repetitious of questions asked by (see " Addresses
- above).
others.The views of questioners should Dated kanary tuet.
be expressed ia their statements and not Dossias M. caste.
as prefaces to quesdoes. 5uen informal d
^
geestioning will be at the discretion and
~
sader the contru! of the prestd!ng N "'* N * **
- oScor.
same sees mas.e
~
'd. Members of the public who are not ah!e to atter.d the hearings or prefer not t3 ask questicas themselves may suesest quostions to de hearing ; anal to ask of speakers.These must be submitted no later than 14 days before any heartng to the Directer (see " Addresses
- above).
The panel wt3 deede whether or not to ask these questions.
- e. Members of the public may also submit comments during the poste hearing comrnr.t period set by tae presiding omcar.These past-heanns comments should be conEned to responses to data and optalons submitted at the heartngs or to written.-
comments received by ttte Agency.
L In additica to tese public hearings, we would apprecate any written comments en dose proposals.These wig be givsn equal consideradon in formulatka Anal roccamendations. The procedurs for submitting sucs wntteo comment is given above under Se he :d!ngs " Dates" and " Addresses."
Participants in the hearmss may refer to and comment on such wntten -
comments, which will he available for public inspection and cocytag as,
speciSed below t= der -The F13IIe Heartspecord."
~
A Cpening S ctament At the opening of each hearinf. DA will;rovide a sc==ary statement of is proposed recommendacons and of tse major Usues involved. At th-* t!=e speakers and other membe.. we public can ask questions of Se DA representatives in order to claniv the
~
proposed recommendations and the reasons why DA la proposing denz.
A ~%e hbb*c Hea:ing Record The procedures for !!!Ing documents in these hearings will be spec 5ed by ttte presid!ng omeer. except as already prended herein.
The hearing record willinclude the transcript of oral statements by speakers. de questions and answers.
and all written matertals n!ed in connection with dese hearians. Items la this pub!!c tearing record will be E!ed under DA Cocket No. A.r') to and will be avaJable for;ub:::i-+- " n and
- copyteg as soon as ; o
. wing
~
their receipt. at th
-ental procceti.,n A;ea s C -
.et Sectico. Room 2;ut.P M.,J. st Street.
Enclosure I
~
. 4
,?'".
J' m,
g
~
J'
,,g*
4
+
6*
.. e,
- O e
w
.or
'+
- .' o u-.,,
- N.f %
k.,
,e 3-
. +..
+
s.. *,
e
' e' e.t., u
- s
.t
.. 4 g
,,. fa, g -,... s,.
to *,
'G
- 4 s
,4,,..
+g*
e
% Q.'.-E ( $
('-
b
.-4 g
5, ee-44,5.,.4; t
4
.e,,e,
.e,~..
a
+
A,,,..".,;g..s -is d *,s.. *3 f '..' d.
4
.. ~ W. *.
1. m.. v., u -
- i.,.
~.
. ~..- - -
s-
,a
, - g
, e.:e De
'*TD a
.m v.
.. -',,,-+*e-
." 4.
f..*
s
.;g.
e g
- . 'd,
- en*4
- r
.s p- *,.
,.9,-
- m*.',
., g e* "
- s
- 4
-'r' a ~
-w
.e s s k*t..4,*.
,. *; ~
.;s ;g t.
w
-g*m
^
4 -e g
- f4
. j O
9 e
4
.a 6
Y I
e '
9 4
f s
1
-o* 4 a
.A
'k p
6 g
We
/
ENCLOSURE II
/
e 6
}
7 Mr. Walter C. Barber Acting Administrator U.S. Environmental Protection Agency 401 M Street, SW., A-100 Washington, D.C.
20460
Dear Mr. Barber:
Enclosed for your consideration are the Nuclear Regulatory Commission comments on the proposed " Federal Radiation Protection Guidance for Occupational Expo-sure," published on January 23, 1981 (46 FR 7836).
We recognize the difficulties faced by EPA in developing new guidance for radia-tion protection of workers.
Our response is intended to be constrt?tive and to
' assist you in your efforts to develop the final guidanca.
In summary, while we agree in principle with many of the proposed recommendations, we suggest a number of substantive changes.
Although we do not suggest adopting all of the recommendations in ICRP Publica-l tion 25, we now strongly recommend adoption of the system of dose limitation as l-recommeaded by the ICRP.
That system is logical and self-consistent, and appears to be based on the best scientific information available.
The proposed EPA guidance endorses summation of external dose and internal committed dose equiva-lent,'as does the ICRP system.
However, the proposed EPA guidance also incor-porates major departures from the ICRP system, including changes in organ dose limits and changes in weighting factors which, in our view, would impair the usefulness of the system.
1 Enclosure II
o We recognize that the EPA proposed guidance reflects endorsement of the interim position taken by the Commission in October 1979 on retaining current limits for internal radiatien exposure in the workplace.
However, since pub 11-cation of the ICAP recommendations in 1977, additional information regarding the-bases-for these recommendations has become available.
Open discussions of those. bases have led to a more complete understanding of the ICRP system which, l
in turn, has resulted in a more compitte endorsement of the ICRP system by the international radiation protection community and the NRC staff.
The Commission believes that the ICRP system is based upon the best scientific information and methodology currently available and that the ICRP's general approach is consis-tent with the Commission's policies regarding (1) the appropriate application of. risk-based methodology in regulatory decision making and standaras setting and (2) the necessity for vigorous application of the ALARA concept in radiation protection activities. ' Accordingly, the Commission requests that EPA acopt the ICRP system of dose limitation intact as a sound basis for quantifying relative risk, regulating exposures to radiation, and as one which would be consistent with that used in other countries.
i i
The Commission is also concerned that implementation of some of the EPA pro-posed guidance would infringe on the personal privacy of women who choose to work in a workplace where they might be exposed to radiatien and might inter-fere with the career options of persons who, during the course of their work, could receive greater-than-average doses during their working lifetimes.
In its Federal Register notice (46 FR 7836), EPA requested views on (1) the desirability or necessity for a reduction of the 5-rem radiation protection 4
2 Enclosure II v-syW*
y-v+pyg
-e-g-W w%w m 9-y y m + y yvg gag ygvg-- g sq qq pg-ygymf,mWm--,3+y+,y*wap9n9pe%e-pi--itr$~--hWwem4Wev%-4-WN-T'-~r**--
r-eve,
w e swwPNr=*T-Wp4N-w TN*t*"-'NeN*
r.
. guide (RPG) on effective dose equivalent and (2) the provision of additional EPA guidance that would establish more explicit requirements on exposure of individuals.
The Commission does not consider any reduction in the 5-rem RPG or additional guidance by EPA to be necessary, justifiable, or desirable..The Commission' supports the approach of providing all workers with information on which to base informed individual decisions on the acceptability of-the risk
- associated with employment involving radiation doses.
Enclosed are both general and specific comments on the proposed EPA guidance.
The specific comments are numbered to correspond to the numbered recoc1merda-tions as they appeared in the Federal Register notice.
Sincerely, Joseph M. Hendrie
Enclosure:
NRC Comments 1
. 3 dnclosure II er+-gdv
- tw-e
- rPe
-w w
g-*s-u*-W 4-6e i--W--sur d-----yg+W--7 Se-+ti-g>-a----w-wIr-eM aeeya e----'e eW'--
-T++e T-'
k e-
-*em
+=g-s-
wi e
a
.., ~
~
NRC COMMENTS ON PROPOSED ' FEDERAL RADIATION PROTECTION GUIDANCE FOR OCC(DATIONAL EXPOSURES PUBLISHED JANUARY 23, 198}-(46 FR 7836)-
j A.
GENERAL-COMMENTS
+
The NRC's-evaluation' of the ' proposed EPA guidance has identified a number of:issuesLthat would' introduce substantial problems for the NRC--and perhaps,
-for other agencies. 10ne of the key issues is the, proposed adoption of,a system
'of. dose Llfmitation resembling the :ICRP system of dose limitation, but which
- includes a number' of departures that, in our-view, would impair the usefulness of.the system.. The NRC endorses the adoption _of the ICRP system of dose limitation.
Our endorsement of the ICRP system is in recognition of some very desirable features of that= system.
The ICRP system:
(1) is based on a contemporary radiation erotection philosophy that woulo require-(a) justifying why perscos are to be exposed to radiation (b) ensuring that any ~ exposures are as low as reasonably achievable, and (c) using appropri-ate dose limits; (2) is-based on an " acceptable risk" rationale that is derived from the 1
statistics of job related risks to workers in the " safer" industries, excluding
- nuclear; (3) provides a method (a) to combine doses to multiple organs, doses from multiple radionuclides, and doses from internal and external exposures and L
(b) to express these doses in terms of a whole-body dose equivalent on the basis af risk considerations, which may be compared to the dose limits; 1
Enclosure II ya,- - - -
,,vw---%ge_,,-se-_.-,.,,.,m-,-c,wwm3 3y34.+
gwyew_.,-.-.-a, p,9ggm,.....e-eesp-vew++e-.i4-4w-WN-wp*
-e %rewpe p--g
-e.- ( P-e" p p w'g-
.*we'rtg
-uww,p.
e-g-19 w
- p. ei e wg 9yey9e g m v y -y9y
.gm9 em-py
(4) incorporates the state-of-the-art knowledge of biological, physical, and dosimetric information in deriving " annual limits of intake" (ALI) and
" derived air concentration" (DAC); and, (5) provido ppropriate dose limits for normal working conditions, which are generally more restrictive than previous limits; but provides flexibility for exceptional operational difficulties when it is in the public interest to
- exceed the primary limits.
The new ICRP analytical models are so complex that sophisticated computers are required to calculate those quantities (such as ALIs and DACs) needed to implement radiation protection programs and to regulata the use of radioactive material by industries cnd others.
Owing to the complexities of the calcula-
- tions and the interdependence of the features of the ICRP system of dose limitation, it is not possible to arbitrarily change some selected parts of the system without costroying the continuity and coherence of the whole, which would be the effect of the proposed EPA guidance.
If the proposed EPA guidance is promulgated in its present form, all of the calculations and tables provided by the ICRP must be replaced, and the implementation by all U.S. agencies would be made extremely difficult.
In addition, communication with radiation scien-l tists of essentially all other countries with.adiation programs could be l
extremely difficult because the U.S. would have different definitions for the same concepts.
The ICRP system has been adopted or is in the process of being adopted by the IAEA, the Commission of European Communities, the OECD Nuclear Erargy Agency, and most countries with radiation programs.
The selection of a 2
Enclosure II F'
e-c--m yw w-
.=ww 1-
--*-em' N'e-
'TNb
N
~w
-yw w
7vw
rT
- - - = " ' ' = - -7 9-
'O
~*
to' specific system of dose limitation has a direct impact on international agree-ments, cooperative efforts, and guidelines, related to radiation doses to workers and members of the public.
A ther area of concern to us is that some of the differences between the ICRP system and the EPA recommendations are changes that EPA justifies on the basis of demonstratad practicability.
We believe that the current experience does not demonstrate practicability, but does demonstrate technical feasibility.
This difference is significant.
Primary dose limits and DACs must be met regardless of the costs which might be involved.
In contrast, practicability (in the sense of "as low as practicable"--now "as low as reasonably achievable")
requires consideration of the costs for achieving a particular level of radia-tion protection.
This distinction is the heart of the ICRP system of dose limitation, and we believe that many of our problems with the proposed EPA guidance stem from mixing of ALARA issues with the issues dealing with selection of primary dose limit values.
l~/
An additional problem that we have identified is one of semantics.
Terms such as "should," when used in regulations, usually indicate a substantial amount of flexibility (i.e., that options are afforded to those regulated);
the term "shall" indicates that action is required without options.
- However, when the EPA recommendations appear in the Federal Register over the President's signature, the word "should" may have the impact of the word "shall" for Federal agencies. With this in mind, we have noted that several of the proposed EPA recommendations, that would seemingly permit substantial flexibility for affected Federal agencies, might actually result in de facto limits and require-ments that were not intended.
3 Enclosure II J
s,-~,-w-,
-.,yw,--~
w
,e,,
,.,..~
--,,.,,,.-,,,s,.
,.,.,nn,
,,--,a-,n,
,n.., -.,,, -
P 8.
SPECIFIC COMMENTS Recommendation 1:
EPA's-first recommendation would require the justification of all occupa-tional exposure.
This is consistent with ICRP recommendations, and we concur in this recommendation.
Recommendation 2:
The second recommendation would require that collective doses be as low as is reasonably achievable.
This is also in agreement with ICRP recommenda-tions, and we concur in this recommendation.
Recommenoation 3:
Recommendation 3, would provide radiation protection guides (RPGs) that
.are not consistent with ICRP recommendations.
In our view, recommendation 3 constitutes a major and undesirable departure from the ICRP system of dose limitation.
Key differences between the ICRP system and that proposed by the EPA are as follows:
?
1.
Differences between EPA and ICRP recommended dose limits are shown in the following table:
Organ Annual Dose Limit EPA ICRP Gonads 5 rems
-- (a)
(*)No value given by ICRP, but 20 rems may be inferred from the weighting factor for gonads.
(b)The ICRP provides these dose limits to avoid non-stochastic effects.
4 Enclosure II
..-~-
2.
As shown' in the table of weighting factors below,. EPA is proposing
~
the exclusion of the risk to gonads in calculating the weighting factors, but-is pro, posing the inclusion of skin.
Tissues Weichtina Factors (Wt)
TPA
.ICRP Gonads 0.25 Breast-0.20 0.15 Red bone marrow 0.16 0.12-Lung 0.16, 0.12 Thyroid 0.04 0.03 Bone surfaces
-0.03 0.03 Skin G.01(a)
Remainder (other organs) 0.40 0.30(a).
3.
The EPA guidance states that the value of an ALI (or equivalent) currently in use'is not to be increased in regulations governing work situations identical with'or similar to those currently in existence although information provided in ICRP Publication 26 and its companion volume, Publication 30, would
- support increasing some ALIs as well as decreasing others.
The ICRP system of dose limitation would (1) combine the doses from inter-
- nal and external exposures, (2) add contributions from several internal organs in a " weighted" manner, and (3) impose an overall combined limit for the whole
. body of 5 rems or its equivalent in terms of dose to body parts or organs.
The ICRP system of dose limitation makes use of a series of " weighting factors,"
W, by which the dose to each organ would be multiplied to give an effective T
dose that would be equivalent to a whole body dose with respect to risks.
The ICRP system requires that the " effective dose equivalents" for each organ be r
(*)Five other organs with highest dose.
The factor for each of the other organs is then 0.06 (ICRP) or 0.08 (EPA).
4 5
Enclosure II w
e ay-e s
-A e
+3W G
g
-we-.g-r--"=s ow qw y
e, 9
%e--y pi g,
y y
pwgr--p---y o-g
, - -w
k summed (along with any external whole-body doses) and that the sua should not exceed 5 rems.
The ICRP does not recommend an annual dose limit for a single internal
~
organ.
However, an annual dose limit for a single organ may be inferred from ll
~ the ICRP W values if it is assumed that (1) there is no external exposure and T
that.(2) no other organs receive any dose during intake, transport through the l
body, and elimination of the radionuclide.
In this case, the dose required to yield a risk equal to that associated with whole-body irradiation might be so high that some nonstochastic (prompt,~nonrandom) biological effects might occur.
In order'to avoid these nonstochastic effects, which are related to dose in a
" threshold" manner, the ICRP recommended a constraint that the annual doses to l
L any internal organ not exceed.a conservatively established value of 50 rems.
Thus, the 50-rem dose constraint should not be ccmpared directly with the dose I
limits for " critical organs" that are currently being used.
The ICRP limits for the. lens of the eye and for skin are also-based on avoidance of nonstochastic effects.
l Since the 30-rem dose constraint proposed by EPA for all internal organs l
presumably would be used to avoid nonstochastic effects, and since the 50-rem L
dose constraint of the ICRP system and the 30-rem dose constraint of the E?A are both below the threshold for such effects, it would appear that the lower l
l dose value selected by EPA would represent an unnecessary added factor of con-
^ servatism that is not supported by either biological information or cost-benefit analyses, and wculd'cause confusion in relationship to practices in other countries.
This is also true of the differences in dotes to the lens of the eye l
table.
l and the dose to the skin, which EPA chose to include in the WT l
6 Enclosure II
~
O w--*a w-,
sww-
,ew s
<m..,,,yn-2g..w-.y p,_n.p.oy g _,,,,p
,,mpp.,,,,
While the ICRP system of dose limitation, which combines doses from exter-nal and internal doses, would, in-general, be more restrictive than the current standards some derived air concentrations based on the ICRP system would be somewhat higher than the current values.in 10 CFR:Part 20 (based.on FRC guidance) for a' variety of reasons.
For example, the ICRP values are baseo en quantifi-cation o'f risks; they are derived using contemporary biological models; and some organs are less important radiocarcinogenically than others.
The ICRP system of _ dose limitation, which ir.cludes justification, ALARA requirements, 4
and dose limits, is based on a logical scientific' rationale that is internally
- consistent.
Compared to current EPA (FRC) standards, some annual intake limits (and their reflection in_ the derived air concentration values) would increase, some would decrease, and others would remain essentially unchangad.
The primary
- dose Ifmit of SL rems per year would not change. ' We believe that the EPA guidance should reflect the new values for the intake limits and DACs indepen-dent of the direction of th. change.* We believe that any restrictions on exposures below the basic limits, particularly those that would be selected based on operating experience, are ALARA issues.
Such mattars, can best be handled by the regulatory agencies who can judge whether any adjustments are needed, and if so, by how much, and the justification for doing so.
By; removing " gonads" frem the list of organs that are included in the derivation of W values, the proposed EPA guidance would increase all but one T
of the W values for the remaining organs.
Since the doses to each organ are T
J
" learly, if questions occur concerning a particular issue, such as wnat the C
MPC value shculd be when chemical toxicity restrictions might be more limit-ing than tha radiotoxic restriction, or should the N'CRP or others identify any problems that we have not anticipated, the issues should be resolved before the-new values are implemented.
o 7
Enclosure II JtW
- TP-mWe1 9 e --
qw-T
's*-*rwW w twg v1v=
ei-w--wg mm-g--
wgMpv-<-g**ep-1-ty-7(
e-t e%vew-e-"e ye
=qirgiw-*
- ,g+rw-ye*m't>w=WW *N af%
-f*
W'e T-'"XMWNF
-'Em=+--PM*T'*M>P'T-N-'e' wr' wf'M9"'"WP'T e-W i
i multiplied by the W value for that organ in order to obtain the effective dose T
equivalent, the effect of the EPA change would be to' add an additional factor L
of conservatism without-justification.
By limiting the annual dose for gonads l
to 5 runs, another factor of conservatism is introduced by EPA for that organ.
i If the U.S. adopts a variation of the ICRP system, as proposed by EPA, the U.S. derived effective dose equivalents will not be comparable to those deter-mined on the basis of the ICRP system which is being^ implemented by essentially all countries with nuclear industries throughout the rest of the world.
- Further, there will not be a simple way of translating.from one system to the other for comparison purposes.
All ALI and " derived air concentration" (DAC) values in ICRP Publication 30 are based on the ICRP system.
If the proposed EPA system is adopted in the U.S., an entirely different set of values for ALI's and DAC's will have to be established (calculated) for use only in this country.
We feel that a cost-benefit analysis would not support the departures from th'e ICRP system proposed by EPA.
Moreover, departures from the broad, generally applicable guidance that are more conservative than the primary dose limits should be seen in the context of ALARA and should continue to be the prerogative and l
responsibility of the individual Federal regulatory agencies.
For the reasons stated above, the NRC requests that EPA revise its recom-mendation 3 to conform exactly to the ICRP's risk-based system of dose limitation.
~
l I
8 Enclosure II e-
~+,,----,--"re--eoym,.
-rnm.m.,,
4 If the EPA concludes that it'is necessary.to achieve greater radiation-safety by-arbitrarily' adjusting parameters, the NRC believes that the RPG~ values-should be adjusted /rather than the components of the-formulae and procedures used to calculate.the " effective dose equivalent" values.- In this way, at least the. basi.c biophysical data developed by the ICRP could be~used and the ability
. to communicate on. radiological matters with scientific and regulatory peers in the world community would not.be' sacrificed as a consequence of the EPA having modified some of' the key ~ elements of the system of dose Ifmitation.
Recommendation 4:
Recommendation 4 contains a set of graded radiation protection actions correlated with three exposura ranges.
It is our view that the form of the set of graded radiation protection requirements could_ result in greatly increased
. costs and-personnel requirements that are not likely to be justified by the dose saving, if any dose saving is to be realized.
We believe that a cost-benefit analysis should be made as part of the basis for the final decision of EPA with respect to this. recommendation.
/
We agree that protective measures should be commensurate with the potential risk in the work place as indicated in recommendation 4.
In fact, the Commis-
. sion's present regulations include this approach.
However, the NRC requests that the implication of de facto limits (" Ranges") in recommendation 4 be 1
avoided by making a change in the wording to replace the term " requirements"
(
with the term " actions" so that the first sentence reads:
9 Enclosure II
-e m y 'msp -y-yg-
,upy'**4 m----v9--
g M g-- eq P W#-M-%-
9-g we eagyt-$'-9WEP$***b'M
-NN W "w 9 g Gw-yMmw$Webeewse f"g-er*7w-r*W-"
e'*e**'**N-TW-*eY'w"W"W'**T'-'
C"-*'m--"
"--'""^-^-- --~
"The following minimum radiation protection actions should be established by appropriate authorities and carried out in the workplace on the basis of the range of doses anticipated in individual work situations."
Recommendation 4:
Recommendation 4.i. pertaining to a career dose limit would have the effect of requiring that each worker's lifetime occupational dose be limited to 100 rems.
Although'NRC-EPA staff discussions indicated that'the language of recommendation 4.i.
would be hortatory, the use 'of the words "should be managed" in this recommenda-tion, when signed by the President, may, as a practical matter, leave no room for discretion on the part of the implementing agencies.
This would have the effect of requiring that each worker's lifetime occupational dose be limited to 100 rems.
Such a dose limit would be, in effect, a two-to three-fold reduction of the maximum lifetime dose permitted by recommendations of the ICRP and NCRP, which allow an average of 5 rems per year.
This proposed career limit is based on EPA's premise that maximum potential lifetime risks from occupatici1al expo -
l l-sures to radiation should be limited to a value comparable to averace risks I
from other occupational hazards. We consider this approach to the establish-ment of radiation risk limiting standards to be unjustified.
I Serious qusstions would be raised by imposition of such a career limit.
l Clearly, it could impact significantly on a person's employability, job conti-l nuity, and ability to plar, and pursue a career.
An individual's career, for which extensive training and experience are required, could be terminated i
j prematurely, regard?ess of the individual's willingness to accept continuing i.
I 10 Enclosure II l
E
exposures and the associated risks.
Indeed, we are not aware of ar,y valid epidemiologic study that. demonstrates any observable increase in health effects at the radiation exposure levels found in the workplace.
In addition, a significant career impact may result if a worker has accrued a higher total dose than others competing for the same job.
An employer could be expected to hire selectively those workers with the lowest career doses regardless of their skill level or other positive attributes.
The accumulation of 100 rems would likely occur at an age when, because of latency considerations for radiogenic cancer, the risk per unit of dose is.
actually decreasing and when hereditary considerations are declining.
The career limit might, in effect, select 1<ely remove those individuals from the work force who are at least risk from additional exposure.
Further, it must be remembertd that 100 rems does not represent : dividing line between abso-lute safety and unacceptable risk.
Under t'.1e " linear hypcthesis," the 101st rem presents no more risk than any other, earlier, 1 rem dose.
Also, current data indicate that only a very small number of workers are likely to exceed a dose of 100 rems during their working lifetimes.
l Based on these considarations, a requirement for limiting ca eer doses to 100 rems, with its potential for career interference, does not seem justified.
l It appears that requirements for justificatico of dose and ALARA efforts would l
l acccmplish essentially the seme objective.
The NRC suggests that reccmmenda-tion 4.i. be recast to read:
" Maintain lifetime occupational doses as low as l_
is reasonably achievable.
Individual workers should be instructed on the levels 1
of risk from radiation and encouraged to mair.tain career cumulative dose as lcw 11 Enclosure II l
~ - -.. - -
as is reasonably achievable." NRC regulations require that workers be informed of the risks associated with the radiation exposure so that each worker can make an informed decision in this regard.
Recommendation 5:_,
Recommendation 5 pertains to the regulation of occupational radiation hazards from breathing, swallowing, or immersion in media containing radio-nuclides and introduces the term " radioactivity intake factors." Tt:e term "radioactivi tv intake factors" should be replaced with the ICRP term " annual
. limits of ini The introduction of the additional term " radioactivity intake factor" is unnecessary and can lead to confusion and misunderstanding.
Also, it is suggested that recommendat!on 5.b, pertaining to the reten-tion of existing radioactivity intake factors (or their equivalent), where j.
they are smaller than such factors calculated on the basis of the new proposed system, be deleted.
As stated above with respect to recommendation 3, we feel L
.that justification for departures from the broad, general system of guidance in such areas as exposure limits that are more conservative than the guidance should be the prerogative and responsibility of the implementing agencies.
We believe that this is a matter that could best be handled by implementing ALARA requirements, as presented in recommendation 2, with which we concur.
Recommendation 6:
Recommendation 6 states that " Federal agencies should establish limits and administrative levels that are below the RPGs and the RIFs, when this is appropriate...."
The Commission believes that this recommendation is unneces-sary and should be withdrawn.
We believe that Federal agencies have such 12 Enclosure II
authority now. ' To the extent that the recommendation.fs read by some Federal agencies to require establishment of lower limits it could result in the imposi-i tion of different standards by the several agencies.
If, after reconsideration, EPA concludes that it is necessary to make a' recommendation of this nature, we
- request that the word "should," in the first sentence, be replaced with "may."
Use of the word "may" would recognize the responsibility of individual agencies to take actions appropriate to optimization or ALARA and to justify such actions,
- including actions such as thosa overed by proposed Recommendation 5.b., dis-cussed above, which should be recognized as an ALARA issue.
In addition,- if Recommendation 6 is retained, it should be revised to encourage interagency cooperation and consistency in setting standards, par-ticularly where twr or more agencies have responsibilities for differene facets of a particular activ uy or operation.
Examples of this are the authorities of MSHA and NRC over uranium milling, and the author,ity of OSHA over naturally-occurring and accelerator-produced radioactive materials (NARM) that are fre-quently used in the same programs as byproduct, source, and special nuclear materials regulated by NRC.
Differences between agency standards could pose a significant problem for States having formal agreements with both OSHA and NRC for the assumption of certain regulatory controls.
This is because those agree-ments require a finding that the State regulations are compatible with the
. Federal agency's regulations.
Recommendation 7:
The NRC concurs in the recommendation that workers under 18 years of age be 'timited to one-tenth of the RPG for adult workers.
13 Enclosure II pw t<w
-y e--+,-w.
wwwwg-y a
v'-
-w-wr-w ggyrvtian-.-y w vw w og g
wywi.p.*e w&,q,.my.yywy p-_.www,*i yy.+ c ygv w-9,y-wygg-kg w wg, 9-,que gyw,y=rT9f***8 wwWWPwM'9t*=w**
wtT**7wwTw=*F*--WMN a'thvwww*
r.
Recommendation 8:
In recommendation 8, which pertains to exposure of the fertilized oocyte, the embryo, and the fetus, EPA has proposed four alternatives for comment.
Based on much deliberation in this area, we consider a voluntary approach, such as alternative "a,"'as the oniy practical approach.
Alternative "d" appears to establish an RPG for whole-body dose of 1 rem per year for all workers l
(i.e., 0.5 rem per six-month period), which is '1 consistent with the RPG of 5 rems per year given in recommendation 3.a.
In a'ddition, such a1 RPG would probably fail a practical cost-benefit test and appears to be an unreasonable coat :*aint on necessary operational flexibility.
Alternatives "b" and "c,"
are discriminatory towards women, unduly burdensome in their restrictions and, for reasons given below, are probably not capable of being fully implemented.
i Although recommendation 8.a. seems to embrace a purely voluntary approach, it contains what amounts to an exhortation to limit the dose to a woman sus-
-pected of being pregnant to 0.5 rem during the pregnancy.
The NRC cannot dis-l agree with the intent of this part of the recommendation, but we are concerned l
that the inclusion of the 0.5 rem figure is likely to be interpreted as a de facto limit and result in serious limitations on women's employability and implementation problems for regulatory agencies.
A requirement that a female employee be removed from or limited in her performance of work involving exposure to rzdiation because she is fertile, or because she is pregnant, raises both Constitutional and statutory questions.
l l
In addition, such a requirement implies an obligation on the part of the f
licensee, and perhaps the NRC, to determine, as a condition of employment, who 14 Enclosure II l
-is fertile and who is,aor is likely to be, pregnant.
Any mechanism to accomp--
lish~ this involves a potential for infringement of the individual's right to
- privacy.
1The present NRC approach to protection of.the fertilized oocyte, the embryo, and the, fetus encourages the instruction of all radiation workers
' about the risks t these entities associated with occupational exposure.
This permits each individual to make a decision as to whether or not to accept (or continue to accept) those risks associated with exposure to radiation, based
- on the best available radiological information.
We request that the guidance not contain any language'that may be-inter-preted as establishing or recommending the establishment of special limits for fertile and/or pregnant women, but rather that it encourage fully informing both men and women with respect to the risks involved before they uccept radia-tion work.
In'effect, the recommendation should be based on an " informed con-sent"Lapproach with fertile or pregnant women being free to decide for them-selves whether or not to accept work involving radiation exposure after being instructed as to the risks associated with such exposure.
Recommendation 9:
We agree with the general nature of recommendation 9 that, in some cases, doses exceeding RPGs can be justified.
The obvious example 's an action that, although resulting in-doses above the RPGs, results in preventing much larger doses to others on a collective or individual basis.
Those workers accepting work that involves the potential for receiving doses in excess of RPGs should 15 Enclosure II w
-em.
---y.---
-,e-*h---r,v-4vem
-=a+---4 e--t+--or+w w-v
-e'a v - vr,,w-*
g st-w m,w s -
w
--v-e--*,
--ev7- - -
v
-i--= < - -
--,--v-w*e.evi--w--vt-ete-*iwewe--
be aware of the potential risks involved and should be free to decide for them-selves whether to participate in such work.
It is anticipated that circumstances requiring doses above the RPGs would occur infrequently.
In many cases, these circumstances would develop in such a manner that they could not reasonably be foreseen so as to permit a long period of planning preceding the necessary action.
In other words, the preven-tion of major harm may depend on rapid and decisive action by responsible management at the scene.
In such cases, it would be unreasonable to expect the licensee to notify the NRC, provide detailed information, and await a case-by-case evaluation by the staff.
We believe that provision can be made for such actions in NRC regulations without involvement of the NRC staff in lengthy evaluations of each such action before the licensee is authorized to take the necessary actions.
Therefore, the NRC requests that EPA recommendation 9 be reworded to avoid the implication that a case-by-case evaluation of each and every action that may result in exceeding the RPGs is necessary prior to such an action.
This could be accoinplished by revising the existing recommendation to-read:
l i'
"In exceptional circumstances, the RPGs may be exceeded, for cause.
Provision for doing so may be established on a generic basis by the Federal agency having jurisdiction where clear and specific criteria f
are provided as a basis for permitting such doses, including the requirement that such doses are permitted for the purpose of miti-gating circumstances that might, otherwise, result in greater harm to other workers or the general public."
16 Enclosure II
~w--J d-v-
,ee
--wee--+-e w
w w
w-
--,---e
- w,,v---n w-e,,,,
mver s
,-e w
w----4
,-g---
.+-v
-- y y4-
4 C.
. NOTES CLARIFYING RECOMMEf:0ATIONS:
4 We have two suggestions concerning the notes following the recommendations.
The_ffrst concerns.the manner of compliance with subitem e of recommendation 4 (individual monitoring and recordkeeping), and the second pertains to recom-i l
i
.mendations 2 and 3 and the' mp ementat on of the ALARA concept.
1.
Note' Clarifying Recommendation 4.e:
~
The most direct, and perhaps the most desirable, way of determining committed internal. dose is by means of determining _the amount and location of
. internally deposited radionuclides by bioassay methods.
However, bioassay met'ods (including whole body and organ counting; breath, urine, and fecal h
analyses) are not always practicable at' exposure levels encountered in the
~
workplace.
In order _ to clarify EPA's _ acceptance of other more-indf ract methods for estimating and controlling internal exposure, we request that an additional note, perhaps designated 2.a., ce inserted between notes 2 and 3 to read:
l "With_ respect'to-the requirement in subitem e of recommendation 4 for the provision of individual monitoring and recordkeeping, it is
-recognized that, under some conditions of exposure, monitoring indi-vidual exposures by means of bicassay procedures will not be feasible or necessary.
Therefore, regulatory agencies may provide for alter-native monitoring and recordkeeping procedures such as monitoring and recording of concentrations of radioactive materials in air to l
which the individual is exposed and the duration of that exposure."
l L
17 Enclosure II
{
Even'this alternative might prove'to be difficult to implement in Range B
- where levels ~might ce as low as 10 percent of the RPG from both internal and external exposures.
2.
Implementation of ALARA We are concerned that the EPA proposed guidance may be read as requiring a rigorous quantitative.fsplementation of ALARA..The difficulties involved in
- a rigorous quantitative approach to implementation of ALARA are recognized in ICRP Publication _26.
The NRC has studied this problem and concluded that, wh'ile quantification of the cost-benefit analyses associated with reducing the
- exposure of-workers to radiation and optimization of radiation protection provi-sions are desirable goals, the implementation of ALARA should not be delayed while the problems associated with such a quantitative approach to ALARA imple-l L
mentation aru solved, but should proceed on a qualitative basis.
That is, the elements of optimization analyses, which would include the costs as well as technical practicability and benefits, would be considered in judging ALARA.
1 A quantitative optimization analysis can be costly.
Some applications l
-are too trivial'to justify quantitative analyses.
In these cases, qualitative analyses are adequate. What is important is that the elements of an optimiza-
- tion analyses be factored into the decision-making process.
I We, therefore, request that EPA clarify its guidance with respect to ALARA i
implementation by adding a note to the effect that ALARA implementation should not be delayed while a rigorous, quantitative implementation procedure is per-facted, but should proceed on a structured qualitative basis.
18 Enclosure II uy*e-w-C+*"
N 4
w e
w
't ww
=w,**wf e-4w W
D w
v
-w-
.--y.-
e
$-wwm-sye-
-W--w' evt wp eyv ww ve-w vgww gegge-esn y-w---
wwg----
w"
+e'
-i-wweiw-'<w----+-1e-==we7
-M M
g v
e D.
OTHER COMMENTS:
1.~
EPA requested comments on approaches to further restrictions on the expo-sure of workers in Range C, which is defined in EPA recommendation 4.
As indi-cated above, we have serious reservations concerning the overall value of the proposed set of graded minimum radiation protection requirements as proposed in recommendation 4.
It does not appear that EPA guidance that would require further. restrictions on exposures within any range below the RPG could be justified on a rational cost-benefit basis.
It is our view that each indi-vidual regulatory agency is in the best position to determine the justifica-tion for and the specific nature of any such requirements.
As expressed above, it is our position that the 5-ram annual RPG as proposed by EPA and as
. recommended by ICRP will result in radiation protection that provides an adequately-low level of risk relative to those found in other safe industries, With the requirement for justification and ALARA efforts at all levels of expo-sure, any further restrictive requirements seem to be without merit and verging on stultification.
2.
EPA requested comments on the possible reduction of the 5 rem annual RPG.
t The NRC has published proposed amendments
- to 10 CFR Part 20 that would elimi-nate the 5(N-18) formula and the 3 rem per quarter standard that allows up to 12 rems per year.
We see no reason to reduce the annual dose standard (RPG) l below 5 rems at this time.
The staff has done an extensive analysis of the pros and cons associated with a proposed dose-limiting standard reduction.
It was concluded thct any significant reduction would result in very substantial
=
44 FR 10338, Published 2/20/79.
19 Enclosure II
?-
-#V%
e To T
T M
w *eupwww
&e w
we--
wy-
--A.e9-=ww%*-wwwm ee-W
he-o w+-W-'ke-=
=
cw
- * ' - - --e e--
- -A-ea-ev-e w*e--'-ew-'m>-*v e-y*w--ee+* - - * ' -
costs and that a reduction to 0.5 rem per year wou'd result in wholly unaccept-able impacts, including, for some activities which NRC regulates, a significant increase in collective (person-rem) dose, when considered in light of the theoretical benefitsi Further consideration of any such reduction by EPA should include a thorough and carefully developed cost-benefit analysis.
l l
l l
I
)
l t
l
[
l l
l l~
l l
20 Enclosure II l
,4,
-_f'4-C.M,.-J"M4,4J"A.'
<L_M'+fW (X
"W---.a.u-Wt__In---ete.
U
-EUe.m.**e-w
. ew we..
ytFJ S e_em.i,-. -
(j tw
>D-4 g7
.w P-_
.eem t
?>
(J 9
4'
+-
y.
('
s =
m 4
}
}
e'.
1 g
4 em "
4
.4,-
... -..:; y,.
~,
... - +..
t, e, q
s t,
g..
~
~
p
~%..
y
'm*'
r7.c -. *,-
.,* Q......
y,,Z '
'w.
..v,.
g
^,Q*,....'ya.,-
, g,,g g.
.,,.,.. 4,g, 4,,. q ; 3. %
7,,.,,
e,'
4,Y
,$ -, :^;
,4
- r =s,.. I e.*.-.),
.3=.,. u,
-.,. t -
3-6, i., ;, ','
4,.
(,
.g., **
..w.,=.
.,,p
,aw a.
f.
..g e' g" 4. 4 g e..,, +.. w,e p e.
.*..~p*
3
, rs, 3
o
.,,.J.4
.. ;*',,,"L l~
- f*
y 5
,..~,r
,e
~~
- e " >
- s n
s.
r o.
.Ag-g.
e p'
sa w
h m
t -
e; o.
4
-.).
- ' o..
4 m
- =
,g-e 4
e,*
g,.-~.
em t
... M: -.
g 5 ; s.,. w / -
t-g
- r. ~
.f.-
.a 3
- g
..y_
e, i
e
-r.'
=
9 -
TF g
f e-e 3
I w-
~
4 b
l 0
8 e.'
p -
ej f'
+=
e
,'M 4
p 6
ENCL.05URE III f
[
r k
i, e
b f'
em.
W t,
,/r-ht ht I
i-1 e'
h
(
1 Fu i
f, t*
u
SUPPLEMENTARY INFORMATION IN SUPPORT OF PROPOSED NRC COMMENTS TO EPA A.
lBac'karound L
l
_By memorandum of October 30, 1979,-S. J. Chilk to L. V. Gossick, the staff was informed that the Commission "has, as an interim position, concurred l
with the staff's recommendation to retain current NRC limits for internal l'
. radiation in the work place." The proposed guidance published by EPA reflects the Commission's interim position.
~ B.
Current Staff View It is now clear that the majority of the technical staff recommends a
(
change from' the. Commission's interim position to a position that the ICRP system of dose limitation, including W values and limits to avoid non-T
' stochastic effects, be adopted by EPA and NRC exactly as proposed by ICRP.*
As indicated in the proposed comments to EPA (Enclosure II), the majority
.of the NRC staff endorses the adoption of the ICRP system.
Although the EPA proposed guidance bears some resemblance to the ICRP system of dose limitation, it includes a number of departures which significantly impair i
the usefulness of the ICRP system.
i-I Clearly, if questions occur concerning a particular issue, such as what the MPC value should be when chemical toxicity restrictions might be more limit-
~ing than the radiotoxic restriction, or should the NCRP or others identify any problems that we have not anticipated, the issues should be resolved before the new values are implementad.
l l
1 Enclosure III Fuw Tft w*-pp 19 g-
,?%v%*^
9
,:+r8 w
=>m-H T
N-T
l l
The staff believes that the_ICRP system is based upon the best scientific
~information currently available and that its general approach is consistent-
'with~the Commission's current policy regarding the appropriate application of risk-based methodology in regulatory standards and actions.
- The bases -for.the staff's current view are discussed below.
C.
- Bases For Current Staff View The.ICRP system of dose limitation is the heart of the controversy between
.the NRC staff'and EPA regarding the proposed guidance.
Although the ICRP system was published in 1977, relatively few persons are to.niliar witi, the
- details of.its features and the differences between the ICRP system and the current NRC dose limits.
A general understanding of the ICRP system is necessary to appreciate why valid simple comparisons of different systems (ICRP-26, NRC and EPA) cannot be provided.'
Attachment A presents a very brief summary of the principal features of the ICRP system of dose limitation.
Attachment B is a copy of a Nucler.r Safety article that contains a more comprehensive summary of the
- entire ICRP recommendation, including the system of dose limitation.
Since the time that the ICRP recommendations (ICRP-26) were published, additional information regarding the bases for those recommendations has become available.
Open discus.ons of those bases have led to a more complete understanding of the ICRP system.
This, in turn, has resulted in a more complete endorsement of the ICRP system by the international 2
Enclosure III w
4
+w
-m
.p-
-aa e
ew -
>+g-
--c
-t-ar e-e-ce-e-es
.m e e.
= 1 w e e-ey--Wg or
-s--wwe-
+-S' af r--n,ie-esmw-v-------rums--7--gv.w ei-w
community ~and by the NRC staff.
A number of the principal facets of the ICRP system are discussed below.
The ICRP system of dose limitation, which includes justification, ALARA requirements, and dose limits, is based on a logical scientific rationale that is internally consistent.
The system includes derived limits using
.(a) contemporary biologic and dosimetric analytical models and parameters and (b) the sum of weighted internal doses and external doses.
Compared to current NRC standards, some annual intake limits (and their reflection in the derived air concentration values) would increase, scme would decrease,-and others wc: tid remain essentially unchanged.
The primary dose limit of 5. rems per year would not change.
The dose limits of the ICRP system would not necessarily increase the current dose limits.
Some of the ICRP dose limits would reduce the maxi-mum annual dose values that would be permitted by the current NRC (FRC) limits.
For example, present NRC regulations do not require any reductions in the internal organ dose limits because of exposure to external radiation sources, or any reduction in external dose limits because of the dose from l
radioactive material deposited in the body.
Thus, current regulations would not prohibit up to 42 rems per year to the bone and thyroid (30 rems
- internal, 12 rems external).and up to 27 rems per year to the other single internal organs (15 rems internal,12 rems external).
The ICRP system would (1) combine the doses from internal and external exposures, (2) add contributions from several internal organs in a " weighted" manner, and (3) impose an overall combined limit for the whol'e body of 5 rems or its 3
Enclosure III
-+..w,-wp r e e
y-P-+
-p.a
-g7 a.--y+
9wp+.~,--w
-p'wi-'vvw---'-+.,
w w*w
--g--
gyy-iir 6-a w a?%
v, 6-.--
+
m e
7yw-,
ir ww,-.=
s-ap r
c
. equivalent in terms of dose to body parts or. organs.
(See further discus-sion in Attachment A.)-
While the'ICRP system, which combines doses from external and internal doses, would ~ be more restrictive generally than.the current standards, some-derived air concentrations based on the ICRP system would be somewhat
. higher.than the current values in 10 CFR Part-20 for a' variety of reasons.
.For example, the derived air concentrations are-based on quantification of risk, they-.are derived using improved contemporary biological models, 'and ~
some organs have been found to be more important radiocarcinogenically than others.
E The' consensus' of the technical staff is that the primary dose limits should be based on the-best scientific information available.
Whether values for
^
derived limits rise or fall, the values that result from a scientifically based, coherent system should be used for the standards.
The-actual intake by workers or the concentrations in the working environ-ment do not depend entirely on the primary limits in the standard.
It has been recognized for several decades that a key element of an effective radiation protection program is the ALARA effort.
This is reflected in recommendations of the ICRP, NCRP, FRC, EPA, and others.
The implementation of the ICRP system would make ALARA a requirement, rather than an admoni-tion,'and we endorse this feature.
The implementation of ALARA, rather
'than the dose limits, effectively establishes the level of radiation pro-tection.
The levels of protection achieved by licensees (at considerable r
i 4
Enclosure III
.. 1
.Z..Z.1.li Z i Z..
Z.~...
expense) in the past should not be a principal determinant in reaching subsequent-decisions on limits.
Rather, the limits should be internally consistent.
The staff believes that any restrictions on exposures below the basic limits, particularly those that would be selected based on operating experience, are ALARA issues.
Such matters can best be handled by the regulatory agencies who can judge whether any adjustments are needed, I
and if so, by how much, and the justification for doing so.
Licensees are required to meet primary safety standards regardless of costs.
On the other hand, the costs of efforts to stay ALARA below the limits must be considered. While licensees are operating well below current limits, including MPC values, this demonstrates technical feasibility but it does not demonstrate practicability (in the ALARA sense) because the costs might not have been factored into the consideration.
It would not be appropriate to restrict the changes in primary standards when the new values would permit some relaxation if the licensee could demonstrate that alternative design or operating procedures would satisfy ALAR.. ccnditions.
The ICRP system makes use of " weighting factors," W.
The dose to each T
to give an effective dose value organ is multiplied by the appropriate WT
-equivalent to whole body dose with respect to risks.
The ICRP system requires that the " effective dose equivalent" for each organ be summed (along with any external whole-body doses) and that the sum should not exceed 5 rems.
The ICRP does not recommend an annual dose limit for a single internal organ.
However, an annual dose limit for a single organ values if it is' assumed that (1) there may be inferred from the ICRP WT is no external exposure and that (2) no other organs receive any dose 5
Enclosure III
- +=e-+rwre-4----w~---
.A u
u
during intake, transport through the body, and elimination of the radio-nuclide.
This " limit" would restrict risks of fatal. somatic effects (cancers), which are assumed to be proportional to dose.
However, the
. dose required to yield a risk equal to that associated with whole body irradiation might be so high that some nonstochastic (prompt, nonrandom) biological effects might occur.
In order to avoid these nonstochastic effects, which are related to dose in a " threshold" manner, the ICRP recommended a constraint that the annual doses to any internal organ not exceed 50 rems.
Thus, the 50-rem dose constraint should not be compared directly with the dose limits for critical organs that are currently being used.
The.ICRP system is based on an " acceptable" risk value derived from data on industrial fatalities in " safe" industries.
Non-fatal cancers and
^
additional hereditary considerations are different end points which could have been chosen, e.g., non-fatal cancers might have been compared to
- illnesses caused by chronic exposure to chemicals or non-fatal accident statistics.
Other end points such as statistical loss of lifetime could
/
alsohavebeinusedratherthanfatalities.
The rationale of the ICRP for the selection and the method used to reflect this risk in terms of dose limits is discuss:d in Attachment 8.
Four reasons were set forth in SECY-79-1B in support of the position advocating no increase in permissible organ doses or radionuclide intakes:
(1) Reporting requirements would be relaxed; 6
Enclosure III e
w w,.. -+,,.
..,___.,_.,.,-..r_,_e.,_.,.,
,.,,.m,
,-,..,_-.-,_.m.
(2) Facility and process design decisions would permit higher exposures for many future years;
- (3) Licensees are currently meeting present standards, including MPC's, therefore practicability has been demonstrated; and (4) There is uncertainty about risks attendant to exposures to low level radiation.
l 4
As indicated above, the staff believes that the regulations should reflect the new values for the intake. limits independent of the direccion of the change.
(a) Reporting Requirements Reporting requirements should be reevaluated in light of the new limits and either tightened or relaxed depending on the reasons for requiring the reports in the first place.
The reporting r<.1uirements should not be a reason for influencing the selection of the values
, used for secondary dose limits within an otherwise coherent system of dose limitations.
/
(b) Facility and Process Desian Facility and process design decisions might indeed be influenced by the values of the dose limits and derived limits.
It seems reasonable that they should be so influenced in order to refl.ect changes in either direction.
Actually, the design and operating decisions are much more closely related to ALARA requirements rather than to the dose limits.
For this reason, it is doubtful that increasing selected intake limits would be reflected in a relaxation of design features.
7 Enclosure III w--3 Jp-..-m Gs e-M yy"'W-u
'f"M""*"
'--r*rw-?Nr,> w mga
+-T*qMqs----=+--swe-wp4g-vg--+--emessg g
ye,-g,aveg - y y w
-waw-W-se
-9'aer-g-t^e.w aw-me-y
-g s
T T
(c) Current Practice This issue was discussed previously.
(d) Uncertaint',cf. in Risk There is more scientific evidence on the hazards of fonizing radta-tion, than on most, if not all, other environmental agents that affect humans.
Comprehensive periodic reviews on national and international levels
- have been published by the U.S. National Academy of Science (NAS),
the (U.S.) National Ccu.1cil on Radiation Protection and Measurements
- (NCRP), the International Commission on Radiological Protection (ICRP),
the Unit?d Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), and othere.
There appears to be close agreement among these and similar expert organizatiors that the current state of knowledge concerning low-level exposures is quite adequate to serve as the technical base for a system of dose limitation such as that recommended by the ICRP. Most expert advisory groups have expressed more concern that too much conservatism in the selection of a system of dose limitation might result in the use of alternatives that could produce greater detriments to humans than exposures to
- aadiation Indead, the dose limits recommended by the ICRP are generally viewed at being a conservative, but not excessively conservative, i
basis for radiation protection.
l I
l-8 Enclosure III 9
y 9='w
- -e++
g e-tp
,w,,m--g g--g--y-i,r-+,-m,,
eMt vt *-
T=W
- =W--9f--9*-M* ' 'W W--#-W'-N
"*N
-NWN'T'"'WTT'W T-7T""-~T""-'=Er
- T--*"~'T-D4-'
'*-"Wu-
""-'v*'-a W'---pTW"T'=W'-f-
4 i
ATTACHMENT A TO ENCLOSURE III i
\\
l FEATURES OF THE ICRP SYSTEM OF DOSE LIMITATION l
The ICRP System of Dose Limitations is presented in ICRP Pubitcation 26 (1977).
L l
The main features of the system are:
l L
"(a) no practice shall be adopted unless its introduction produces a i
positive not benefit;
"(b) all exposures shall be kept as low as reasonably achievable, t'
economic and social factors being taken into account; and
"(c) the dose equivalent to individuals shall not exceed the limits recommended for the appropriate circumstances by the Commission."
For convenience, the feature. stated as item (a) is often termed " justification,"
item (b) is termed "ALARA," and item (c) the " dose limitations."
L.
In implementing this system, justification can be judged by applying cost-benefit techniques
- in either a quantitative or a qualitative manner.
Imple-mentation of ALARA_can also be achieved through the use of cost-benefit tech-niques.
In order to determine whether a reduction in exposure is " reasonably achievable,"'it is necessq*y to consider on the one hand the increase of
" Basically, the not benefit resulting from the practice is equal to the gross value of the practice (which includes the value of the product plus tangible
- and intangible social and other benefits) minus the production costs (includ-L ing the costs to society of nonradiological detrimen.ts and the costs to pro-tact against the nonradiological hazards), minus the cost of radiation pro-L taction, minus the cost assigned to tne radiation detriment involved in the l.
operation.
Realistic, rather than conservative cost estimates and collectile doses must be used in the cost-benefit analyses in order to avoid distor-tions that might bias the decision-making in favor of an alternative that is not evaluated conservatively.
1 Attachment A m
9**
MN=
sv " pg y
-p
-um
- w-PON?hw r*
a ww wee-Twe-Te-w>
w-1u-r-e
- tew-g-----4*----
u-
- =-++ - *=-- --
benefits from such a reduction and on the other increase of cost involved in its achievement.
The process of analyzing the costs and benefits of incremental changes in the level of radiation protection to determine the maximum degree of protection which is justifiable is termed doptimization" assessment.
The optimum radiation protection system permits the maximum benefit from a practice involving radiation exposures, while satisfying all dose limit requirements, at the minimum overall cost.
Such a condition is, by definition, as low as reasonably achievable (ALARA).
Since, for radiation protection purposes, any exposure to radiation is assumed to involve some degree of risk, all exposures should be kept ALARA.
The basic requirement can be met in a qualitative or quantitative way.
In particular, the' quantitative approach is recommended when formulating quantitative require-ments such as setting an authorized limit fer prescribed actions.
The aim of the quantitative analysis thould be to assess how far exposures can be reduced before further reduction would not justify the incremental cost required to accomplish it.
This assessment can be made by a differential cost-benefit analysis, i.e., an optimization assessment.
A quantitative optimization analysis can be costly.
Some applications are too trivial to justify quantitative analyses.
In these cases, qualitative analyses are adequate. What is important is that the elements of an optimization analyses, e.g., consideration of alternative measures, their costs, and their Jeffect on the levels of exposure, must be factored into the decision-making process.
2 Attachment A
=+m'.
-mm v
-rg-mm'eare
- we+
e,-,-r,wg---
up
.--giw-
-.-.,,9-.-,--p--w-u y
- w
-e-9-+--
9pp----e y-9--wy,v.ya',yr9 9
-wwww gi---
n Dose Limits For radiation protection purposes, it is assumed that for random (stochastic) somatic effects:
(a) the probability of a health effect occurring is proportional to dose over the exposure range encountered by radiation workers; and (b) the severity of the health effect is independent of the magnitude of the dose.
A range of " acceptable" risks for workers was selected based on the risk of fatalities from industrial causes in " safe" industries.
Information con-carning the distribution of doses to radiation workers was considered in conjunction with the relationship between dose levels and probability of health effects to select the annual dose limit for radiation workers, e.g.,
5 rems for uniform irradiation of the whole body.
-The quantity of radionuclide which, taken into a body, would yield a risk equal to that of a 5-rem whole body external dose was calculated using contemporary dosimetric and biologic models and parameters, and the available data to esti-l-
mate the relationship between doses to specific internal organs and health effects.
Values of the weighting factor, W, by which doses to individual T
organs can be multiplied to yield a whole body effective dose equivalent were i
calculated based on risk considerations.
l:
l In those cases where the internal organ has a relatively low risk of fatal cancer induction, additional constraints were provided to avoid prompt non-l
?
l 3
Attachment A a'$g.v c t*t V
- e
-wuWF-
"r-7-&
s-ew-Pg-Ce-=8+-ryy9'w-ee w-'+-ea9ys-&st
-e-wr+-
wT-w--
O
$-9--
pw4e=i*y-w mwW-=
r----
w tvw
,w-e e-
--e, wtww e'
W e -ere+-
l stochastic (nonrandom) health effects.
Such effects are related to dose in a threshold manner, i.e., they have not been observed below a particular dose magnitude. -The ICRP selected 50 rems per year as the value that would prevent nonstochastic health effects in internal organs.
Nonstochastic effects for external organs are-avoided by using special dose Ifmits for the lens of the eye (15 rems per year) and for' skin (50-rems per year).
Ooses from internal and external exposure modes can now be added with the
~
use of the weighting factors, W, t'i the resulting sum, " effective dose T
equivalent" values, can be expressed in units of rem (or sievert).
Derived Limits The ICRP has provided tables of " annual limits of intake" and " derived air concentrations." These tables
- contain values derived using the best avail-able analytical models and parameters, ICRP W values, and ICRP internal organ T
dose constraints.
)
/
I L
i I
l l
A i
Values are currently available for radionuclides of 21 elements.
Values for the remaining elements are being calculated at the present time and sill be available by the time the system can be implemented by getting the regulations l~
in-place.
4 Attachment A l
.,--,,,.-..-.z,..,-
. _, _, _,,,.,,._ _.,. __.,,,. e_
..... _ ~.
4,
4.fs.
.n.
n r-a.
l, j
?
f
(
4e,
P j'
S F
i 1
f
' b r
1" p
(
~
h f-
] :-,,
t k-J.
l P
1 ATTACHMENT 8' TO
~
1-ENCLOSURE III i
'I d-o
?
E CLEAR-SAFETY' ARTICLE' t
[
o L
f z.
n
-"REcotWENDATIONS OF THE-a L
INTERNATIONALiOfMISSION ON RADIOLOGICAL-PROTECTION"
)
5 f.
e.
/
I' s
k.
b D
e y
--'t..,
II.: ~
1 s; y
\\.
Y e
9 l-;
1, I(I l'-
A i
.'. ~. i.....
___.___.,_.-_.__-_a._.___
____.__._.__.....,,__,,,,,..,.mm
~ Recommendations of the International Commission on Radiological Protection Adapted by the Nuclear SJ/ery Staff
[ Editor's Note: The fogowing adaption by the.Yuclear$4/ary
- ppropriate body to give gener:! guidan:e en the =cre Editorial Staff was made from a much longer report of th*
widespread use of r2distion sources c:used by the rapid sune name I/CRf hescstion 251. The report is an authorita-developments in the field ct nuclear energy.The (CRP dve so=== of informados om dsk estimates et :l! health j g
' associated with ionizirq rad!ation and provides an estabEshed medical radiology and the medical profession genersity, basis for radiation protection actions and poscies both la this counoy and elsewhers. A summary is presented here to and it also recognizes its respcastbdity to other provide s penetradag insisht into this importsat ares l professional groups and its c'elig: tion to provide guidance within the fle!d of rsdtstion prote:tien as As one of the c mmissions established by the Interna.
whole. Details of the ICRP rules, membership, and tiens! Con 5ress of Radfology, the Internat!6nal relationship with other bodies are in the appendix to Commissica on Radiological Protection (ICRP) has IC.8t/hbEcarfon 26.
continued its c!cse relationship with succeeding Con-In 1966 the ICRP published its re:cmmendations gresses,.and it has also been looked to as the
/rct/ /ub# cation 9/ which had been adcpted in 1965; l'
NucuAn susTY, vea. so. No. 2. Mov-Jua.1sm l
l.
l.
i e
... _ =...., _...
1 1
)
1 331 ENVtMr#.tENTAI. EFRCT3 they were amended in 1969 and 1971. During thelast the chief somatic risk ofirradiation at low doses and is I
decade new infermation has emerged which has neces-therefore the main problem in radisuon protection.
sitated a review of the Commission's basic recom-Some acnstochastic somatic effects are specific to mendations; the present report results frorn the ex.
particulst tissues, as in the case of estar:ct of de ! ens.
amination of such new Information by the ICM and scamalignant damage to the skin, cell depletionin the its committees and task groups.The recommendations bene marrow causing hematological deficiencies, and made la this report supersede the former basic recom-gonadal cell damage leading to impairment of fertiity.
mendations published by the Commusion, but not Other nonstochastic effects may arise in the blood vessels or connective tissue elements that are commen necessarGy those ofits committees.
As in Its previous recommendations. the ICRP deals to most organs of de body and therefore require dat, only with fonizing radiations in this report.
as a prec:utionary measure, a dose equiva!ent hit The Comnussion wishes to reiterate that its policy 6ould apply for 211_ body tissues to ensure that acnstechastic effects do not occur in say such tissue.
l l
is to consider the fundamental principles on which For ai! these changes the sewnty of de effect depends appropriate radiation protection measures can be bued. Because of the differing conditions that apply In on the magnitude of the dose received, and dere is various countries, detailed guidance on de appliestion tikely to be a clear threshold of dose below which no detnmenn! effecu are seen.
of its recommendations, either in reg.dations or in codes of practice, should be riatorated by the various The aim of radiation protection shou!d be to g
international and national bodies that are famdiar with prevent detrimental nonstochastic effects and to limit l
r what !s best for their needs. The ICRP reccgnizes that the probabdity of stoch.stic effects to levels der =ed to
(
l the Individual experts responsible for putung radiation be acceptable. An additional aim is to ensure dat l
i protection into practice need guidance that is suf.
practices involving radiation expcsure ne justined.
Sciently flexib!s to allow for natienal, regional, or The prewntion of nonstochasne etTecu would be other vufatica. For this resson the ICRP recommenda-achiewd by setting dese equivalent !!=its at suf-tiens us intended to provide an appropriate degree of ficiently low values so that no threshold dose w x.!d be SexibElty. Seesuse of ties, the form !n which the reached, even following exposure for de whc!: of a recommendations are vorded wn1 act necessar:1y be tifetime or for de toul period of werking IIfe. The l
suitable, and may often be in:.ppropriate, for direct
!!mitation of stechastic etTects is achieved by keeping assimilation into regulaticas or codes of pracuce.
aH justifiable exposures as low as is re:sonably achiev.
Ule, ecoccmic sad social facters being taken into acccunt, subject always to the beendary ccndition dat l
OBJECTIVES OF RADI ATION the appropriate dese-equivalent !!mits vJI not be PROTECTION exceeded.
Most decisions about human activities are based on Radiation protection is concerned with de protec.
tion of individuals, their progeny, and manhnd as a an implicit form of balancing of ecsts and benents i
whole, while still a!!owing necessary activities from tending to the conclusion that the conduct of a chosen which radiation exposure might result. The detrimental practice is " worthwhile." !.ess generally, it is also effsets against which protection is required ue known recogni:ed dat de conduct of the chesen practice as somatic and hereditary; radiation effects us called should be adjusted to esaximize the benefit to the
" somatic" if they beccme manifest in the exposed individual or to society. In radistica protectica it is individual himself and " hereditary" if icy affect his becoming possib!s to formalize these bread dectsica.
making procedures, although it is not always pessible descendants.
to quantify them. iIowever, de applicanen ot dese "Stoch tic" effects are those for which the proba.
procedures does not always provide sufficient prctec.
bility of an effect occurring, rather than its severity,is tion for the individual. It is therefore necessary, for l
i regarded as a function of dose without dreshold.
dis reason also, to establish dose equivaient limits in "Nonstochastic" effects us those for which the sever.
situations where the beneSts and detriments are act ity of the effect varies with the dose and for which a received by the same members of the pcpulation.
threshold =2y therefore occur. At de dose range involved In radistica protectica. hereditary effects are For de above ressons de ICRP recc= mends a regarded :s being stechsstic. Some somsne etTects are system of dose lunitation the main features of which l
are at follows:
stochssuct of these, carcinogene::s is censidered to be NUCt.!AA sMETY, W. :o. No. 3. %=Me 19M
-n Attachment B
.. ~..
,...s. t.
333 ENVIRONMENTAt. EPPECTS
- h' l.No practice sha8 be adopted unlessitsintroduc.
severity of the effect is expressed by a weighting factor
-i tion produces a positive net benefit.
gt, then the detriment to health, G, in a group of 7
.]
- 2. All exposures shall be kept as low as reasonably persons is given by.
achievable, economic and social factors being taken' g f g p,,7 lato account.
3.The dose equivalent to Individuals shan not 1
exceed the limits recommended for the appropnate.
' circumstances by the Commission.
The absarbed dese,' D,is insuf!!cient by itself to predict either the severity or the probability of the 1
recommendations, we must deleterious efTects on health resulting from Irradiation In applying these
. recognize that many present practicas give rise to dose under unspecified conditions. In radiation protection it
- equivalents that will be received in de fhture.Thess is convenient to htroduce a further quantity that-dose equivalent ' commitments should be taken into correlates better with the more important deletedous account so that necessary developments of present of etTects of exposure to radiation, more particularly with future practice would not be !!able to result in undue the delayed stochastic etTects. This quandry, called
...H uposure of any members of the public.
dose equivalent,is the absorbed dose weighted by the.
.y Although the principal objective of radiation modifying factors Q ud N.
protection is. the achievement and maintenance of The dose equivaient,H, at a peint in tissue,is given appropriately safe conditions for activities Involving by the equation.
human' exposure, the level of safety required for the l
- UO#
protection of all human inuividuals is thought likely to be adequate to protect other species, althcugh act where D is the absorbed dese. Q is de qua!!ry fa: tor, necessarily individual members of tho.c species. Thus ard N is the product of all other modifying factors the ICRP believes that if man is adequately protected, specified by the ICM. At the present time de ICRP then other living things are also likely to be suffi:iently has assigned the value I to N.The special name for de Prot M.
unit of dose equivalent is the sievert (Sv);
- BASIC CONCEPTS 1 se = 1 J kg-8 (= 100 rems)
~
.v Detriment The quality factor, Q. is intended to allow for the effect on the detriment of the microscopic distribution
~
The deleterious e:Tects of exposure to radiation fa energy.
Q fact r u dehd as a may be of many Idads. Among the effects on health, function of the couision stopping power (L,,)in water
~
there may be both stochastic and nonstochastic efTects at the point ofinterest. Interpolated values of Q as a la the exposed individual and stochastic effects in later I""#*I n of L. can be obtained by using the values i
generations. In addition. there may be deleterious 6 wn.in de table below.
1 5
effects net associated with health, such as the need to l
restrict the use of some areas or products.
. The ICRP has introduced the concept of detri.
L.-Q Relationship i
ment to identify and, where possible, to quantify 22
[
these deleterious effects. In general, the detriment in a
[*
g l
population is defined as the madematical "expecta.
j-tion
- of the harm incurred from an exposure to 3J (and under) 1 7
2 radiation, taking into acccunt not only the probabGity 23 of each type of deleterious effect but also the severity g
of the effect.These deleterious efrects include both the 175 (and above)
- o effects on health and the effects not associated with 9
health. On some occasions it is convenient to deal separately with the effe:ts. cr the potential etTects, on For a spectrum cf radiation, an effective value, Q, of Q health. These are den characterized by se :encept of at the point'ofinterest can be :alculated.2 detriment to health. For effects on hesith, if pt, the When the distribution of radiation in I.. is act probability of sutTering te effect I, as small and me known at all peints in the volume of interest, it is Nuct.aAn sueTv. ves. :o. No. a. Mov-Aa. is7s 9
=m*
=%p e.--
g
..AMaehment R
.- _ -.--.- -- -. -...--..--..-,-.-.. - -..-- - -..., -.-..-.~.
222 ENVtRONMENTAt. EPPECTI
~
permissible to use :pproximate values for Q related to cesses is in fact highly sigmoid the risk from low doses the various types of primary esdistion. For this could be overestimated by making a linest extrapois.
purpose the ICRP recommends the following values of tion from data obtained at high doses.
@ to be used for both external and intemal radiauon:
There are tsdiobiological grounds for assuming that
- e dueesponse mu (w low.W rshon ws i
X rays, samma rays, and electrons sm@
su in 4e me assg dose and f
Neutrons, protons, and singly charged particles dme nu m de absabed dme mge up to a b i
of test mass greater than one atomic mass gny.t a many ects nu d expatsuy, de unit o(unknown energy 10
- P"" I" *E *8' **" D* "F **""d DY **
5 Mpha partic!ss and multiply charged particles -
'N (and puticles of unknown chstge) of unknown energy 20 E=eD+bO8 Thermalneutrons 2J where E denotes the effect,D the dese. 2nd.: and b are Committed Cose Equivaient constants.The quadratic term (bD )in this expression 8*
"** I""* Y *
- Another quantity used in the ICRP recommenda.
I}*"
tions is the "committsd dose equivalent," Hs o. to a g!ven organ or tissue from asingle intake of radioactive E " **"* " ' " *"
material into the body. This qusntity, which may be a rate an Mued. hugh a nMm.. a. S i
considered to be a special case of dese equiv:!snt
" * * * *Y l
commitment, is the dose equivalent that will be
' P* #*** "" **
- Y acmamuisted over 50 yes:s, represen:ing a working life, bservation to another.
g fo 6d h For human populattorts in particular, knowledge of d"*"**P " #*U "* HIP
- U *
""d *
'"*d' Hs e = ['e' $(tJdt confident predictica of the shapes and slopes of the where H/t)is the relevsnt dose-equivalent rate and to is a uw instances de nsk mbaus c n be based on de the time ofintake.
results of irradiation of human populations involving single absorbed doses, of the order of 0.5 Gy or lesa. or Y' " * "'
DOSE-RESPONSE RELATIONSHIPS In these esses it can be ressonably :ssumed that the The relationship between the dose received by an frequency per unit absorbed dose of particulst harmful Individual and any particular biologies! elTect induced effects resulting from such exposures is not :ike!y to by irradiation is a complex matter en which much overestimate 3:estly the frequency of such effects in further work is needed. For rad!ation protection de dose =nge of concern in radiation protection. even purposes, it is necessary to make cartsin simplifying though the latter may be received at much tower dess assumptions. One such basic assumption underlying the rates.
ICRP recommendations is that, regarding stochastic In many instances, howewr, risk estimates depend effects, there is, within the range of exposure condi.
on data derived from irradiationinvolving higher doses tions usually encountered in tsd!ation work, a linest delivered at high dose rates. In these cases,it may be relatiomhip without threshold between dose and the appropriate to reduce these estimates by a factor to probability of an effect. The simple summstion of s!!aw for the probable difference in nsk. The risk doses received by a assue or organ as a measure of the factors disetssed later have derefore been :hosen as total :isk and the calculation of de collective dose equivalent as an index of the total detnment to a population are valid only on the basis of this assump.
'!IT = IInear enersr transter.
tion and that de severity of each type of afrect is fI srsy (Cy) = 1 ns' (= 100 ruds).
- At high doses mis expression would have to be modined independent of dese.
- " W The added risk from a IIven dose increment wG stsanzation. This effect is not n;:inssat at me deses depend on de slope of the dese-re:ponse reistionship.
.3,,,3,,,4 :n.wr nd ex;cture canditicas. (Hewever, see ee If de dose-response relationship for stochastic pro.
Escussion or hot spots under 54niccant Volurnes :nd Ams.)
NUCJAA SAFETY, vos. 20. No. 2, Yav-JuM M9 e
-w w
"~
~
Atfachment B"
'~
- O J4 ENVIRONMENTAt. EFFICT3 a
.J far as possible to apply in practice for the purposes of most unlikely to cause any impairment of orgsn t
j radiation protection.
functica.
1 The ine of linear extrapolations, from the fre-For exposune ot the skin. either to external sources quency of effects obsernd at higis doses, leads to an or as a result of skin contamination, it is not geners!!y c,verestimate of the tsdistion risks, which in tum could appropriate to avetsge the dose equivalent over the result in the choice of alternatives that are more entire skfn.
hazardous dan practices involving radiation exposures.
Thus, in the choice of siternative practices, radiation Rate of Dose Assumulation tisk estimates should be used only with great caution The ICRP be5 eves that it is suffiefent to set annual and with explicit recognition of te possibaity that the dose. equivalent limits sad does not recommend any actual risk at low doses may be lower 621. that implied further restrictices either on the instantaneous rate or by a deliberately cautious assumption of propor-on the rate at wisich the dese equivalent =sy' be '
y
- donaHty, accumulated, czeept in the case of occupatiens!
exposure of women of reproductive espacity and
[
IMPLICATIONS OF ASSI'MPTIONS pregnant women.
t ABOUT DOSE-RESPONSE RELATIONS Ni T!SSUES AT RISK uj Significant Volumes and Areas
?"E** # "
" ? " ** "'
From the assumption about the proportions!! y
- "**'I " 'E**"I * **" "
"I*"'
- between dose and response, it would fcIlow dat for that have to be considered because
~
r suscepti-stochastic effects it would be justifiable to consider de btHy m radadon damage, de seriousness d mch mean dose
- over si! cens of uniform ;ensitivity in a damsge, and me extet m wkh this M W particu!st tissue or argan. This use of the mean dose tnatah has practical advantages in dat the signifi snt volume Some of the quantitative nsk (sctors are.learly can ususSy be tak:n as that of the organ or tissus age. a seq &nt, as fu usmpk tese fm me under :ensideration.
denlopmmt d mm esngu a (w the teduction W L
When the insdiation of a tissue is nonhemoge-hendtary defecu. In adetion, de nsk fan tu de neous, the use of the mesa dose over the tissue ceases d m6gnska m mduud m cy oc:une.we to be strictly valid if doses to individu:1 cells differ puses because of de long latut puiods 'mvobed us more widely than the range,of doses over which the the development of these etTects. For these ressens the dose-response reisticeship for the tissue can be mtal m fmm sn m dual expcswe wiu vay regarded as linear. An example of this may be the somewhat with sge and with sex. 21though in fac: de irradiation of the lung by radicactive particulates.
udades fmm the sursge value fw 23 sgu and both However, on the basis of theoretical consideraticas and sms m not ens derable. nus fa pmmden pw.
1 of available epidemiological evidence, the ICR? be.
p ses su ficient sc uracy is btained by using a single lieves that, for late stochastic effects, the absorsuon of doseequivalent limit for each orgsn or tissue for all a
a given quantity of radiation energy is ordiner v likely
- " "I*
- I'"****
- I"'
- to be less effective when due to a series of" hot spots" m dkased unda ne bmm d Dose hauca, than when uniformly distnbuted because of the etTect
"E'i"*N*M{*"
md MaMe 1 u m ase e anrste n
of high doses in causing the loss of reproductive
'h' " N " * "I*"' " *I**"*
capacity or de death of caus. Thus, with particulate
- I" "* E""
radioactive sources within a tissue, to assess the ruk by I*** *
- mnt maes m ased u
'i assuming a homogenecus dose distribution would "I
'5 probably overestimste the actual risk..\\toreover, for dem, nasmchmk changu a mbstandal guck nonstochsstic etTects the limited smount of ceil loss de ecu aprene in u n a n neendants. It is neog-that might result at moderate dose levels would be nized that the sppropriste basis for quantifying detri.
9
~
ment should inchde the evalustion of su other for.s of hurt and sui'mng that m:y result front exposure.
't niss spennedy qudded *.!te term "dese equinient.
This prob!cm :s te subject of a tssk gmup report being refers to ce :nesa sose equinient over cs ennte orpa or prepared for 1e ICRP. It sppests likeay that $4 fctms dssue.
1 NUCt.!AM SMETY. Vol. 2o. No. 3. May-June 19I9 1
_a.
.2_*..
~.
325 ENVIRONMENTAL. IFFECTS Table ! Hisk Factors for Radistf ois ores-and tissues at the !evels of dose normally Protection Purposes encountered in rsdistion work. The evidence for life shortening from e(Tects other than tumcr induction f****'-
!s inconclusive and cannot be used quantitatively.
Moreover, it seems unlikely that say major hazard from irradiation at recommended leve!s bas been Goemds 10 ' Heredhary in health withis f'
amt two semeradone overlooked, 23 judged by the evidence from heavily Red teen marrow 2 s 10 " Leukemia mortaury irradiated populations, observed for periods up to 30 Bone 5s10~* be cancer mortality years.
Lees 2 m 10' Li.as cancer mortality Thyroid 5 x 10' Dyroid cancer mortality 3reast 2.5 a 10' Breast cancer mortancy THE SYSTEM OF DCSE LIMITATICN An other tissue 5 x 10' cancer mo'rtsSty l
Any other slagte -
act x 10' Cancee mortrtity The ICRP recommend: a system of dose Ilmitation, 18"**
the main purposes of which are to ensure (I) that no Uniform whole-body 10 " Cancer mortality source of exposure is uni'"*tified in relatiert to its in-dianos benefits or those of any av:ilable altemstive,(0) that Uniform whole body 4 s 10 " Hmditary errecu of thin any necessary exposures are kept as low as is reason.
Irradiation first two senerations Umform whole-body S s 10' Hereditary effecu la sA ably achievable.(3) that the dese equivalents received inadiation subsequent senerations do not exceed certain spec:fied tinuts. 2nd (4) that i
allowance is made for future deve!cpment.
I It may thus he necessary to mne subjective value of detriment mentioned abne wculd be regstded as judgments in order to compare de rdstive Ltportsece of the costs imposed en human hesid by rsdistion the dominant compocents ot de harm which may be exposure with other ecenemic and social factors. In
~
caused by rsdistion and those on whi:h nsk factors this respect, mdistion is not unique, :nd the same should most appropriately be based.
statement could be made in respect to a num:er of other sgents to which msnknd is expcsed.
l Children and Fetuses Exposure before birth or during childhood may cose Equivalent t.imits: General interfere with subsequent $rowth and development, The total absorbc3 dese rate in mest human tissues' depending en such factors as d:se and age at irradia.
l tion. Susceptibility to the indu.: tion of certain malig.
from naturs! rsdiation is about ene-theusandth of a nancies aho appears to be higher during the prenats!
gray per year, but absorbed dese rates up to ene-l and childhood periods than dunng sdult life.
hundredth of a gray per yest or more have been reported frem certainlimited aress of the wedd.
l Man-made modifiestions of de envtronment and Tissues of Low Sensitivity man's activities can incre:se the "ncr=s!" expcsure to It.a now established that there are van.ous tissues, natuM stka. WW of $is d'de enig such as muscle and adipose tissue, in which the f!!ght at hi5h altitudes, and the use of building development of malignancy following irradiatica seems
& con stuMly ng rad 6M*n to be very rare, as evidenced by the fact that nuc!! des. Sen living within a house is often suf!!cient spidemiclegical surveys have so far not showrt excess m in adfah gsum Wm wh ve 4 rates of malignancy in such tissues. For these tissues, lation tenc: to lead to an secumuistion of radioscuve dose limitation is based on the possibility of vascular or gases and their decay products, other deleterious changes. There may also be some In radiation protection the Commission's recom-tissues, for example, those centsining nonnucie:ted mended dese equivalent limits have act been regsrded cells, the irradistica of which can be ignored for the as applying to, or including, the " normal" levels of purpose of radiation protection.
natural radiation, but only as being cencemed with those ecmponents of nstursi r:distica that resuit from =:n-made :ctivities or in speci:1 ::viron=ents.
Cther than the specific effec.s alre:dy disc.:ssed.
Moreover, it scu!d be emph:si: d ist. On de there is no good evidence ofimp:ir.nent ci functica cf premise $:t the frequency :( c:distica effe:ts is Nue:.zAn smTv. voi. :o. No. i vo-u. isn
+.
- ~-
w.
Attachment;...B.. __._...
a 336 INVIRONr.tmTAt, EngCTS 7
linearly proportionsi to the dose teceiwd. s aci, harm as life in many industrics and to be associated with sn may be caused by natural radiation couk be tersrded approximately equal tots! Ioss of wurking time from as independent of, and simply additne io, the amount -
industrial accidents. A fatal ms!!gnancy induced by of harm that may be caused by any of the man made occupstional exposure to radiation.muld he expected
?
practicet involving radiation exposure to which tb9 to involw the toss of about to years oflife, owing to Commission's Emiu apply. la this sense, regie. sal the long latency in the development of such a variations la natural radiation are regarded as inve'.ving condition, without spprecisbh associated time loss -
j a corresponding variatio s in detriment in the ssr a way from accidents, j
as, for example, regions! variations in meteorological In many cases c' occupational exposure where the
- conditions or volcanic sctivity involve differences in Commission's sywe.n of dose !!miution has been the risk of harm in different stess. On this basis, there applied. the resultant annual aurzge dose equivsfent is is no reason why differences in natural redistion should no greater than one-tenth of the annual limit.'
af'act acceptsbie lewis of man-msde exposure, any Thmiore the application of a dose equivalext limit rnore than differences in other natural risks shocid do.
provides much better protection for the average worker in the group than that corresponding to the !H.For example, in the esse of uniform exposure of the whole Medical Exposures of Patients and body, in circumstances where de ICRP's recommenda.
Dose dnuivalent Umits' tions, including the annual dese-equivalent limit of 50 mdical exposure is, in geners!, subject to most of mSv, have been applied, the distribution of the annus!
the ICRP's system of dose limitation, that is,unneces*
dose equivslents in large occupational peups has been sary exposures should be avoided: necessary expesures shown very commonly to tit a lotnormal function.
should be justii' table In terms of benents tat weu!d with an arithmatic mean of shout 5 mSv and with very not otherwise have ban receivedt and the doses few values spproaching the limit. The applicarica of actusHy administered should be limited to the mini-the risk factors given in Table I to the above mean mum amount consistent with the medics! benefit to dose indicates ist de sverage risk in these radiation the individual patient. The individual recei.ing de occupations is er sparsble with the average risa in
,f exposure is himself the direct recipient of the benerlt other safeindust resulting from the procedure. For this reason it is not Ruommen& ese@uimlent Limin. The ICRP i,'-
appropriate to apply tne quantitative values of the recommendations given in Table 2 are intended to Comrmssion's recommended dose equivalent Ilmits to prennt nonstochastic effects and to limit the oc:ur.
medical exposures. With certain medi:s! exposures, a unce of stochasde etTects to an acceptsble ImL De very much higher level of risk may in fact be justified Comnussion be!! eves that nonstochastic effects will be by the benefit derived thsn by the Icvel Judged by the prennted by applying a dose equivalent limit of 0.5 Sv
. ICRf t'o bi appropriate for occupations; expesure or (50 nms) in a year to aH tissues except the tens, for for exposure of members of the public.
which the Commusion recommends a limit of 0.3 Sr Dose Equivalent Umits for Workers Table 2 Recommended Annual Dose Equivalent R
The ICRP belleves that for the foreseeable future a Umits T
valid method for judging the acceptability of the tevel
(
of risk in radiation work is by companns this risk with thst for other occupstions recognized as having high Gmie Applicacios Tissue or organ standards of safety, which are geners!!y considered to
- 1 be those in which the aversge annual mortailty due to 0.5 Sv (30 : ms)
Workers Au tissue except
!*88of*Y' occupational hazards does not exceed 10-' (Ref. 3).
0.3 Sv 00 rems) vorkers I.ans of eye
~
]
The Commu ion beh. eves that the esiculated rate at 50 msv(3 rems) worken t niform trradiscon s
which fatal malignsacies might be induced by occups-of schole body
- i 4
tional exposure to radiation should not in any essa 5 m3,(0.5 remQ fndMdusi memeen Mote body 1
2xceed the occupational fatality rate cf industr'es 50 a5v (3 remsy of :he public Any one or, n or recognized as having high standstds of1siety.
It should be mentiened that sn scaidents! dssth ey, appests to involve an sversge lots ot about 30 years of NUCt.IAn sA7 TTY Vef. :o. No. 3. Mav=Jurie le79 1
9
s 337 (N%tRCNMENTAL EPPECTS (30 rems) in a year, as Indicated in Table 2. These, Occupational E.rponuv of ILbmen a/Reproduerire li' nits apply irrespective of whether the tissues are Crpeerty. When women of reproductive capacity are exposed singly or together with other organs, and they occupationally exposed under the recommended !!mits are intended to constram any exposure that fulnits the and when this exposure is received at an pproximately limitation of stochastic effects.
regular rate, it is unlikely thr. any eminyo could For stochastic effects the ICRP's recommended receive more than 5 mSv during the tirst 2 months of Jose limitation is based on the principle that the ask pregnancy. Ifaving regard to the cftcumstances in should be equal whether the whole body is irradiatert which such exposures could occur, the ICRP boileves uniformly or whether there is nonuniform tradiation that this procedure wil provide appropriate protection This condition will be met if during the essential period of org:nogenesis.
O"**#"*5
'A##" #I II"#"' W#"'"' f' i'
[ WyM 4Nwb.L likely that any pregnancy of more than 2 months' j
T I
T duration would have been reccgnized by the woman where Wr is a weighting factor representing the herself or by a physician. The ICRP recommends dat, proportion of the stochastic risk resulting from the when pregnancy has been dia6 nosed, strangements l
t Irradiation of tissue (TJ to the total risk when th, should be made to ensme that the woman can cenrinus whole body is irradiated uniformly: # is the annus to work only where it is most unlikely that the annual 7
does equivalent in tissue (TJ; and #w6.4 i'. (a, exposures wir exceed three4 ends of the dose-recommended annual dose.equivslent limit for uniform Irradiation of the whole body, e.,!0 mSv(5 rems).
equivalent !!mits.
Dose Equivalent L*mits for indirhal 3fembers of the Pubile. Radiation risks are s very mmer fraction of Table 3 Tissue Weighting Factors the total number of envitertmental hszards to which Tissue Weishunsfactae(W f members of de public are exposed. Thus it stems T
reasonable to consider the magnitude of r:distion nsks to the general public in the Ugat of the pubi!c acceptance of other risks of everyday life.
Red w -
0.n Laes 0.12 An example of such risks is that of using puclic Thyroid 0.03 transport. From a review of avsilable infor=stion related to risks regularly accepted in everyday life,it 0
can be conchaded that the level of acceptab:lity (cr fatal risks to the general public is an order of magnitude lower dan for occupstional esks. On this basis a risk in the range of 10-* to 10-8 per yest t
The' values of WT recommended by the ICRP are would be likely to be accept. ble to any individual 7 or de remauung f
given in Tabis 3. The value of W member of the public.
tissues requires further clarification. The Commission The assumption of a total risk of de crder of 10-2 currently recommends that a value of W = 0.06 is 7
applicable to each of the five organs or tasues of the Sv'8 (Table !) would imply the restziction of the remamder receiving the highest dose equivalents and
'ifetime dose 's the individual member of the public to that the exposure of an other remaining tissues can be a value that would correspond to I mSe per year of l
l neglected. (Men the gsstrointestinal tract is irradiated, lifelong whole body exposure. Beesuse the appliestion l
the stomach, small intestine, upper !stge intestine, and of an annual dose equiv: lent !imit of 5 mSv u lower large intestine are treated :s four separate individual members of the pubi!c is likely to result in average dose equivslents ofless than 0.5 mSv, provided organs.)
that the practices exposing the public are few and Although the ICRP no longer proposes separate annual doss equivalent !!mits for individual tissues sad cause !!ttle exposure outside de critical groups, de organa irradiated singly, the implied values of such ICRP's recommended whole body dese-equivslent limit limits can be obtained, if required. by dividing the of 5 mSv (0.$ rem) in a year as :pplied to c:itiest dess equivalent limit by de re!cvsnt value of W. S.ach peups. hss been (cund to provide this deg:s of safery, 7
values. would be subject to de 3rmts, based on and de Comr ission reccmmends its cendtued uss nosstochastic e!Tects, given in T.:ble 2.
under the conditions specified in IC.RP?ubliest:cn 25.
NUCLIAn sASETY. Vos. so. No. a. May-June f 979 i
l e
g
'J
' -e.
N I.
6-e.
g.
Tf-w-
gai we--
wwqe9.-*-p-y-mew.-w-'r-m--g--
vt-~we
-gwvw mie---v,-ya-,.-mewwyse aymm-q-w me w weerw,.s erws.e-i-ve.srey.-
an sww-*
a-ere
-"-"F
'~
's ENVIRCNMENTAl. EFFECTS i
s33 in the calculation of the dose equivalent incurred of the casu of the secfdent and of remedial action,
-i by meinbers of the public from intske of radionue!! des, levels below which it vould not be appropriate to take account must be tsken of differences in orgsa size or action. The Commissioc's recommended timits are set metsbolic chstecterstics of children. Data on such at a tevel that is thoughs to be associated with a low
. differences are in the report of the task group on degree of risk; thus, unless Ilmit were to be exceeded Reference Man //CRPPubEcstion 2JJ.
by a considerable amount, the risk would still be As with workers, an increase in the average dose to sufficiently low as not to warrant such counter.
members of the public could result from any 1stge measures as would themselves lavolw significant risks increase in the number of sources of exposure, even or todue cost. It is therefore clear that it is not though each sausfactordy met the criteria of justifica-obligatory to take remedial action if a dose.equivsfent tion and optimization sad caused no exposures above
!!mit. has been or might be exceeded.
the recommended !!rmts. Nations! and re5 onal autheit.
i ties should therefore keep under survei!!ance de separate contributions from 20 penetices to the aversie GENERAL PRINCIPLES OF exposure of the whole population so as to ensure that OPERATIONAL RADIATION PROTECTION no singe source or practice contributes an unjustifled ResponsibEties (a sc.%g appropnate tsdadon
- amount to de total exposure and that no individua!
prctection fall or the employers, de ststutory com-reesives undue exposure as a result of membership in a pount aden, de man &m and W nen d number of critical groups.
producu giving rise to r:distica exposure, and in some
- d N"*
Ea,3osure of Populations institution must ptovide 21! the necessary factilties for i
In. these recommendations the ICRP does not the safe conduct of the operations under its control. In propose dose !! min for populations. Instead, the particular, it should designate penons with special Commissica wishes to emphasize that each man made duties for protection, such as members of rsdistion contribution to population exposure has to be justified protecuen teams.
by its benefits, and that !!mits for individual membes It is important to distinguish between distfact of the pub!!c refer to the total dose equivalent received types of protection standards, Le., basic limits (dose-from 28 sources (except as already noted). The limit equivalent limas and seconday '.imits), denved limits, for Irradiation of a whole population is thus c!carlY suthortzed limits, and reference leve!s.
seen as the total re:ched by a summation of minimum necessary contributions and not as a permissible tots!
1.imits apparently avail:ble for apportientnent. Thus the g
g y
gg Commasion,s system of dose !!mitation :s likeiy to equi alent, w, whus appr pnate. to de committed ensure that the awrage dose equivalent :o the popula.
dose eq*alent, in de agans a dssues oMedy d tion wi!! not exceed 0.5 mSv per year.
an individual or, in de esse of exposure of the population, to the aversge of one of these quantities g
g g
over a group ofindiv du21s.
Under conditions in which accidental exposures Secondary limits are given for extem:1 irradiation occur, questions arise as to what remedial actions may and for Internal irradiation. In the esse of extemal be avadable to limit the subsequent dese. la such esses irradiation of de whole body, the seccedary I!=it the hazard or social cost involved in any remedial applies to the maximum dose equivalent in the body at measure must be justified by the reductiers of risk that depths below I em. The second:ry limits for intemal wi!! result. Because of the great variability of the exposure are de annuallimits of intake by inh 21: tion circumstsaces in which remedial action might be or ingestion.
considered, it is not possible for te ICRP to recom.
In practical radiation protection it is often neces.
mend " intervention levels that weald be appropriate sary to provide timits which are associsted with for all occasions. The setting of such tevels for quantities other th:n dose equiv: lent. committed dese particular circumstsnees is considered to be the equivaient, or intake, and which re!ste, for example, to responsibility of te nation:1 sudenties. Wwever.
environments! conditions. When des: (!=its are reisted with sert:in types of se:ident th:t are to scr:e extent to de basi:limus by a detined meal of the situst::n
?
foreseesble, it m:y be possible to gauge, by an sn:iysis and tre intended to reflect the 5: sic IImits, dey :::
NUCt.KAn sAPETY. Vol to No s. Mav=hne 1973
4 239 ENVIRCN!.tENTAL EPPECTS called derived limits. Derived limits can be set for such
- 2. Workng Condition & This describes conditions quamities as doss equivalent rate in a workpi:ce, where it is most unlikely nat the annual exposures wt!!
contamination of air, contaraination of surfaces and exceed three4enths ot the dose. equivalent limits.
contamination of environmental materials. The ac.
'*I"'
curacy of the link between derived and basic limits occupational exposure. thus a reference level used in is depends on the realism W 4e model und in te the organiastion of protectientit !s not a limit.
- dMuda, main ami e deGnidon d yng Cadi-Limits laid down by a competent authority or by ha A is to ensm dat worhn who aght odmus the management of an institution are caHed surhon=ed reach or exceed the dose-equivalcat limits are subject Ihnicr. In general such Umits should be below derived l-
'dt' des, although, exceptionaHy, toy may be equal to restricted if necessary. In Working Condition
"* * "N 8 ** * * " # "# ***
- s.
them. Where an authorized !!mit exists, it will always Mdus! monkoring is ut nasary. dt.5ougn it may take precedence over a derived 3mit.
sometimes be carried out as a method c,conSrm: tion that conditions are satis (:ctory.
i y
The practical application ef this system of classi.
Referoce levels can be established for any of the fication of worldng :oaditiens is greatly simp!! Sed by l-quantitics determined in the course of radiation protec-introducing a corresponding system ofdassiScation of
_ tion programs, whether or not there are limiu or dess workplaces. The minimum requirement is to denne f
quantities. A reference levelis not a lindt and is used to contrciled areas where centinued oper: tion would give determine a course of action when the value of a rise to Working Condition A and to which ac:ess is j
quantity exces,is or is predicted to exceed 24 refer-Umited.
ence level. The most common fctms of reference leveis It is sometime: convenient to specify a further dass are recording !avels, inv-stigation levels, and interven-of workplace. It is called a"su;emsed ares ** and has a tion!avels, boundary chosca so as to make it most unlikely that the annual dose equivalents outside the supervised at:2
- E "*"d * *"* #'h' h
- APPt.! CATION TO There is u
- cme par He! ism betwun de dassin.
I' OCCUPATIONAL EXPCSURE canon of areas and the dassincation of woricng
)
The-main responsrcility for the protectiott of conditions, because the c!:ssincation of areas takes no workers rests with the no: mal chain of management !n ac: cunt of the time spent by workers in :he :res an institution possesting any radiation source dat during the course of the year and because conditions causes exposure of workers. It is necessary to identify are rarely uniform throughout an area.
technicaHy competent penons to provide advi:e on sil Individual workers tre usually classided to simpilfy relevant aspects of radiation protection. both inside de arrangements for medical supervision and fer and outside the institution, and to provide such individual monitoring. In principle. this can be done in technical services as are needed in applying appropriati tetms of the class of working condittons in which they recommendations for radiation protection.
operate, but in practice it almost always must be done in terms of the areas where they work, the type of Condidene of Work work doce, and the time to be spent in the area.if this can be forecast with s.afficient teilability.
for the purposes of this article, occupational exposure comprises 211 de dose equivalents and intakes
%% g g y g,,,,
l incurred by a worker during periods of work (exclud.
ing those due to medical and natural radistica). The As far as is reasonably pr:cticable. the arrange.
l scale and form of the proble:ns of radiation protectica ments for retttfeting occupational expcsure should be of workers vary over very wide ranges, and there are those applied to the source of adiation :nd to features practical advantages in introducing a system of dassi.
of the workplace. In gener:1. the use of jaersen:1 fication of conditions of work.Ccaditions of work can protective equipment should be supplement:ty to be divided into two dassest dese more fundmental provisions. The emph: sis 1.WorWng Condition A. TMs desenbes cend!: lens shcu!d dus be on intrinsic safety in de workpf:ce :nd where de annual exposures might en:eed $ree<enths only see:ndartly en prete: icn 1:: sepends cn the worker's own 2:!!Cns.
of the dose equiv: lent lim 2ts, l
NUCLEM SA7ETY. Vos. ;o, No a. Vay4.ee 1979 f
T.,
Attachrr:ent S
~i 380 mvlAcumut, specTs
}
- )
,1
' Since there is no ICRP recommendation on individ.
estimate should be made of the average dose equivalent J
over 1 cm in the repon ci the highest dose eqt.ivslent.
8 d
ual monitoring in Working Condition B (Ls., where it is d
most unlikely that the exposure will ex:eed three-This dose equivdent should then be compared with the tenths of the :ppropriate dose equiv:!ent, secondary or doseequiv !cnt limit. If the dose distnbution is ex.
denved !!mits), it is often appropriate to use this figure tremely nonuniform, as is that from very tmail of three tenths la setting invas:igation levels for Indl.
particles in contact with the skin, the local distnbution vidual monitoring. However, for an investigation level of absorbed dose should be assessed and used to to be useful, it should be set in reistion to a single predict possible local skin reacticas. !t is inappropriat:,
./
measurement, not the ac:umu!sted dcse equivalent or however, to reiste such hedized absorbec doses to the intake in a year. In addition. the investigation level absorbed doses corresponding to the dosa equivalent l
shesuld be based on the fractiors of three-tenths of the
!!mit.
limit corresponding to de fr:ction of a year to which the individual monitoring messurement refen. The Medical surveittance monitoring is associated with a single event, although g,g
.H d mW md to
,,,j not necessa:ily a unique one, and the chcice of an dh is bd a d4 W MW d q>
investigation level depends on the expectation of the gg gg ggg g -
number of oc::siens on which simJar events will occur
"""U
.r
.* j during the year. In ICRP bblication 10 the ICRP U""* I " *E * *
- 7 O
- recommends dat the investig: tion level should corre.
workers and the conditions of ietr work, and (3) to spond to one twentieth of the annual dese equivalent provide a base!m.e ofinformatica ussfd in de case of limits,if it is assumed 6st events requiring a program sceidental exposare or oc:upational i.sease.
of special momtcring may oc:ur in reistien to a single Workers designsted as eperating in Working Cendl.
individust about six times in s yest.
"^*
- *E'"E*" "*
Although investig: tion levels are suitable for initiat.
examination before starting this kind of work.
ing investigations into specific situations, it may be M
a dde convenient to record dose equivalents at somewnst g
ggg,g
.a lower levels. The ICRP cecommends that se recordng ha d'h hdd h'm levels should be based on an annual dose equiv: lent or N ICRP WM &A d 'h mt dm.
]
intake of one. tenth of the annual dese equiv2, lent limit g
p or intake limit.
is appropriate for worken :s far as radiation nsks are For the special case of monitoring of skin. tw concerned. In particular, no specisi art:ngement is situations oc:ur in routine practice. In one si'uauen, esquired with respect to working houn and length of for external radiation, a dcse equivalent is measured by y,g
]
one or two dosimeten, and de results are treated as representative of the whole skin or of substanttal areas interventionin Abnormal Situations of the skin. No problem of averaging ten 2nses and the results are related directly to de relevant dese.
Arnngements should be made for des!!ng with 2bacrmal situations, not ortly with respect to their equivaant limit. In the other situation the irradiativa detection and de :ssessment of dose orintake but z!so j-results frem surface cents:nination on the skin. Surface f
contamination is never uniform and oc:un preferen.
- 1th respect to the form of!ntervention that may have tially on certain parts of the body,chietly the hands.
to be :ppil.d. The intervention leve!s and the so-I w
However, surfsce skin contamination does not persist propriate actions for limiting expesure thould be $e suoject of openting instructicas. Prov:sica shculd be j"
over many weeks :nd does not always occur agam at l
-i exactly the same places. For routine purposes it is made for special medic:1 surydhnee and,1f necessary, I
treatment following exposure substantidly in excess of adequate to regard the contamination as being avenged over areas of 2 bout 100 cm. Routine =enitoring for de doss equiv2!ent !!mits.
2 l
skin contaminstion should derefere be interpreted on this b: sis :nd de limit appiled to the aversge dese APol.!CATICN TO OTHER EXPCStJRES
,equiv2!cnt over ICO cmt in se:idents or susp-t:d :c:i:icnts, mere det:iIed The various :entributier:s to other expcsures may l
infor=: tion should be sought on de distr:bution of he grouped in:o bread :::egst:es to which the praerd I
l absorbed dese, dese equiv:!cnt. cr centsrmnstion. An principles of protection may apply but whi:h :211 for Nuct.An suffr. voi. 20. no. 3. vav-we 1s79
..a
~
.m
_..,,m.
m.
m,y,
___.y.__r.
-.,.,-y y
.w--,g-.-.v
i set gNVIRCNMENTAL EFFECTS b
different technical approaches.These estegories are(1) la some esses it is also useful to sisess the exposure due to the dispersion in the environment of doss equivalent comnutment or the collective dose.
radioactivmaterialst (2) direct exposure to rsdistion equivalent commitment.
sources used in industry, medictne. sad researcht (3)
These assessments require the use of models of i
exposure resulting from the use in everyday life of vanous degrees of complexity, representing the move.
I widely distabuted products containing sources of ment of radioactive materials through the environment ionizing radiation;(4) exposure to natural sources of from the source to man. These models have to take radiation and to practices in everydsy life that cause an into account the nature and the physical and chemical increase in the level of Jose resulting from the natural forms of the radioactive m:terists together with their j
background of radiation; sad (5) exposure due to the methods of release.The mode!s then have to retlect the use of radiation sources in test.hing.
characteristics of the emironment and of man whi.6 Influence the consequent exposure of individuals and
- l l
Amassment of Exposures groups. To make such models detsited and realistic requires extremely complex studiss involving a con-
~
Appi! cation of the sy* tem of dose !!mitation to any siderable etTort, and it is reasonable in practice to practice involvmg such exposures tsquires assessment adjust de magnitude of dis effort to de knport.nce -
of both the individual dose equivalents and the f de particular problem.*
collective dose equivalents. For the purpose of::mpar.
Ing individual dose equivalents with de :ppropriate i
Emits, the doses from the normal natural rsdistion REi ERENCES background are not included.
- 1. sternstional Commasion on R:distion tatu and Ste:sure.
The dose equivalent to a specified orgsn of tissue in
- ments. Radiation Gudnfifre! Jnd C'mtr. ICRU Report 19.
3-a given popu!stion group will usually be determined on 3.ashinsten. D. C July.1971.
the basts of a representsuve sample. The seresd of the
- 2. Inter anonal Cammission on R:dianon truts and >tessure.
observed values will be an indication of the homogene.
ments. Dose E4uhelent. ICRU Report 19duppt.). 4'sstur.c toa. 1 C 3*Pt I.1973-ity of the sample, and thus of the group, sed will
- 3. Internauonal comaussen on Radtstaccal Protection.h:3 provide a ststistical buis for judging whoder de group lems involved in Cereiopirig an indez af Harvn in 7tsinra-has been suitably defined.
g 11is often possible to identify population groups
- a. United Nanons 5.:tenufle Committee on he Effecs oi with characteristics causing dem to be expcsed si a Atomic Radianon. 5tedicalIrt:dfanon. Aanes F o(Iourers
^"d Effec *r of tona:ar Radianon-197* Recorr :o due highet level than the rest of the exposed population C'"arel Assemoin Unated Nsuons. New York 19M.
from a given prsctice. The exposure of these smups.
known as criues! groups, san then be used u a measure of the upper limit of the individual doses resulting c:his topic is discusand in detas in a report beiris prepared from the proposed practice.
br ICRP Comtrmte 4.
l l
l l
NUCLEAM sA# STY Vol. o, No. 3 Wy-Me 1973 c.
.htt&Chment.S
..u i
g 3
x
~
o.
., v,.,
g s
s
/.
.n.....
c.
e
~
b
.d ENCLOSURE IV I
l I
O l
l l
r G
l I
r i
i O
f t
FIRST MINORITY OPIKON The comments prepared by the NRC staff on EPA's proposed guidance to Federal agencies contain two recomendations in which R. E. Alexander, Chief, Occupa-tional Health Standards Branch, Office of Standards Development, did not entirely agree.
First, the -coments request recasting of Section 4.i. of the proposed guidance in'a manner which would eliminate a proposed 100-rems lifetime dose limit and state instead that lifetime doses should be maintained ALARA and that workers should be instructed on the levels of risk from radiation.
It is Mr. Alexander's position that the EPA's proposal for a lifetime dose limit is too stringent, while the staff majority proposal is too lax.
Mr. Alexander believes that the Commission should recommend that the EPA establish a mandatory informed consent precedure which would involve considerably more than training workers on radia-tion risks, but which would not limit their opportunities to obtain and retain L
employment.
The informed consent procedure would consist of notifications to workers when their lifetime risk reached a pre-set value; the workers would l
then make their own decisions about accepting additional radiation risks.
Mr. Alexander believes this procedure to be more in keeping with the risk associated with continued annual radiation doses near the 5-rems per year limit.
His position is developed in more detail in Section I of this enclosure.
Second, the proposed comments to EPA request that subsection 5.b of the proposed EPA guidance be deleted.
This subsection states, essentially, that Federal agencies should not adopt concentration values for airborne radionuclides that
(
are less restrictive than those currently in use.
Deletion of this statement 1
Enclosure IV
l would leave the Commission free to allow higher radionuclide concentrations in air as-recommended by the ICRP.
It is Mr. Alexander's position (1) that.com-pliance with ICRP recommendations is not necessary in the United States and is undesirable to the extent that such compliance would result in less protection for workers, and (2) that the Federal government should not take action which would reduce the degree of protection currently being provided for workers when the only justification for such action is compliance with ICRP recommendations.
For these reasons Mr. Alexander proposes that subsection 5.b. of the proposed EPA guidance be accepted by the Commission.
His position is developed in more detail in Section II of this enclosure.
i 9
2 Enclosure IV g
e,y 4
r----w w - -
,w w
y
-*g
,--m,-
w-
-w g
m----
I.
RISK FROM EXTERNAL RADIATION SOURCES Summary The EPA has proposed a lifetima radiation dose limit of 100 rems to the whole body.
This constraint is described by the EPA as being necessary to limit the risk for those workers who are exposed on a long-term basis to annual doses near 5 rems per year.
The constraint could result in carser interference for affected workers--workers who could find difficulty in obtaining acceptable employment in nonradiation industries.
Therefore, it is proposed that each worker be allowed to decide for himself/herself whether or not to accept addi-tional risk after a limit such at 100 rems has been achieved.
Under this pro-pocal it would be necessary to establish a mandatory notification system to let affected workers know when the limit had been achieved, although no work j
restrictions would be imposed.
It is further proposed that a risk notification system be established rather than a dose notification system.
This approach l
l would permit consideration of the number of years of life at risk following an l
annual dose, an important factor which would be neglected by a dose system.
The approach would also permit consideration, with respect to cancer induction, of the age-dependent aspects of the dose /effect relationship.
Risk Notification Sy3 tem In relatively recent developments the ICRP and EPA have recommended or proposed 5 rems per year as the Ifmit for occupational radiation dose to the whole body.
However, both of these organizations take the position that a worker actually i
3 Enclosure IV
-m 4-w
+v e
,g-
,-,-_--c-
-y y-r-,
4 w
- a W
receiving 5 rems per year over a long period might incur a risk that would be considered high in relation to other' occupational risks.
The ICRP position is stated in paragraphs (101) and (102) of ICRP Publication 26:
" Exposures consistently near the Ifmits would be comparable with a situation where a higher-than-average risk has been identified for certain individuals in non-radiation industries."
"Long-continued exposure of a considerable proportion of.he workers at or near the dose-equivalent limits would only be accepcable if a careful cost-benefit analysis had shown the higher resultant risk would be justified."
The present EPA position appears on page 99 of the background report for their newly proposed guidance to Federal agencies (EPA 520/4-81-003):
"However, a worker who received the maximum allowed annual dose every year throughout a working lifetime could accumulate a lifetime risk higher than that of averace workers in the three highest risk major occupational categories not normally exposed to radiation--mining, quarrying, construction and agriculture."
The EPA position is predicated on the observation that a comparison between those maximally at risk in one industry, and those exposed to the average risk in another, is informative.
Unfortunately, risk data for workers maximally at risk in industries such as mining and quarrying have not become available.
l The EPA background report states on page 92 that:
l "The maximum lifetime risk of death from radiation-induced cancer allowed under the 1960 guide was estimated to fall between 3 and 6 in a hundred."
The 1960 guide established an average annual dose limit of 5 rems per year.
This risk estimate, which states that 3% to 6% of workers so exposed would die of radiation-induced cancer, was based on risk factors published in the 1972 BEIR report.
Using age-dependent risk factors published in the 1980 BEIR l
l 4
Enclosure IV l
1 report, the risk estimate for the incidence of radiation-induced cancer is 6.5 in a hundred for male workers exposed for a working lifetime at.the rate of 5 rems per year.
It is often assumed that one-half of such cancers would be fatal.
Thus, for the linear hypothesis, the two BEIR reports are in essen-tial agreement.
The ICRP bases the acceptability of its 5-rems per year ifmit on the fact that, i
as shown by experience, under this limit the mean (or average) annual dose is 4
near 0.5 rems per year, an acceptable level.
This position may be found in E
paragraph (100) of ICRP Publication 25:
"In the case of uniform exposure of the whole body, in circumstances where the Commission's recommendations, including the annual dose-equivalent limit of 50 mSv (5 rems), have been applied, the distri-bution of the annual dose eouivalents in large occupational groups has been shown very commonly to fit a log-normal function, with an
. arithmetic mean of about 5 mSv (0.5 rem), and with very few values approaching the limit.
The application of the risk factors given in paragraphs 40-60 to the above mean dose indicates that the average j
risk in these radiation occupations is comparable with the average risk in other safe industries..."
The position of the EPA, which may be found on pages 97 and 94 of the background l
l L
report, is similar:
l l
"... based on experience for the past 15 years, the risk of death from radiation induced cancer for the average worker is low in comparison with risks of accidental death in other occupations.
For this reason we do not find it necessary or justified to lower the whole-body Radiation Protection Guide below 5 rem to provide greater protection from radiation-induced fatal cancer to the work force, taken as a whole."
Thus, it is concluded that both the ICRP and' EPA accept the 5-rems-per year 1'
. limit on the rationale that experience with the limit has indicated *an accept-able degree of protection for the average worker, who receives only acout 10%
l of the limit.
Neither organizations endorses 5 rems per year as a limit pro-l l
l 5
Enclosure IV
- viding the desired degree of protection for workers exposed at that level for long periods of time.
In an effort to provide additional protection for the small group of workers who receive annual doses considerably above the average (e.g., some nuclear power plant transient workers and some medical workers),-the EPA is proposing a lifetime dose limit:
4 T
"...in order to achieve the objective of limiting maximum lifetime risks to a value comparable to_ average risks from other occupational hazards, a two-to' three-fold reduction of the max'mus lifetime dose permitted by an RPG of five rems per year is required."
1 According to the EPA proposal, this objective is to be achieved through manage-ment of individual worker dose accumulation in a manner avoiding lifetime doses greater than 100 rems.
Although the overall objective of lowering the risk for highly exposed workers is necessary and should be achieved, several dis-advantages are associated with the EPA proposal.
Among these the following three are outstanding:
(1) The recordkeeping burden; (2) Potential career interference (which could occur at a particularly disrupting time in life); and (3) Control of dose rather than risk.
In the following discussion an alternative approach to meeting the objective is proposed; this approach would remove the final two disadvantages.
It should be noted that EPA would recommend this degree of reco'dkeeping for the small r
numcer of highly exposed workers whether a lifetime dose limit is imposed or not.
l 6
Enclosure IV
In attempting to achieve comparability in worker safety with other industries, it does not appear essential to eliminate completely exposures at the maximum lifetime level.
Mine safety regulations and procedures do not absolutely prevent all of the higher-risk tasks, such as prevention of If fetime doses greater than 100 rems would it.
However, it is believed that miners in general understand L
the risks they are taking, and accept the risks voluntarily on an informed basis for reascns of their own.
In operations invelving long-term radiation exposures near t'1e limits a comparable situation could be achieved by a system of notifi-cation.- Under such a system individual workers would receive a written notifi-cation from their employers at the time the lifetime dose (or risk, as discussed i
below) reached a predetermined accumulated level.
The notifications would explain the associated risk in. sufficient detail to permit an informed decision by the i
worker as to whether additional occupational exposure should be accepted.
i.
l A risk notification system of thi:, nature has the folicwing advantages:
1 (1) Those workers receiving an annual dose near 5 rems per year on a long term L
basis would not be subjectec to a sense of false security; l
l (2) The government would not terminate a worker's career in activities involving radiation exposure; (3) At the worker's own, informed option, work could be performed as usual until terminated by other causes such as retirement; (4) Workers would have the opportunity to make a change in their futur1!
(
occupational radiation exposure situation if they chose to do so; l
7 Enclosure IV
(5) No one would be incurring an accumulated risk greater than the preselected value withc9t knowing.it in advance; (6)
It is likely that affected workers would make an improved effort to avoid reaching the preselected level, since it would have a special significance for them;
. (7)
It is likely that many employers would be more willing to endure addsd costs for protection in order to avoid sending such notifications; and 4
(8) Workers with small accumulated risks would not be affected; only tne' higher-risk personnel would be notified.
l These advantages indicate that most of the desirable erfects of a Iffetime dose ifmit would be made available by the proposed risk notification system.
i.
l.
The risk notification system should employ a risk level rather than a dose level.
J The dose is only one component of the risk.
The other two components are the f
risk factor (cancers per rem par year) and the number of years at risk after the dose is received.
These three numbers may be multipited together to esti-mate the risk for the dose received during a given year.
The lifetime risk is obtained by adding all of the annual risks already incurred.
The ICRP has provided guidance regarding an acceptable, occupational lifetime l
l risk level.
In paragraph (96) of ICRP Publication 26.the following statement appears:
8 Enclosure IV
-, - - -. -... ~. -
-.,-...-..,...m-_.-
_,.-,..,,.-.m,-~., -. - - -,,, - -.. ~., - - -. -... -. -,,...,. -
-_..,-,,.-_,_____.___,.,,,_-....,m--,.
l
?
"The Commission believes that for the foreseeable future a valid method for judging the acceptability of the level of risk in radia-tion work is by comparing this risk with that for other occupations recognized as having high standards of safety, which are generally considered to be those in which the ave annual mortality due to occupational hazards does not exceed 10 If it is assumed that a person works in some industry for 50 years, and that
~4 the average annual risk associated with this work is 1 x 10
, the lifetime 3
~
accumulated risk would be the product of these numbers, i.e., 5 x 10 In other words, work in which 5 such people out of a thousand die as a result of their jobs is censidered to have a high standard of safety, sufficiently high 3
to use.as a standard of excellence for radiation work.
This number, 5 x 10 could be usec' as the notification level for those in radiation wo-k.
The radiation risk incurred by each worker during a year would be estimated at the end of the year.
This annual risk would be added to the annual risk for pre-vious years.
The r'sk from radioactive material deposited in the body would be included as well as the risk from external sources..As soon as the total reached 5 x 10-3 the worker would be notified.
The notice would state that, in accordance with currently accepted scientific opinion, the risk of radiation-induced cancer as caused by occupational exposures received during his/her entire working lifetime had reached a significant level.
The level would be described as sufficiently high that additional exposure could place the life-time risk in a category similar to that of occupations not considered to have high standards of safety.
A key question that arises is the notification age, i.e., under various condi-tions of exposure, at what age would'a worker be.iotified that the significant risk level (5 x 10~3) had been reaci.ad? The table be,1cw provides a few per-tinent answers obtained using age-dependent risk factors for cancer incidance from the 1980 SEIR report.
For this table it is assume that the workers are 9
Enclosure IV w
-e
+------%.%
w-.
.y-g gy3
,,,w--
,q--ge#..
-.- ---ii.,,
w-4
,,y y
y-.-.
p.e
--.w.
,,yy y
. exposed until age 65, that-they live to age 75 and that the risk factor is applicable to every year of life following the annual exposure.
The table presents the age at which workers would be notified if they received annual doses of 0.5, 1,,2, 3, or 5 rems.
Notification ages are shown for workers-who sta:t their radiation work at ages of 20, 30 or.40 years.
The table makes several significant points:
(1) For workers receiving'5 rems per year, the risk notification criterion (5 x 10-3).is reached very quickly, even for those wtio do not start until
~
age 40; (2)-.For. workers receiving 3. rems per year, the criterion would be reached in a relatively short period of time; (3) Workers receiving 2 rems per year or more would receive a notification if they continued their radiation work for as long as 10 years.
/
((4). Workers receiving i rem per year would not be likely to receive a notifica-tion unless they continued in radiation work for 18 years or more.
(5) Very few workers receiving the average annual dose (about 0.5 rem) would ever receive a notification.
i It appears that this risk notification system would provide ample opportunity for workers to evaluate their own risk status; it also appears that such a system j
is badly needed for those who receive annual doses near the 5 rems per year limit.
10 Enclosure IV
s NOTIFICATION /,G2 FOR VARIOUS CONDITIONS OF EXPOSURE 2 (years of age)
Average Annual Dose
. Starting.
(rems)
(years) 0.5 1
- 2. ___
3 5
4 20 55
. 38
'30 26' 23 30
> 75 48 40 36 33 40
> 75 58 50 46 43
- Male workers f
11 Enclosure IV Y
y
- T 1r8
- --M*
wsg 4--9. p gvw'a#
Tev'M'=N7 w
F= efP** W--Wk mege pNw'ytv-
--**N-vv-9-'whe-*~*4-'--N-w=-*e
~v~"
- " " * * ' ' * +
.D.--a--W-we-ev+v***-
---*-Jv'-
v'+* = - - -
='
II.
RISK FROM INTERNAL RADIATION SOURCES Summary The EPA has proposed new standards for protecting workers from airborne radio-active materials.
Some of these standards would allow higher concentrations in air,.but the EPA is recommending that Federal ager.cies continue to use present standards in these cases.
The EPA rationale is that present standards are acceptable to employers, and that, under such conditions, government agencies should not take action to reduce the degree of worker protection presently afforded.
It is proposed that the NRC accept this recommendation.
. Recommendations for NRC Position Using newly recommended calculational techniques (modified slightly) and data recently published by the ICRP (ICRP Publication 26, ICRP Publication 30), the EPA is proposing new guidance to Federal agencies which would sigrificantly change,the concentration of radioactive material in air that would be permitted in the workplace for most of the radionuclides of interest to the NRC and its licensees.
Some concentration values would be reduced, while others would be increased.
The reason for these changes is that some radionuclides have been found to present a greater risk than was previously thought, while others now appear to present less risk.
The actual ri;k that is being incurred by the workers,is determined, of course, by the quantity and type of radioactive material taken into their bodies, rather than by current scientific opinion.
If the:e quantities are allowed to increase, 12 Enclosure IV R
-gn-.
w g-,-i.*
-e w
,.,..w
.-----,.y-9 mg-e4-
- 9
-g-w yC=.-
T'*w--
W
---W*'--
Nw --
-TW-*
p*M--
=we'ww--
the actual risk will increase accordingly, even though the nuclide in question may be less hazardous than previously thought.
Thus a question arises as to whether, as a. result of new information, increases in these quantities should be allowed.
Some health physicists believe that it is necessary to avoid governmental action that would permit higher concentration values than those presently permitted.
The major reasons for this position are:
l (1) The relaxation of overexoosure recorting recuirements.
In general,_
licensees are very sensitive about overexposure reports and will go to great lengths to avoid them, much to the benfit of the worker.
Signiff-cant relaxation-of overexposure reporting requirements would result in a concomitant relaxation of protection effort on the part of the licensees.
In addition, the Commission's inspectors would not be notified of many incidents that are now reportable,.and would thus lose the opportunity i
for special investigations of breakdowns in the licansees' safety programs.
(2) Facility and orocess design decisions.
The long-range impact of higher I
l intake limits would lie in the area of facility design and process planning.
L Design and planning decisions are very dependent on the magnitude of the i
l l
regulatory concentration values, and those decisions virtually dictate l_
what the worker exposures will be for many years to ccme.
The higher the concentration values the fewer protective features, and the higher the exposures.
l l
l; 13 Enclosure IV
(3) Practicality of present concentration values.
NRC licenseas apparently
- are having little difficulty in complying with.present standards, and more permissive standards could allow increased risks to the workers with no justification other than compatibility with ICRP recommendations and, in some cases, decreases in operating costs.
(4)~ Present uncertainty about low-level radiation.
It would not be prudent to raise limits while the Government is in the process of assessing whether the biological effects of low-level radiation are more likely to occur
- than previously believed, at least not without compelling justification.
To relax the standards now would, to many people, have the appearance of
- irresponsible governmental action.
These four reasons are considered by some to be adequate justification fo ot increasing permissible organ doses or radionuclide intakes at this time.
Based on considerations of this nature, the EPA has included in its proposed guidance the following statement (5.b):
i "When a RIF for a specific redionuclide in a specific chemical or physical form determined on the basis of part (a) is larger than that currently in use, a value no greater than that in current use should be adopted in regulations governing work situations identical or similar to those currently in existence."
c For the purposes of this discussion the acronym RIF may be used interchangeably with the term concentration value.
In the Federal Register notice proposing the new guidance (46 FR 7836) the fo' lowing statement appears in support of 4
this part of guide; 14 Enclosure IV t
p ymt y
=--w,w
-e w-W
<-yy, a-
.-pg-m-e-ou--
-yr-gri9* r wt
-9W
'--@-fN-9-se'T' wr4'N-- - - - * -'m Y'
-*Y-'--t---*M-4'M*
'upwe-
-s P
"We believe 'that, for existing applications, experience gained over the past two decades shows that current values can be reasonably achieved.
Accordingly, in cases where the RIF for any specific radionuclide would be increased under the proposed guidance, we recommend that the value adopted in regulations governing existing applications be no higher than that now in use."
From these quotations it is apparent that the EPA does not believe that it would be appropriate for Federal agencies to take action that would increase the con-centration values where they are presently being applied.
However, the higher concentration values could be used in new applications.
Thus, it is the position of the EPA that, where employers have accepted present concentration values, higher values should not be allowed, with associated higher risks, in order to comply-with new calculational techniques and data."
l It is proposed that the NRC accept the EPA position and refrain from raising 1
any of the concentratiou values presently appearing in 10 CFR Part 20.
There appears to be little or no evidence that compliance with the present concentra-tion values is a source of serious concern among NRC licensees.
The licensees have been able to conduct their businesses under these constraints for many years.
And, from the regulatory viewpoint, the only apparent justification for relaxing constraints, at the expense of worker health protection, is com-patibility with ICRP-recommendations.
"The views of the utility Workers Union of America are given in the attached letters to EPA.
15 Enclosure IV
~
4 - - h s.- - m e a: m u met'a:N=ur.e I7TH.ITY WOR.uas UNION OF AMzaiCA W
====== u.L.m VALINTINE P. MURPHY JAMES JCY. JR.
PREsiCENT EXECUTWE VICE PRESiCENT Ncvb MMtsHALL M. MicXs
- c. JOSEPH Luc!ANC ascnETAnv.inEAsusEn vica PRESIDENT d-f.@ 7 815 SIXTitNTH STRIIT. N.'6 j
WASHINGTCN Q.C. 2COC5 EXECUTIVE BOAAD MEMBEMs N 7 2 7g- {J
- i
/
(222) 347 4105 peruses A atteswas muss u.t w aast sauts p. astun t.
' g '*
m C. m.C:nD
- Cam 3. 34G*4 1
- 1eae0 L C00.3MS. ;4.
O. 3AmtQ.3 saama m. casts acmata F. puras seus uvurov raut L uc.:sv
- 74anc:s a. owens 4WIIS70 8. Thubse Asse J. WEBEA J03EPst L. apses 0 1
May 27, 1980 4
Mr. Douglas M. Costle, Fdndstrato:
U. S. Environr. ental ? otection Agency 401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Costle:
~
The Utility ~4c kers Union of America, AFL-CIO, represents the workers in a n"+ er of the nuclear generating plants in various parts of the United States.
As tha Representative of these workers we are very concerned about the exposure to radiation involved in such work.
We recently became aware that the Office of Radiation ? ograms - Federal Guidance Branch of the Agency has developed a p cposed (draft) - Standards for occupational Exposures to Ionicing Radiation.
We have not had the opportunity to review the draft of the proposed standards and we have been informed that such a review is not possible as the draft must be reviewed and approved by the depar ene heads responsible for this activity.
Therefore, our infor=ation might be considered as hearsay at this point but we have been able to obtain sc=a general information f cs a source we considor to be most reliable and the information we de have haz raised very serious concerns.
It is our understanding that the standards drafted by che IPA staff follows the new ICa?
26 approach for establishing airborn radioactivity limitations in the wc k environ =ent, with sene minor exceptices.
The adherence to ch's concept O
en a
1
<er-wb-
,ey
--,-w,,-.,,w e
,---,-,.-.-w e,--,e-
,m--wn,,,-----,,
--.,,e.--,-ee.w,,-,,-,.,---e+e
,.e,w-
,,,ew-n,-w~r-----o--
.-won--e---- - - - - - -
UTIIJTY WORKERS UNION OF AMERICA, A.F.L-CLO.
Mr. Coctic Page 2 May 27, 1980 s
expressed in ICR? 25 would permit and, in ~ all probability, result in increased expcaures to i
airborn radioactivity fer nuclear workers in l
the generating plants as well as other licensed facilities and, if I understand the implication l
of the EPA's role in setting such standara, d
t the application would include other facilities where radiatics is involved even if not licensed by the NRC.
We have, therefera, within our cwn Councils, a::ived at a conclusica that the standarda being p cposed by the E?A staff will increase i
exposure to =4-hcrn radicactivity greater than is presently perritted by 10 C?R Part 20.
Until we are shewn clearly in the p:cposed standards that such is not the: case, we will proceed on j
the asst =ptics that our conclusions are cc :ect.
t While we are understanding cf the fact work can he perfc =ed'in nuclear facilities in such a manner that wc kers are reascnably protected f:cs serious ha s f:c= icw levels l
of radiation, over the =any years we have represented d
nuclear wc kers, we have accepted the standar s
,in 10 CFR Part 20 as adequate.
We have never agreed to or accepted the facu the exposure levels were too icw and we do not new feel that the existing standards are set eco icw.
We would cppose most vigorcusly any attempt to permit increases in the levels of airhorn radicactivity in work areas where our m bers.would be required to perform.
Since there is no overriding consideration either econcmically, technically, c scientifically to suggest a necessity fc increasing the permissible levels of airborn radioactivity we i=plere you as the P Mstrator and we i=plere the Invizcc= ental Protection Agency to re-eyedne the p cposed l
standards and make app Opriate revisions te take full aPrantage of the ICRP 25 app:cach in those areas where worker protections are strengthened and to reject those areas where protections would be reduced c: weakened.
l O
l -
0 O
e w.--wt
--g
--stwgi-t--
w-
-,W,wewy gyw9e-+p..-.p_.4,n-eey,w,g tw g yq.,-,.--.e-%,9-,
.y.4w,,w..wnqecwwg e-we,,s,w,w-.-i.pe-,.-wegew=,.,,rwgv.,
.,,,gr.e-woese-eig e w-ewye-r m-e--
v MTY WORKERS UNION OF AMERICA, A.F.L CI.O.
Mr. Coctic Page 3 May 27, 1980 As an c=ganization having substantiai responsib'ility and interest in standards applicable to workers in the nuclear industry, we respectfully
.. request that we be given the opportunity to-review the p cposed standards and possibly arrange e
a meeting with the EPA staff to nere thoroughly and explicitly explain our posi-J.cn en the matters expressed.in this letter.
Sincerely, f J// flfah
/
4 jf" Marshall M. Eic:a National Secretary-Oreasur -
1 MME:njs opein 12-CC: CWUA Ixecutive Cc"d:tes-AFL-CIO Depart =ent of OSHA I3EN - AFL-CIO IUD OSEA Director CCAW,.AFL-CIO
< R. E. Alexander, NRC 4
Jm o
1 1
e
\\
m.
4 6
-,. -, -. ~ _.,.,. _. -.,, - -.. -, - ~, _, -.. _,
.--...,._._..m,,,.
-,,..v wv....
!Nwc.v=i6 UTILITY'W ORK?RS UNION Ur h.Mr.mCA.<.'!W annan u us.ts.
vatswitNa P. MURPHY JAMES joy, JR.
j PREslOENT EXECUTIVE VICE PRESIDENT -
A--N h.
- MARSHALt. M. HICKS
- c. JcSEPH 1.UC:ANo l
SECRETARY. TREASURER VICE PRP.SICENT 815 SIXTIINTH STREIT. N.W t
WASHINGTON. D.C. 23GC8 EXECUTIVE BOARD MEMBERS N* h !
]
(222) 347 31C5 L* 2 *_.
pafittcE A CACACMER wuCN w. '.ceptAng IAasts p. stLLat
). ' s(L. ;
?
i
=
a C.AnO,L,C",.3;ms. 3.
g,C N gLgwyn c. **.11C.11 MM'I 3.1AQ 4m esata A; a.t (L12AstTM 8. cAntib8
. *um 4. JAv41 7tue:s s. cwess 84
- 46 4. w.m l
. aces asannot
~
nerasono s rnussas 2cna L suaa
- ostm t. mam July.17, 1920 l
Mr. David G. Hawkins, Assistant Adminis'Jater United States Environmental Protection Agency Office of Air, Noise and Radiation i
Washington, D. C. 20460
Dear Mr. Hawkins:
t l
On May 27, 19 80, I wrote to Mr. Costle, L
Director of the Inviron= ental Protection Agency, to register the concerns and objections of the Utility Workers Unica of America ec he IPA's proposad draft fc
" Standards f : Cccupaticnal Exposures to Ionizing Radiation".
It is' apparent f:cm the response received f:cm you, dated June 20, 1980, that the objections stated in our ec=municatien were not understood as we had meant them to be.
At the time we submitted the objections and voiced our cencerns
-we felt that we did have a full and ccmplete comprehension of changes that would be effected.
~
We had studied ICRP 26, including the statement
.from the 1978 Stockholm meeting.
And, in addition, ve had censidered cther information and had i
reviewed our understandings with others.
We have accepted without disagreement that the conclusiens reached by the International Commission en Radiolcgical P ctection are the We did
. best scian*ific knowledge available.
and de not, argue with the conclusion that
- not, it is possible in the case of certain radionuclides to allcw c persi: an increase in the "Maxist=1 Permissible Concentraticns" without surpassing the dose limit to the whole bcdy.
Our argument and objections were derived f cm the fact we see no need whatsoever to nake such increases in the MPCs when it has already been clearly 4
m.
_,.__.-,.....,,.,....--_,e_,,w--..-..+.,.m--.,..,
....-.-,,..y,-,
,y_-------
=
.=
WORIGRS UNION OF A> ERICA, A.F.L.-CLO.
Paga 2 1
i Mr. Hawkino July 17, 1980
~
proven that we have the-technical and engineering capability to maintain the icwer levels for the maximus permissible-concentrations because it has been done for a nt-mMr of years.
.o merely raise the MPCs because it has been deemed possible without surpassing the whole body dose limits appears to be totally ridiculous.,
We attempted to make the point that the MPCs should not be raised for any radionuclide unless there was a clearly established and ccmpelling economic, technical ~cr scientific necessity _
to do so. _ If.it were not possible, for instance, to establish an envirc:.=ent at the limits previous 17 established, than sc=e consideration for raising the MPCs seems reasonable and your analysis may have sc=e = erit.
_However, the idea'that such limits should be increased based on he hing more than a newly reached conclusien that such increases will not surpaus the arbitrarily established whole body dose ' N ' 's contrary to the basic "cbjectives of Radiation Protection" as stated in ICRP 26.
"(9) kha aim of radiacien procaccion should be :o prevene decrimental acn-stochastic effects and to lini: the probcbili:v of stochascie affacts ec levels deemed to be acceccable.
.ut additional als is to ensure chac
- practices involving radia:1cu exoosure are justified.
~
(12) (b) All exoosures shall be kaot as low as reasonabtv ach:.evable. -
economic a:d sccial f ac:ces be::t taken into account.'
l There can be no question that the previously l-established Maxi =un Permissible Concentrations are " reasonably achievable" and a standard that would permit or allcw higher concentrations are not " justified".
e l'
u M
- x....
TJTILITY WORKERS UNION OF AMERICA, A.E.L-C.LO.
s%d a Mr. Hawking July 17,-1980 It is hoped these additional co=sents make the position and objections of the CWUA clearer
-and the EPA will be convinced it should take a closer look at its proposed standards and failing to find justification for raising the standards for "maxistra Permissibis Concentrations" a conclusion will be reached to retain the previously established limits.
Sincerely yours, fu
/i<Y..Ldf8 i )g -. h Marshall M. Hicks National Secretary-Treasurer MME:njs opeiu #2 CC: CWUA Executive Cc~ittee AFL-CIO Department of CSEA IBEN, AFL-CIO IUD OSHA Director CCAW, AFL-CIO R. E. Alexande:, NRC
~
?
l l
l-l 1 +
..,... -...., ~, - -.,,........ -.,
~
s'. c:nm mpu. wa nmc
- -w :-
ser
. u ~
. +.
~w
-n
.u n
e Y
4 O
O 9
a M
.,.g e,
a 4
~
,P M-g
-',6;*-je p
- y, 4
4
- j a
- ~.
e 3
.* *5 N'
- 7, gh3.-
9 e=s s
3
,,m
._r=
e g
f*
s 69 a.
k V
,'*.+4%
y f
i+
=
g a
p=
=
e "h
w 5-y W
m O
e W
e O-m O
ENCLOSURE V 9
9 Y
9 O
Y V
I O-'
@m., A hm
,79
- e
SECOND MINORITY OPINION Certain important issues are not addressed with sufficient clarity by the staff-puition -in the opinion. of C. A. Willis, Leader, Applications Section, Fffluent-Treat.,.ent Syst' ems Branch, NRR. Consideration of these. issues emphasizes the importance o'f careful evaluation and justification b'efcre making fundamental changes in the. bases for the radiation protection regulations. These issues are addressed briefly in this enclosure.
1.. There is no' health and safety justification for changing the bases for-
~
the radiation' protection, regulations. Neither the EPA'ncr.the ICRP have contended that a problem exists. Further, according to the most authoritative determinations available, the occupational risks from radiation are far less than the risks from other carcinogens (Table 1).
2.
No major reduction in occupational radiation exposure or risk can be expected from changing the regulations as would be required by adoption of either the EPA proposal or the ICRP recommendations.
Neither the EPA nor the ICRP has suggested that exposure reductions are to be expected.
In fact,
~
neither has offered any practical benefits from the proposed changes.
i 3.
The only known reasons for considering a fundamental change in the radiation protection regulations are:
(a) -to make the limits consistent with current risk estimates, and l
(b).to make the U.S. limits consistent with the limits of other countries.
i These are desirable results but it is not self-evident that they provide benefits commensurate with the costs. Neither the ICRP ner the EPA has addressed this
, question.
Enclosure V
. ~ -.
.E...
2-4 Adopting the ICRP recommendations would help achieve these results. The EPA proposal would not help on either count.
L
- 4..The proposed changes in the bases for the radiation protection regulations have the potential for being very costly. NRC regulations affect tens of thousands of licensees with millions of employees and with hundreds of
~
billions of dollars in facilities and eqdipment. Under these conditiens even simple terminology changes can be costly; it could easily cost the NRC millions of dollars just to revise the regulations as would be necessary to use the ICRP-recomended terminology (gray, sievert, becquerel, ALI, etc.).
The costs to the agreement states and to the licensees could be even more sub-
~
.stantial. Of course, terminolo y changes would wreak havoc with public information programs.
The-potential for increasing costs is illustrated by one feature comon to both EPA and ICRP; they would reduce the air concentration limit for thorium by a factor of 50 (Table 2). This could have a major cost impact on breeder L
reactor programs.
If such a change is necessary, it should be made explicitly so interested parties would have the opportunity to fully address the issues.
l
-The-inevitable cost of diverting scarce resources frem more serious problems is particularly cbjectionable at this time.
i It seems that no systematic effcrt has been made to identify the potential costs of either the EPA proposal or the ICRP reccmendations. Nevertheless, i
there is evident potential for high costs.
l
?
Enclosure V y
er 7
--1
'=w w
y.-
-g-
- w--
- -y-wew g-p-=-
ee e
-r--
--r w* * -
'-pee m
T'wwy 3
w-c--
- ? W "'"
T'
'W'"
-F-S"
'-'t*T
-JM'-"
- e'"--
W
.a 3-
==
Conclusion:==
The NRC should oppose implementation of either the EPA proposal or
- the ICRP reconnendations without a-full eva';ation of the potential costs and the potential -benefits.
J t
~
l L
i t
Enclosure V
.nw-e e
vm, - >
w-e m
-en,.,
,-we.-,-w-e-
w
,- rw v v.-- m - - -
,wn,w-+,-g e - w e re,w m,4
-~,.e,---
g-e-
---o p-
.-ww-.e,,
~, ~
p~~~-v-e.m.~-.,--rgw p.
,-.en, - - w 9 -e, + --
a TABLE 1 OCCUPATIONAL RISKS (Events per year per _100,000 workers)
Mining &
All U.S.
Radiation Quarrying Industries ~
Trade Exposure _
O Fatal Accidents 63 14 6
0 (1)
Disabling Injuries 5040 2460 1850 0
Delayed Effects Actual.
readily Occasionally Not not Observable Observable Observable Observable Estimated
?
Includes 115-
~ ?
Includes 4-6 219 lethgl lethal cancers ('
cancersl'1 (1)1976 data, from " Accident Facts,1977 Edition," National Safety Council.
(2).
Estimates from " Toxic Chemicals and Public Protection, A Report to the President by the Toxic Substances Strategy Ccmmittee," Council on Environmental Quality, Government Printing Office, May 1980.. Minimum estimates are 6 to 29.
(3) Estimates from BEIR-III,1980, assuming an average radiation worker exposure rate of 0.5 rem /yr; exposure at the limit. 5 rems /yr, would yield an estimate of from 37 to 63 lethal cancers per year per 100,000 workers.
s Enclosure V
TABLE 2 COMPARISON OF THE AIR CONCENTRATION LIMITS OF 10 CFR 20 TO THOSE OF ICRP-30 FOR 40 HOUR /WK OCCUPATIONAL EXPOSURE 3
Limit,* Ci/m Ratio Nuclide -- -
DAC (ICRP-30)
P-32 2E-7 7E-8 3
SE-6 SE-7 10
-Mn-56 1E-8 9E-9 1
Co-60 1E-4 1 E-5 10 Xf-85 Sr-90 2E-9 1E-9 2
Zr-95 5E-8 3E-8 2
Mo gg Te-127m 1E-7 4E-8 2
L Te-132 -
8E-8 1E-7 0.8 l
Ce-141 2E-7 2E-7 1
Ra-226 3E-10 3E-11 10 Th-232 SE-13 3E-ll 0.02 U-235 2E-ll l E-10 0.2 Pu-239 2E-12 2E-12 1
Am-242 3E-8 4E-8 0.8 Cm-244 SE-12 9E-12 '
O.6 C f-251 2E-12 2E-12 1
- In each case the lowest limit is given; the other chemical forms have higher r
or equal limits.
__.,~..
/N g' %gt gc
%g >
v vs
.s wr f:
o3
,,y_.
g e
a 2
.om m.--em-e-
.o.
,,w,.,
.s.,
h-t-.
s.
e 4
e, -
r
,,.w p
7
{
g*
9,
" "'r..
4.
f o.,
7c ".,
p,
y
. ' *. =.,g, #
-.A'..
~
2' f
'e
' ',,}
e.-
.,._a
' p
~ ~
.4i
- g g
-v,~.
..'un.
{f p
m s
- c..
A.,
~
, 9c. 3 k. t..* ],.'
_ y
..-~
,-c;.-
f p
- ' ' ~
- c...
- m.
p.
3(.
'..t *.., ' ; &..w.'
- s
^
- 9 ;.o..*.
'+*k - f
-.=~.
M 7'
I 54
$f - ' y' ih ".. _,.
7.. r om,.
3.,'...
.4
=
3
,o.
,s s
.~ *
-%+? h4P. '% d a g.
4g g
M e _'e ;* 4 A,l'%i f i Mr 1 - b
".'*.w
- 4.. ~
. y'..
b'
.. i
}'
3,,,, '..-.,u. g. 4* f.5 3..,.;,;.g;r*,.* *;- e.,.. g,...,'*
3,,,l ' ' *[.....* ~ ' * ~*
3,,, e ~.:. ;.. :.
q p~
'e 1- ;{* 1h 6.9% ' -
8 ' EM= #.
A,
=. -..
'.h
- N I'
- -'s a_
, '"-.p*
-s -T
- y<,T.i?.
%'a *=W.% ^.
'i;
.,:'.'.~ +
x P
,r s.. =.,,' e p.t *
- f..
.,* t.
-- s,3... g.e d
.,s
- sw3.. c,1 + -., -
- .*e6.-
i i. ' *.
e -.w..~
- r,.
. ' - ~1
~-'
4 6
{c
. a-u.- m r-
- g"'f',%,
. =..
- e.
,.,, f r
,.,.e.
,, =.*.-.af.p, w' j.,p.f. a...'.w, ~. ~., e.
Y*
e **
I
,.. k. A.c ', 3 -,.-
.',l...
- ~'
t, 4*
y "was
,s ye*6,. a f,,,,q* Q*
g b
- 8-c s-ey h
=
...e-w.
' g gf g'*,-[
N
[
- ..a
,,y_
g
..g*.f.,..,*
7
,....*4..~>*
=
e,.. c g
f
.s
=
'b
.$**,d%
,Q i.,,,,, j.
3'
{
W..+.
.- s.
~. =,
- m
- .g. % +g d 9 sd. *',**,. L, 5.',., *. - 4 '4
. '* A " *
{"
~.
p
'- % ;c 4:1 4 r...'
'~
s
-. J..~-.,. %. ~['.. ~,. >.f, ', T :..
4' s
e
,. u;-
r a 't g g*
81 ;. - if =..,,
e < * '*'
e a
=
i.
~
- s j^g. t f >
- g_.~ \\ -,%
. *. *;sik < ~.,..
t
- d3 e* ef**, ' ' *
{g.
. [ &
e*
j p_.
.-. t ;.
.7 a.
s>
~
f.
~ *, - " ' 2, 7.., m,'*,,,
~~
- * -d e,.._
is
e-
~,
.s
.9 4% '.',.,,
P N
- * -... i
- .. g.a
=
s
.s
-.c 4
.c,.
(
- D * ' "
ENCLOSURE VI
=
k.
w 1
F N
a h
4,
~
s m-
.e d'
'i s,
e t
./
4
/
4 s
E e.
T I
}
4 J
2 l,
m-m m,,
an a,
m e.,
me
- c. cm na..m..
, cr-v.c
-c,w.
,,m-r.,- m n w.
o
-w c =c v
-