ML20010A042
| ML20010A042 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1981 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20010A040 | List: |
| References | |
| REGGD-08.029, REGGD-8.029, NUDOCS 8108100429 | |
| Download: ML20010A042 (3) | |
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BIBLIOGRAPHY
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American Cancer Society,1979 Cancer facts and Figures, Internationai Commission on Radiological Protection, Radia-
- 1978, tion Protec. ion, Recommendations of the Internationai Commission on Radiological Protection, ICRP Publication 26, Anderson, T.W., " Radiation Exposure of llanford Workers:
Pergamon Press, January 1977.
A Critique of the hiancuso, Stewart, and Kneale Report,"
llealth Physics, Vol. 35, December 1978.
Kelsey, C.A.," Comparison of Relative Risk from Radiation Exposure and Other Common llazards," Ilealth Physics, Archer, V.E., " Effects of Low-!xvel Radiation: A Critical Vol. 35, August 1978.
l Review," Nuclear Safety, Vol. 21, No.1, January-February 1978.
Lapp, R.E., The Radiation Controversy, Reddy Communica-b tions, Inc., Greenwich, Connecticut,1979.
Atomic Energy Commission, Operational Accidents and Radiation Exposure Experience, WASil 1192, Fall 1975.
Lapp, R.E., A Worker's Guide to Radiation, Atomic Industrial Forum, August 1979.
Barnett, h1.Il., The Biological Effects oflonizing Radiation:
An Overview, Department of flealth, Education, and Welfare Linos, A., et al., " Low Dose Radiation and Leukemia, Mayo Publication (FD A) 77-8004, October 1976.
Clinic and Foundation, Rochester, Minn.," New England Journal of Medicine 1980; Vol. 302, pp. I101-1105.
Cohen, B.L., and Lee, l.S., "A Catalog of Risks," //ealth Physics, Vol. 36, June 1979.
Mancuso,T.F., Stewart, A., and Kneale,G.," Radiation Expo-sures of llanford Workers Dying from Cancer and Other Cook, J., an d Nelson, D., Occupational Exposures to luni:ing Causes,"llealth Physics, Vol. 33, November 1977.
Radiation in the United States: A Comprehensire Summary for 197.5, EPA 520/4-80-001, Environmental Protection Muller, R.," Natural Radiation Background vs. Radiation from Agency.
Nuclear Power Plants," Journal of EnrironmentalSciences, Department of Ilealth, Education, and 'Nelfare, Biologic Effects ofIonizing Radiation, Report of the Science Work Najarian, T., and Colton, T., "hfortality from Leukemia and Group of the Interagency Task Force on Radiation, June 1979 Cancer in Shipyard Nuclear Workers," Lancer,1: hiay 1978.
Dreyer, N.A., et al., The Feasibility of Epidemiologic Inves-National Academy of Sciences, The Effects on Populations tigations of the llealth Effects of Low-Levelloni:ing Radia-of Exposure to Low Lerels oflonizing Radiation, Report rion, NUREG/CR-1728, Nuclear Regulatory Commission, of the Committee on the Biological Effects of lonizing November 1980.
Radiation (B EIR),1980.
- Gilbert, E.S., " Assessment of Risks from Occupational Rossi and hlays, " Leukemia Risk from Neutrons,"llealth Exposure to lonizing Radiation," in Energy and llcalth Physics, Vol. 34, pp. 353-360,1978.
Proceedings of the Conference on Energy and llcalth, June 26-30,1978, SI A h! Publication, Philadelphia,1979.
Schottenfeld, D., and llaas, J., " Carcinogens in tne Work-place." CA-A Cancer Journal for Clinicians, Vol. 29, No. 3, Gofman, J.W., "The Question of Radiation Causation of M.,y-June 1979.
Cancer in llanford Workers," llealth Physics, Vol. 37, November 1979 United Nations Scientific Committee on the Effects of Atomic Radiation,1977, Sources and Effects of Ionizing Gotchy, R.L., " Estimation of Life 5hortening Resulting Radiation, Report to the General Assembly, UN Publica-from Radiogenic Cancer per Rem of Absorbed Dose,"
tion No. E.77.IX.I,1977.
Ilealth Physics, Vol 33, October 1978.
Upton, Arthur C.," Radiation from Nuclear Power Exagger-Ilall.
E.J., Radiation and Life, Pergamon Press,1976.
ated," New England JournalofMedicine, Vol. 302, pp. I 205-1206, May 22,1980.
International Commission on Radiological Protection, Problems inrolved in Der
- loping an Index of flarm, Anna!s World llcalth Organization, llealth implications of Nuclear of the ICRP,ICRP Publication 27, Pergamon Press, May 1977.
Ibwer Production, Report of a Working Group, December 1975.
9 8108100429 810731' PDR REGGD 8.29-15 08.029 R PDR l
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VALUE/ IMPACT STATEMENT -
, I. PROPOSED ACTION from the availability of an NRC guide on radiation risk suitable for iAclusion in those training programs. The guide 1.1 Description was reviewed and distributed to agreement states by the Office of State Programs. Comments have been received All NRC licensees are required to provide appropriate radia-from the EPA and the Bureau of Radiological llealth.
tion protectim training for all permanent end transient person-nel who work in restricted areas (@ 19.12 of 10 CFR Part 19/.
1.3.3 Industry A clear and reasonable assessment of the biological risksasso-ciated with occupational radiation exposure is essential to Providing a reasonable and understandable statement on effective radiatim protection training.The proposed actimis worker risk should facilitate industry efforts to provide to provide instructional materialin a suitable form describing effective safety training and to better achieve as low as is and estimating the risks from exposure to radiation. The reasonably achievable ( ALARA) objectives. Minimalimpact instructional material will be suitable for use in licensee is expected in the form of additional cost of training training programs and will represent an acceptatL: method of programs since training requirements already exist. Comments comolying with part of the existing training requirements.
from unions and industry in the development ofinstructional material on risk were encouraged. Numerous public comment 1.2 Need for Proposed Action letters were received from industry and three meetings were held with worker groups to review the draft guide.
One common element of those occupationalareasencom-passed by NRC licensing activity is worker exposure to ionizing 1.3.4 Workers radiation and the biological risks from exposure. Union repre-sentatives have expressed a dissatisfaction with the way in The proposed action should improve worker protection which these risks have been explained to the worker by the in that reasonable understanding of radiation riskisessential licensee. In addition, they feel the NRC hasa responsibility to the development of safe working practices. The staff to make its position on the controversial issue of radiation believes that an objective discussion of radiation risk may in risk clear to the worker and the public. A meeting of NRC fact reduce "over concern" and also eliminate "under staff and union representatives was held on November 28, concern" on the part of some workers. If improved training 1978, during which this matter was discussed. A transcript results in a wider recognition and respect for radiation as of the meeting is available from the Public Document Room.
an industrial hazard, more attention will be given to protectie precedures and a reduction in individual and collective dose The Environmental Protection Agency (EPA) has should result.
published recommendations concerning radiation protection for public comment and, in conjunction with other govern-1.3.5 Public ment agencies, will be holding public hearings on radiation risk and dose limits. This guide reflects current and proposed Nuclear workers are also members of the public and are EPA guidance and will be helpful to workers and worker generally residents of the area where facilities are located.
groups interested in understanding current discussion on llaving a better-informed public should result in a wider the issues of risk and dose limits.
range of participation in local decisionmaking concerning nuclear development. Improved training implies the added' l.3 Value/ Impact of Proposed Action benefit of increased plant safety, thereby decreasing the probability of accidents that could involve the public.
1.3.1 NRC Operations 1.3.6 Decision on Proposed Action Instructional material on radiation risk written at a level and scope understandable to the worker should contribute The NRC should develop and provide instructional to increased confidence, on the part of the worker, in the material concerning risk from occupational radiation NRC in general. A better understanding of the risk should exposure.
elicit more worker cooperation with NRC-enforced safety programs. Impacts of the development of instructional
- 2. TECIINICAL APPROACil material on risk include task completion manpower cost, estimated to be 0.2 person-year, and printing costs of The technical approach proposed is to develop instruc-approximately $400.00.
tional material concerning risks to the worker from occupa-tional radiation exposure and to publish the material in a 1.3.2 Other Covernment Agencies form that will receive the widest dissemination among NRC-licensed facilities. An alternative is to publish the Agreement States whose licensing regulations include findings of the proposed hearing on dose limits and assume radiation protection training requirements may benefit the relevant information will filter down to the worker. It is 8.29-16
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the feeling of the staff that a direct approach is required 3.2 Decision on Procedural Approach here.
The staff concludes that a regulatory guide similar to 9
- 3. PROCEDURAL APPROACil Regulatory Guide 8.13 on the subject of worker instruction concerning risks from occupational radiation exposure The proposed action, to publish training material concern-should be published at this time.
ing risks from occupa ional radiation exposure, the use of which woold be recoramended to all licensees, could be
- 4. STATUTORY CONSIDER ATIONS accomplished by several alternative methods. These include an NRC regulation requiring that specific training materials 4.1 NRC Regulatory Authority be used, a regulatory guide based on the existing 19.12 that would provide an acceptable method for training on Section 19.12 of 10 CFR Part 19 estabhshes a legal risks, an ANSI standard on training that could be adopted requirement that all NRC licensees provide radiation by a regulatory guide, and a NUREG report or a branch protection training to personnc! and that the training be l
position paper.
commensurate with the potential risks from radiation f
exposure encountered by those personnel. The NRCis thus 3.1 Value/ impact of Procedural Alternatives authorized to provide criteria for acceptable levels of l
training and to inspect for compliance with training require-An NRC regulation establishes generallegal requirements, men ts.
j is costly and time consuming to prepare, and is not an appropriate vehicle for the specific and narrow objective 4.2 Need for NEPA Statement proposed here. A regulation would be difficult to modify as new information on radiation risk i.= developed. One The action proposed here is to publish an instructional advantage is that a regulation legally requires compliance.
document on risks. This will occur after, and be in addition in general, this approach is not considered cost effective in to, any major NRC action on retaming or modifying view of the objectives of the proposed action.
existing dose limits, based on planned public hearings.
Since at that time it would not constitute a major addition ANSI atandards are generally intended as highly technical or change and would entail no effect on the environment, and advanced treatments of specialized areas of concern to an environmental impact statement is not considered industry. A comprehensive technical review of risks from necessary.
radiation would be of value but would not be suitable as
) instructionan material at an introductory level for worker
- 5. RELATIONSillP TO OTilER EXISTING OR PROPOSED y
radiation protection training. Completion of an ANSI REGULATIONS OR POLICIES standard and an endorsing regulatory guide would require several years and would oe too costly. This approach is not Regulatory Guide 1.70, " Standard Format and Content considered cost effective in view of the proposed objectives.
of Safety Analysis Reports for Nuclear Power Plants,"
requires a commitment to appropriate radiation protection A NUREG document would be an appropriate vehicle training. When next revised, it should include reference to for a comprehensive discussion of radiation risk beyond the this proposed action as an acceptable element of a licensee's scope of what is proposed here. A regulatory position, training program.
however, is not established through publication of a NUREG report. Since this proposal includes establishing an accept-This proposed guide is consistent with Regulatory able method for compliance with elements of required Guide 8.8,"Information Relevant to Ensuring That Occupa-training programs, a NUREG report is not suitable.
tional Exposures at Nuclear Power Stations Will Be As Low As is Reasonably Achievable."When next revised, Regulatory Branch position statements are interded as interim Guide 8.8 should include cross-reference to this proposed measures to be used when an immediate response = required.
action.
They are usually superseded when a more permar. nt mode of guidance is developed.
This proposed action directly supplements Regulatory Guide 8.27 and will supplement and be referenced in other A regulatory guide can be prepared at reasonable cost planned guides on training at other types of licensed facil-within a reasonable time period. The staff does not consider ities, e.g., uranium fuel fabrication plants, uranium mills, that revision of any existing regulatory guides could provide medical institutions.
the instructimal materialintended here. Regulatory guides on training requirements are being developed but are =pecific to
- 6.
SUMMARY
AND CONCLUSIONS types of licensees such as Regulatory Guide 8.27," Radiation Protection Training for Personnel at Light-Water-Cooled in summary, it is proposed that this regulatory guide be Nuclear Power Plants." The action proposed here has broad prepared and issued for the purpose of providing instruc-application to all licensees, as does Regulatory Guide 8.13, tional material concerning assessment of risk from occupa-
} " Instruction Concerning Prenatal Radiation Exposure."
tional radiation exposure.
8.29-17
UNITED STATES
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