ML20029B219
| ML20029B219 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-50FR51992, RULE-PR-19, RULE-PR-20 NUDOCS 9103060226 | |
| Download: ML20029B219 (41) | |
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NEWS NEDIA BRIEFING ON FINAL RULE 10 CFR PART 20 3
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DISCLAIMER rg This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on December 13, 1990, in the Commission's office at One Ifhite Flint North, Rockville, Maryland.
The meeting was open to pitblic attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may I
contain inaccuracies.
i The transcript is intended solely for general
(
informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination l
or beliefs.
No pleading or other paper may be filed. with j
the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein',
except as the Commission may authorize.
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t UNITED STATES OF AMERICA O
NUCLEAR REGULATORY COMMISSION NEWS MEDIA BRIEFING ON FINAL RULE 10 CFR PART 20-l 1
PUBLIC MEETING i
Nuclear Regulatory' Commission One White-Flint North
.Rockville, Maryland 4
^ O V
Thursday, December 13, 1990
]
PRESENT:
JOSEPH FOUCHARD, Director of-Public Affairs DONALD COOL, Office of Research-i i
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P-R-O-C-E-E-D-I-N-G-S 2
10:15 a.m.
3 MR. FOUCHARD:
All right.
Let's move ahead with the briefing for the news media on the 5
Commission's action in approving the first major 6
revision to our radiation protection regulations in 7
.30 years.
8 Doctor Donald Cool of our Office of 9
Research is going to take you through the major 10 changes in the regulation, and after he's finished 11 we'll be pleased to take your questions.
12 So, Donald, go ahead.
13 DOCTOR COOL:
Tharks, Joe.
ph 14 Joe Fouchard asked me to try and provide 15 you with a very brief overview sketch of -- come on, 16 I'm not that bad.
Maybe I will and maybe I won't.
17 Maybe we'll do it without the microphone.
If I start 18 talking too sof tly, just let me know and I'll try and 19 talk a little bit louder.
20 The revision which the Commission just 21 affirmed is the first complete revision of 10 CFR Part 22 20, which is the NRC's Basic Standards for Protection 23 Against Radiation that has been conducted since the 24 time the rule was originally put out in the 1950s.
O(T 25 Since the time the rule was originally put out, there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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.e over 90, in fact 1
have been 90 amendments at 2
various times looking at specific aspects, changing.
3 various
- things, but this is the first time the 4
Commission has ever gone through and completely 5
revised and updated, put the entire rule back into a 6
coherent structure again.
That was one of the major purposesofdoingthisrevision.'O}
7 3
8 The revision adopts the currently 9
published recommendations of the ICRP and it adopts i
10 and implements the Federal Guidance for Occupational t
11 Exposure that was signed by President Reagan in 1987.
12 As Chairman Carr said during his brief statement j
13 before the affirmation vote, the rule is to be 14 effective 30 days af ter the publication in the Federal l
15 Register.
Licensees will have until January - 1st, 16
- 1993, to implement those provisions.
They may 17 implement it before that time if they so desire by 18 notification to the Commission.
The agreement states 19 will have until January 1st of 1994 to bring their 20 regulations into conformance with the new standards 21 adopted.
22 We are currently in the process of moving 23 into that implementation phase that the Chairman 24 mentioned.
In particular, we're preparing a number 25 of dif ferent regulatory guides.. A number of these are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) N WASHINGTON, D.C. 20005 (202) 232-6FM
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totally new guides.
In other cases, they are major 2
revisions of existing guidance documents.
Those 3
guides will be available in draf t form within the next 4
few months with the_ goal to have the final guidance 5
documents in place by about the end of 1991 so that 6
licensees have a full year between the time when final 7
guidance is available and the time when they must 8
implement the rule.
9 For some of the major provisions of this 10 revision to 10 CFR Part 20, let's first look at the 11 occupational exposure.
The dose limits are now based 12 on the summation of internal and external exposures, 13 rather than the previous 10 CFR Part 20 which had 14 separate limitations, an external exposure limit and 15 controls on internal exposure.
Summation will be 16 required if each component had to be monitored for, 17 and in most cases licensees will not have to worry 18 about the summation requirement because in most c res 19 there is either an external exposure situation or an-70 internal exposure situation, but there are relatively-l 21 few instances where there are significant 22 contributions from both of those sources.
23 The limits are expressed in terms of an J
24 annual basis, 5 rem per year total effective dose 25 equivalent.
The previous rule contained quarterly J
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1 dora limita, which havn benn climinatsd.
The previous 2
rule also had a cumulative dose limit which has been i
3 eliminated.
In the internal dose, the dose is 4
calculated using what is called a " committed effective 5
dose equivalent" approach.
It is an approach whereby 6
the exposure in each of the organs is looked at and 7
calculated and the risk to all of the organs which 8
might be exposed as a
result of an intake of 9
radioactive material is considered in looking at the 10 limit.
The old Part 20 used what was called a 11
" critical dose" approach where only the exposure to 12 the organ that was most highly exposed was consider.J 13 in determining compliance.
O'Q 14 Appendix B of the rule, which contains the 15 values for airborne radioactivity cccupational 16 exposure have been modified to reflect the new dose 17 limits and to reflect the 30 years worth of data we l
18 have on how radioactive materials move in_the body, 19 the metabolic models and the information that we have l
20 on the dose received from various radionuclides.-
21 Licensees are now going to be required as 1
22 a part of this new rule to have a radiation protection 23 program.
Many licensees, by virtue of requirements 24 in Part 35, Part 30 and other places, already have i
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required to have those programs.
As one part of that 2
program, licensees will be required to have procedures
~
3 and engineering controls to achieve doses which are 4
as low as reasonably achievable or ALARA, that phrase 5
which you have of ten heard.
The old Part 20 contained 6
a " licensee should" try to work to having reduced 7
doses to as low as reasonably achievable.
This new 8
rule moves that up a step and makes it a "shall."
9 They shall have these programs for looking at as low 10 as reasonably achievable.
11 There is a brand new dose limit which has 12 not been part of the previous Part 20, which is a dose 13 limit on exposures to the embryo fetus, the unborn O)
(
14 child.
That limit, which is a half a rem over the 15 course of the pregnancy of the declared pregnant woman 16 is consistent with the recommendations of the NCRP and 17 is in fact lower than the recommendations which ICRP 18 put out in 1977 for that situation.
19 There are dose limits contained in the 20 rule for minors, which are individuals who are under 21 18 years of age who may be working part-time, say, in 22 a university, in a-laboratory, something of that 23 order.
Those dose limits are ten percent of whatever 24 the occupational dose limit was.
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1 cquivalent for a whole body exposure.
2 For members of the public, the new Part 3
20 contains an explicit dose limit of 100 millirem, 4
which is a five fold reduction from the implicit value 5
that was contained in the previous Part 20.
Appendix 6
B also contains values which correspond to the publio 7
dose limits for airborne radioactive effluents and for-8 11guld radioactive effluents.
Those values are 9
actually calculated to a 50 millirem level, one-half 10 of the total public dose limit value, to account for 11 the fact that there could be exposure to two different 12 pathways.
13 There are values contained in the table, 14 Appendix B,
for disposal to the sanitary sewer as 15 there was in the previous Part 20.
Those values now 16 represent a calculation to a value of 500 millirem, 17 which is a factor of 10 reduction in the dose limit 18 that they're corresponding to from the old Part'20, 19 In terms of moniaing, record keeping, 20 and reporting, a lot of the other provisions that go-21 along with having limitations on dose, monitoring will 22 be required if the dose could exceed cen percent of 23 the limit.
In-terms of external exposure, that's the 24 same as was contained in the old Part 20.
For 25 internal exposures, that represents s reduction from NEAL R. GROSS COURT REPORTERS AND TRANSCR10ERS 1323 RHODE ISLAND AVENUE, N W.
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tha previoucly required monitoring level,
- rom 25 2
percent to ten percent.
3 For reporting and record
- keeping, 4
licensees must provide dose data to employees each 5
year.
This requirement is actually contained in 10 6
CFR Part 19, which is being amended along with 10 CFR 7
Part 20.
The previous Part 19 had required that.
8 licensees provide that information to an employee if 9
he requested it.
The new rule requires that it be l
10 provided, whether or not they request it, to each of 11 the employees.
12 10 CFR Part 20, the old rule, contained 13 a
requirement that licensees in one of seven
)
14 categories such as power reactors, high-level waste, v
15 independent spent fuel storage, fuel cycle facilities, 16 large radioisotope production faci?ities, 17 radiographers, those categories of licensees had to 18 provide statistical summaries of their employees' 19 exposure each year to the NRC, and they also had to 20 provide to the NRC what were called " termination 21 reports," reports of an individual's exposure when 22 they terminated emnloyment with that particular 23 licensee.
24 Those two provisions, the statistical (b
's 25 summary and the termination
- reports, have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4,g3 WASHINGTON. O C. 20005 (202) 232-6600
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1 climinctedqnfavor'ofthoselicenseesnowproviding 8
2 to the NRC each year each individual's dose for that il 3
year.
It 1IB exactly _ the same kind of information 4
which we are requiring the licensee to provide to the 5
individual themselves.
That information will be kept 6
by the NRC in our radiation exposure information 7
reporting system, which is the same system where we 8
currently keep the termination report data and can be 9
used to provide a database of exposures, exposure 10 history, our ability to determine trends in exposures 11 in the license facilities and is a step in moving 12 towards a request by the National Cancer Institute for 13 a national dose registry.
14 That, in very brief terms, is some of the 15 highlights of the provision and we'll be glad to try 16 and answer any particular questions there may be on 17 the ru.le.
18 MR. FOUCHARD:
George?
19 QUESTION:
(Question off mike.)-
You're 20 reducing the exposure limit for the public and you're 21 keeping the one for workers at the same level.
I 22 mean -- reducing the one for the public because you 23 feel that the risks are greater than previously 24 thought.
Can you explain the discrepancy between O
25 those two actions there?
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DOCTOR COOL:
Okay.
Let me elaborate on 7
2 that just a little bit for you.
3 The recommendations which we're putting 4
out today are consistent with the currently published 5
ICRP recommendations, which is 100 millirem per year.
6 We are at a five rem per year.
If you look at the 7
limit which is in effect in the new rule today versus 8
what the limit was in the old rule, simply' comparing 9
limits, you will find that the limit has in fact been 10 reduced for occupational exposure.because individuals 11 could receive three rem per quarter up to a maximum 12 of 12 rem per year as long as their cumulative 13 exposure was less than five times their age.
14 So, in fact, if you want to compare limit a
15 for limit, the occupational exposure has been reduced.
16 And it's also been reduced in the sense that you now 17 are apply 1ng the five rem value to both internal and 1
18 external summed, and previously each of those were 19 limited separately.
- The five previously had only 20
-applied to external exposure.
21 But I'd like to also point out that limits 22-constitute only one part of the requ1rements.
The 23 second part of the requirements is to reduce exposure-24 as low as reasonably achievable, the ALARA program,
! Q 25 and under those provisions exposures have been reduced D
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to well below those dose-limits. The average exposure 2
of workers in the nuclear power plants is now 3
something less than 400 millirem per
- year, 4
significantly less than the dose limits, and that will.
5 be continued.
6 QUESTION:
(Question off mike.)
Just so 7
I'm clear on this, the annual limit for. workers -- is 8
what?
9 DOCTOR. COOL:
The annual limit, if I 10 wanted to add up all the possibilities, I could have 11 gotten to about 17, three rem per quarter. to a maximum 12 of 12 rem per year external plus an additional amount 13 for internal exposure.
14 QUESTION:
Someone earlier today spoke of 15 the limit as five.
I still don't understand how you 16 get 17.
You also said something about multiplying by 17 age.
Would you go over that again?
18 DOCTOR COOL:
Okay.
I will try to 19
-elaborate a little bit more.
20 We're talking'now about,old Part 20, not-21 what the Commission affirmed today.
What -is currently -
22 existing today contained a basic dose limit for 23 external exposure of five-rem per year or three rem 24 per quarter.
All right?
25 Now, there was a provisions known by its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i 1323 AHODE ISLAND AVENUE, N W.
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equation, SN-18, which said that if an. individual had 2
accumulated less exposure than five rem times his age 3
minus 18, assuming he starts at age 18 to work, that 4
he could accumulate greater than the five rem value 5
so long as he was within the three rem per quarter and 6
less than that cumulative equation, five times his age 7
minus 18.
8 So, it would be possible for an individual 9
who, say, started working at age 25 and who had not 10 had previous exposure to receive up to 12 rem per year 11 under that combination provision until such time as 12 he had reached the five times his age minus 18, SN-13 18, cap, at which point he would be effectively at 14 five because that's all that cumulative equation would 15 have allowed because we went to a strict five.
16 QUESTION:
(Question off mike.)
Why do 17 you rely on ICRP 1977 data --
18 DOCTOR COOL:
We are well aware of the 19 fact that ICRP is looking at a-revision of its 20 recommendations.
They've been considering it.
They 21 circulated rather widely in the scientific community 22 earlier this year some draft provisions that they were 23 considering.
Those revisions do not change the basic 24 framework for radjation protection which was 25 implemented in their 1977 recommendations.
One very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 734 4433 WASHINGTON, D.C. 20005 (202) 232 6600
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1 atrong reccon for going forward now is-to put that 2
framework into place so that future changes which need-3 to be made can build on that framework.
l 4
The ICPR recommendations that they are l
5 considering will not change the dose limit for members 1
6 of the public.
The ICRP considerations for
[
7 occupational. exposure have been expressed in a couple l
8 of ways over the past few months and I have not seen i
9 what their final was.-
What was being discussed,when 4
10 it was actually circulated'before would have been a 4
l.
11 limit of two rem per year averaged over periods of j
12 five-years with a maximum amount of five in any given f
13 year.
The-maximum amount of five still corresponds 14 to where our dose limit :would 'be.
(
j 15 I'd-like to remind you once again that the
}
16 limits represent simply one level and that'underneath 17 that the ALARA has to be applied, which has--reduced i
18 doses to well below.
the'
- five, well below a
i 19 recommendation of two.-
[
20 MR. FOUCHARD:
I think, Don, you ought to 21 note that the federal government.is_ gearing up for a i.
22 broad scale consideration of the new
.ICRP 1
-23 recom w 4ations.
24 DOCTOR COOL:
Yes, under the auspices of i
25 the Executive' Office of.the President, the Committee NEAL R.-GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOCE ISLAND AVENUE, N W.
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on Interagency Radiation Research and Policy 2
Coordination, CIRRPC. That group has formed a science 3
subpanel witnin the last several months to look at the 4
new recommendations and to provide a
federal-5 government consensus view on how to proceed, how to 6
implement those recommendations, recognizing that 7
ICRP, if they come out with what they have talked 8
about, will suggest an average. "That means that it=
9 might be -- there are possibilities for implementing 10 that in several different ways when you have to write 11 a regulatory limit.
See, ICRP is not b6und by having 12 to go out and inspect and enforce a licensee.
13 One of the things that we're going to have 14 to consider as we look at how to apply new 15 recommendations is what its impact is going to be on 16 overall exposures in the industry because it's one 17 thing to simply say, "I
want to reduce.any given 18 individual's exposure."
If I do that, and depending 19 on how I do that, I may in fact increase the total 20 amount of exposure in tho' population because I will 4
21 have to send two or three people in to do a job where 22 only one individual might h6ve to do it before and a 23 collective dose might actually be greater.
24 So there are a number of considerations
(~}
25 that we're going to be looking at.
That group will D
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- l e
r 1
start looking at it and will probably hold its first A
2 meeting in January.
3 One further thing that I thought of in 4
response to your question,- the federal agencies ~are 5
required to implement the guidance issued under the 6
auspices of the Environmental Protection Agency, under i
7 their federal guidance authority.
This regulation i
1 8
implements the occupational guidance which was 9
published, signed by President Reagan in 1977 and --
10
'87, excuse me and it is consistent.with the 11 current draft of the public exposure guidance which 12 is currently being circulated.
13 Yes?
14 QUESTION:
(Question off mike )
Are you 11 saying that this conformance with the ICRP 16 you've got to change this thing in order to implement 17 it - -
18 DOCTOR COOL:
There will have to be 19 changes in numbers certainly.
There will not have to 20 be changes in structure of the rule, at least I' hope 21 so.
22 QUESTION:
A change in numbers meaning 23 individuals?
24 DOCTOR COOL: I cannot predict until those 25 recommendations come out what sort of changes might NEAL R. GROSS COURT REPORTERS AND TRANSCA!DERS 1323 RHODE ISLAND AVENUE, N W-(202) 234-4433 WASHINGTON, D C 20005 '
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be necessary.
But it's certainly reasonable to 2
hypothesize that one of the things that we might need 3
or want to do for various reasons would be to reduce 4
the occupational exposure further, consistent with 5
their recommendation.
We will probably want to look 6
at weighting factors for individual organs which may A
7 require modification. There are a number r different 8
numerical things which will have to be examined, but 9
the structure of the rule based on those 10 recommendations we do not expect to have to change 11 because we - do not believe the recommendations are 12 going to change that structure.
13 Yes, sir?
14 QUESTION:
(Question off mike.)
Yes.
-I 15 wondered if you could explain why go through this 16 process of actually formulating -- regulation if it 17 could be changed in a couple of months?
Wouldn't it 18 perhaps have'been quite adequate just to wait until 19 one has -- the ICRP -- and then make it somehow-fit 20 in?
I don't understand why they have to be such 21 different -- confined differences.
Was there a need 22 to rush into this all?
23 DOCTOR COOL:
I don't believe we rushed 24 into this.
25 QUESTION:
Why go through the process in NEAL R. GROSS I
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1 o couple of months when it might be changed again?
8 2
DOCTOR COOL: This revision represents the 3
culmination of'something on the order of 12 years 4
worth of work.
S QUESTION:
Yes.
6 DOCTOR COOL:
And one side of the coin 7
would be, " Gee, it's coming out.
Why don't we wait?"
8 Then there would be something else which we could wait 9
for and there could be something else which we could i
10 wait for. You could do that more or less indefinitely 11 and never change anything.
12 Your alternative is, I have this new 13 structure.
I know the structure isn't going to remain D
14 the same in the new recommendations.
I know that we 15 are implementing reductions in the public exposure-16 level.
I know that we are putting in a new dese limit 17 to the embryo fetus.
I know.that we have reduced 18 occupational exposures from the maximum allowable and 19
-separate limitation to a single limitation.
20 The Commission believed it was appropriate 21 to go ahead and do those things now because it could 22 do them now.
It had been through the process, rather-23 than to hold up the process, wait for ICRP to come 24 out, determine how it might be implemented and start 25 the whole process-through again, through a proposed NEAL R. GROSS COURT REPCRTEAS AND TRANSORIBERS 1323 RHOOE ISLAND AVENUE. N W.
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1 1
rulo, public comm3nt, dnvelopmsnt of final rule, which 2
takes a gree.t deal of time.
3 QUESTION:
(Question off mike. ) What does 4
this mean in terms of the plant operators?
Are most 5
of them already meeting -- or will they have to do 6
something --
l 7
DOCTOR COOL:
Okay.
There will be a i
8 number of procedures record keeping sorts of systems 9
that are going to need to be modified so that the 10 reports now conform to the new rules so the 11 terminology corresponds appropriately. _In terms of 12 are there individuals out there who today are being 4
13 exposed in excess of these values and will need to be fD g
14 reduced, no, we do not believe that there are and j
15 that's a direct result of that other half of the 16 regulation.
You have limitation and you have ALARA.
17 As a
result of that
- effort, up-to this point 18 voluntary, to reduce exposures as low as. reasonably l
19 achievable, those -individuals-are not receiving 20 exposures-occupationally which are for the vast 21 majority of the individuals anywheres close to those-1 22 limits.
23 QUESTION:
Let me make sure I understand 24 this.
Workers and the general population already at p
25 plants are belleved to be exposed to less than the--
C/
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DOCTOR COOL:
Significantly less.
2 MR. FOUCHARD:
I think it's important --
3 Doctor Cool indicated that the avarage exposure to 4
nuclear pownr plant workers at the present time is 5
somewhat less than 400 millirem per year.
There has 6
been no instance in the United Statesi certainly where 7
the number 100 mr to the general public has been 1
8 reached, let alone the 500, and that includes March 9
of 1979 in Pennsylvania.
10 DOCTOR COOL:
Frank Congol, correct me if 11' I'm wrong, but the effluent data around the power 12 facilities for exposure of the public, those values 13 to maximum individuals are a
couple orders of b
i 14 magnitude less than one millirem.
Am I remembering g
15 that correctly?
8 16 MR. CONGEL: Yes. Transposed dose in well 17 under five millirem per year and as you go aEay from 18 the plant it's well under-that.-
19 DOCTOR COOL:
Lynn?
20 QUESTION:
- Don, do you know what the 21 status of NCRP's review of the soon to be released 22 ICRP recommendations, is that an important piece in 23 the equation for our federal agencies to factor into 24 the regulations also?
25 DOCTOR COOL:
The last time wo talked to O
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1 than ecvoral weeks cgo, they had held at.least one i
2 meeting.
I understood that someone was off busy I
l 3
trying to draft something.
Mr. Beckner, who is with j
4 the NCRP, had indicated that they would have something j
5 perhaps by tho end of 1991.
That wae just sort of off 6
the top of his head port of epproach.
Certainly what 1
7 NCRP decides to do pr not do in terms of the 8
recommendations that it makee hero in the United 1
l 9
States will have to be taken into account by not only 10 the NRC but by all of the federal agencies that are J
11 involved in radiation protection.
One of the things 12 that the CIRRPC Committee will be looking at is those l
13 recommendations or what we can learn about those
{
14 recommendations as well as what we can learn about the
)
15 ICRP recommendations.
16 Ms. Duriga?
4 17 QUESTION:
(Question off mike.): Why aro 18 you increasing the concentrations of radioactivity 19 to -- near water for workers of the public?
Although 20 the rems are staying the same or going down, you know l
21 radioactivity is going up.
22 DOCTOR-COOL:
For those who are not 23 familiar with the structure of the rule, what Ms.
i 24 Duriga was referring to is the values in the Appendix 25 B of the rule which are values published which are, NEAL R. GROSS COURT REPOf t. ERS Abf3 TRANSCA10ERS 1323 RHODE l R AND AVENUE, N W m 2WG WASHING!ON D C 20005 (32) P32-6600 j
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hy d9sigt, sciatifically carresponding to whatever
(~~N 2
tN2 dose limit in the rule is.
3 The revised Part 20 which was affirmed 4
today contains revised calculated values which 5
correspond to the dose limite.
B6cause of what we 6
have learned in the intervening past 30 years with 7
regard to metabolism and dosimetry of those 1
8 radionuclides, some of those v31ues went up, some of 9
them staye,d the s ame, some of them went dqwn.
They 10 were calculated so that they woul6, in fact, still 11 represent a value corresponding to the dose limit.
12 QUEST. ION:
(Question off mike. )
First of I.3 all,1 was goint) to ask the opposite of -- why did it
.f3
'v' 14 take so long?
How do you intend to enforce the 15 incond pr7ng of this, which is the ALAFJC 16 DOCTOR CO9L:
Okay.
Let me see if I can H
17 anmur.
Why did it te.ke so long?
The process of 18 attempting to talte what ore recomre~ndations written 19 by the
- ICRP, which do not really consider 20 implementation or enforceaunt to something which we 1
21 '
can, in Ee.ct, iruplement en1 enforce han taken a long 22 time because of a raumber of considerations.
There was l
23 a,n advanced notice which was put out which we received 24L !
a great deal of ccmment on.
We spent a great deal of
{')
25 tima, and this is back in the mid-1980s, developing t
v NEAL R. GROSS i
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1 22 arulewithwideinp]utfromvariousindustrygroups 1
2 and other groups, concern groups with regard to what 6
1 3
the provision should look like and how practical wara 4
the provisions that we were considering.
5 The proposed rule that resulted from that 6
was published in 1986.
The comment period on it, just 7
the comment period itself, was open for nearly three~
8 quarters of a year.
The revised requirements then 9
were put together by the staff, once again going 10 through all those comment letters. We had 830 comment 11 letters.
The stack was a rather large stack of paper 12 because several of the letters were several inches 13 thick of various and sundry comments and documents 14 that were provided.
Those were all gone through by 15 the staff and looked at in considering what the final l
16 rule would be.
17 Those were then provided to the 18 Commission. The Commission asked some questions, some 19 very good questions, which required us to go back and 20 explain, look at some particule impacts, how this 21 might be implemented and that required some additional 22 time.
23 It's never an easy there's never a 24 single or easy reason as to.why something takes a 25 relatively long period of time.
This represents, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) p g WASHINGTON. D C 2000$
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23 I
believe, the best answer is a very deliberative and 2
careful process to try and implement it in a way that 3
we can, in fact, implement it and enforce it and look 4
at it.
5 Enforcement on the second prong, ALARA.
6 ALARA is, by its natur@,
as low as reasonable 7
achievable, a philosophical concept.
What may be in 8
one situation this as low as reasonably achievable do'se 9
may not be the as low as reasonably achievable dore 10 in the other situation.
That is why the requirement 11 contained in the new Part 20 is for licensees to have 12 in piece the mechanism, procedures and engineering 13 controls to control doses to as low as reasonably 14 achievable rather than a requirement that the doses 15 theuselves be as low as reasonably achievable.
16 By having the requirement be that they 17 have in place the structure, the procedures, t
18 engineering
- controls, we can go in and we can 19 determine whether they have that structure, whether 20 they have the procedures, whether they have the 21 engineering controls, whether they are reviewing on 22 appropriate periodic basis the doses and their 23 facilities, whether ' they are implementing actions 24 where they find that doses can be reduced.
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vioistion.
i 2
QUESTION:
(Question off mike.)
Is that 3
going to be done --
4 DOCTOR COOL:
That will be done through 5
the routine inspection and enforcement proceduren 6
which we already have in place.
We already -- our 7
inspectors go in and look at licensee's programs,. look 8
at various records which they are required to' keep, 9
look at the minutes and. results of meetings of 10 radiation safety committees and thosa sorts of things.
11 What this is providing, it is providing a handle, if 12 you will, a firm handle to actually look at that 13 particular area and to cito and enforce against it,
(
14 if necessary, where previously you only had in Part 15 20 that they should.
It was not a citeable provision.
16 Now there is a
mechanism to cite under that 17 procedure.
18 Yes, sir?
19 '
QUESTION 1 (Question off mike. ) Would you 20 mind putting these -- into some kind of context for 21 everyday life, aside from rems and millirems? I mean, 22 could you perhaps give us what the equivalent is for 23 somebody, for a member of the public or somecae who's 24 a worker in a nuclear power plant or something like
,p 25 that just so that it means something in their daily v
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11voo?
2 DOCTOR COOL:
Okay.
Without trying to do l
3 a whole lot of mathematics in my head, which I will 4
undoubtedly get wrcng --
5 QUESTION:
(Question off mike.)
This is 6
just -- scientific journal.
7 DOCTOR COOL:
The dose conversion factor, 8
which the Commission is now using, is a conversion j
9 factor of 5x10** effects per a rem of radiation.
10 That's five in 10,000 per a ram of radiation, five 11 chances in that 10,000 thct if you got one rem that 12 you would have an induced fatal cancer.
Now, you can 13 multiply that by whatever dose number, the five rem k
14 value, the 100 millirem value, the ALARA values where 15 workers are actually being exposed at less than
.4 l
16 rem, the individuals around the power plants which tre 17 less than five millirem, and come up with some sort 18 of estiinate of fatal cancer exposures.
19 Is that the sort of thing.you're looking 20 for or --
21 OUESTION:
(Question off mike.)
Oh,-no, 22 I'm thinking id terms of -- chest x-rays, something i
23 like that.
24 DOCTOR COOL: Okay. Something that we put 25 out in a press conference a little while ago, the-NEAL R. GROSS COUNT REPORTERS AND TRANSCf 'EEAS '
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National Council on RCdiction Prottetion Cnd 2
Measurements had issued a report on what natural 3
background currently is the United States.
They 4
estimated that an average person in the United States 5
received about one millirem per day as a total of 6
natural background.
The average of medical exposures 7
and various things like that, one millirem per day or 8
about 360 millirem per year as an average exposure to 9
an average individual in the United States.
10 QUESTION:
That's through what, sunlight?
11 DOCTOR COOL:
That's all of those sorts L
12 of things, cosmic radiation coming in from sunlight, 13 the natural radioactive material which is in the
,o 14 ground, in the bricks, radon gas in the air, natural 15 potassium and tritium which is contained in your body, 16 all of those various sorts of things.
17 MR. FOUCHARD:
You might point out there l
18 are variations in natural background also.
It's 1
19 different in Denver than it is in --
l 20 DOCTOR _ COOL:
Considerable variations.
21 QUESTION:
So, one assumes that these l
22 limits are then over and above this?
I l
23 DOCTOR COOL:
That's correct.
l l
24 QUESTION:
(Question off mike.)
(~~N 25 Considering that the average person is getting three
, V l
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docco --
2 DOCTOR COOL:
That's correct.
3 QUESTION:
You had said that licensees 4
have until-January lat. 1993 to come into compliance j
5 with this.
You also mentioned something about 1994.
6 DOCTOR COOL:
Okay.
7 QUESTION:
(Question off mike. ) Could you 8
clarify that?
Also, what would be the pinalties for 9
noncompliance?
10 DOCTOR COOL:
All right.
The NRC has, 11 under its Atsmio Energy Act authority, entered' into 12 what are known as agreements with a number of states 13 where by the states have the authority to regulate 14 some source byproduct materials.
Under those 15 agreements, they have comparable regulations to that 16 of the Commission.
Those states will have until 17 January 1st, 1994 to conform their regulations with 18 this new regulation.
19 QUESTION:
So they get an extra year.
l 20 DOCTOR COOL:
So they get an extra year.
21 QUESTION: How many such states are there?
22 DOCTOR COOL:
There are 20 agreement 23 states.
There are a number of procedural rationale 24-for allowing them that amount of time.
Some of the 25 states have their regulations actually codified in the NEAL R. GROSS COURT REPORTERS AND TRANSCRtBERS.
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8 1
lcgicictura cnd it rcquirca o 1cgiolctiva voto.
Som3 2
states have legislatures which meeting only overy 3
other year.
So, for those sorts of reasons, the 4
Commission chose to provide them with what has been 5
the standing practice of three years to bring their 6
regulations into conformance.
7 I believe you had a question.
8 OUESTIOli:
Which industrics, if any, face 9
major changes in their manufacturing processes or 10 their work practices in order to meet any lower limits 11 that you may have?
12 DOCTOR COOL:
Okay.
There is one group 13 perhaps that faces the greatest chance of having to n
(
14 change their procedures.
That is the uranium fuel 15 fabrication industry, that set of plants which is 16 making the uranium dioxide and fabricating the fuel 17 rods for the nuclear power reactors.
18 One of the things that has happened in 19 this revision, in the occupational exposure, is that 20 the values for insoluble uranium have come down by a 21 factor of six.
That's one of the ones that came down 22 and came down significantly. As a result, individuals 23 who used to be at, say, ten percent of the limit are 24 now much more close to the limit and those facilities p
25 may need to make some modifications on their l
G NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j
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production lines to account for these changes and to 2
be able to assure and be able to demonstrate that 3
they're in compliance with the limit.
4 They may also, in addition to looking at 5
changes to their system, look at how the model which 6
relates an amount of radioactive material to a dose actually compares to the assumptions which are in P)Virt 7
)
8 20, one of the things that has to be recognized.
The 9
limit is in terms of dose.
The concentration values 10 which are presented in the table makes some 11 assumptions about the particle
- size, about how 12 radioactive material behaves in the body.
Those are 13 based on what has been called a standard man.
It may, 14 in fact, not be a good representation for what's 15 actually occurring in a facility.
16 So, one of the options that a licensee 17 like that would have would be to look at those la assumptions and to determine whether or not there is 19 a more appropriate value which still corresponds to 20 the same dose limit.
21 QUESTION:
Did you say they can petition 22 you or something to kind of -- in other words, if they 23 do a different dose assessment they may be able to--
24 DOCTOR COOL:
The rule provides that they 25 O.
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u00 th m upon approval of the Commission.
They would l
2 have to come to the Commission for approval before 3
they could use those modified parameters.
4 QUESTION:
So, they can get a special 5
exemption?
6 DOCTOR COOL:
They could get a special E
i 7
exemption.
8 Yes, sir?
9 QUESTION:
Is this going to affect the 10 clean-up of the nuclear weapons plants? Are there any j
11 chnges in here that impact on that process?
12 DOCTOR COOL:
I really can't answer what 13 the Department of Energy will do.
The Department of 14 Energy is looking at trying to implement the federal 15 guidance just as we are implementing the federal 16 guidance with this.
This does not affect cleanup 17 standards in terms of an environmental standard amount 18 of material on the ground.
19 MR. FOUCHARD:
Actually though, the i
20 well, part 20 applies only to the licensed industry, l
21 traditionally government facilities have --
22 QUESTION: This doesn't really apply th n.
i t
23 MR. FOUCHARD:
It' does not apply to Rocky 24 Flats.
It does not-apply to Fernald.
p 25 QUESTION:
Is there an average in nuclear
%J NEAL R. GROSS COURT REPORTERS AND TRANSORIBERS 1323 RHODE ISLAND AVENUE, N W.
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.e 1
power plants for millirems per year for the workers l
8 2
who are exposed to radiation in the plants?
We have i
3 a figure for the general public of about 365 a year.
4 Is there a ballpark estimate or average for power i
5 plant workers?
i 6
DOCTOR COOL:
I'm not quite sure I-7 understand your question.
MR. FOUCHARD:
I think the answer is 400 8
9 mr a year.
Tl,'at's the number I've been talking about, i
10 QUESTION:
For power plant workers?
,{
11 DOCTOR COOL:
For power plant workers.
12 Yes, sir?
i 13 QUESTION:
(Question off mike. )
When you 5
14 talked about how long this has taken --
l l
15 DOCTOR COOL:
At the time that the rule i
16 was published as a proposed rule, the Commissioners 17 at that time asked the stLff to prepare a backfit 18 analysis and that was published during the public 19 comment period for the proposed rule and contains 20
,several options for how the rule might meet the 21 backfit analysis.
It wasn't that it didn't meet it, 22 there were several options available for how it might 23 meet -- this-particular rule.might meet the criteria t
24 of the backfit provisions which the Commission 25 operates.under.
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The Commission looked very closely and 2
very hard and had a great deal of discussion with 3
regard to how this rule compared to its criteria 4
within the backfit analysis.
5 QUESTION:
(Question off mike.)
The 6
backfit rule says something about actual benefits, 7
- right, and that this rule, as it's written, the 8
backfit analysis has something to do with possible 9
benefits or -.
10 DOCTOR COOL:
The Commission's finding, 11 and I don't have the specific wording here, was that 12 they determined that there was a substantial increase 13 in safety on the basis of the reduction in the limits.
14 They also found. that this rule was justified on 15 qualitative factors as well as the quantitative 16 factors and that that was within their lc ticular 17 purview and
- analysis, actual reductions in dose 18 limits.
19 QUESTION:
If there aren't substantial 20 changes that most industry will have to do to conform, 21 why is there a two year delay in implementation?
22 DOCTOR COOL: Let me remind you once again 23 that to the first part of the question you asked a 24 little while ago I said that there would be a number l
25 of procedural
- changes, record keeping
- changes, L
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1 formatting changes.
There may need to be computer 2
code modifications so that the records come out in the 3
proper form or are expressed in the proper way. There i
4 may need to be changes to procedures.
Certainly a 5
reduction from 25 to 10 percent in terms of the 6
monitoring level may require 'some changes for some 7
individuals.
8 So, as a
result of those procedural 9
necessities to ellow people time to look at the rule
^
10 and to implement it properly in terms of procedures, 11 they are allowed until January 1, 1993 to come into 12 compliance with the ru]e.
They may implement it 13 earlier if they so choose.-
If they choose - to 14 implement it' earlier, they must impisment it in its
-15 er,tirety.
It cannot be-implemented in ' a piecemeal 16 fathion.
17 QUESTION:
(Question off mike.)
And on 18 the ALARA issue, even though it's been recommended -
19
- is there any sense from your inspectors as to what 20 percentage of the plants are not using the -- as the.
i 21-lowest reasonable achievable --
I i
22 DOCTOR COOL-I do not'think that there i
23-will be av change in that.
Thd voluntary use of that 24-has been total.
25 QUESTION:
In other-
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.'e 1
recommendction h20 bcon trccted os a --
2 DOCTOR COOLt Has been treated and taken I
8
?
3 and run with quite well by the licensees.
4 Yes, sir?
5 QUESTION:
(Question off mike.)
To what 6
extent does the decision to reduce exposure levels
}
7 suggests that the previous standards were inadequate 8
and that have been allowed to be exposed to l
9 radiation levels that are now considered unacceptable?
10 DOCTOR COOLt Anytime you go through and j
11 reduce limits, you have'the implication that what you l
12 had before was not acceptable.
I don't really believe 13 that's the particular case here.
The reason 14 particularly we don't believe that's the case la that 15 the actual exposures under the rule in its totality, 16 limits and ALARA, have reduced the doses to well below i
i 17 what were the old limits or the new limits.
18 QUESTION:
So why reduce them if the old l
19 ones were adequate?
Why change?
20 DOCTOR COOL The limits have been revised F
21 to reflect the current philosophy and the current i
22 science.
But part of that philosophy continues to be 23 to produce exposures to as -low as reasonably 24 achievable below the limits and that philosophy also l
25 continues in place.
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1 Yes, ma'am?
You've been waiting very s
2 patiently.
3 QUESTION:
(Que tion off mike.)
You 4
mentioned earlier that this rule enight prompt changes 5
in procedures such as having two or three corkers 6
do -- that previously would have taken less people.
7 Do you have any estimate of how' much rule change is 8
going to cost the industry?
9 DOCTOR COOL:
There have been various 10 estimates that have been made.
I tnink it would be 11 a complete crystal ball estimate if I were to try and 12 guess today what the actual cost would be.
So, I will 13 not.
14 QUESTION:
(Question off mike.)
Has the 15 industry not given any --
16 DOCTOR COOL:
They have complained at 17 various times.
Sometimes they'v.
ecluded ground s
18 numbers, sometimes they haven't.
19 MR. FOUCHARD:
How about one more, Dave?.
20 DOCTOR COOL:
Yes, sir?
21 QUESTION: I don't understand then how you 22 can do a cost benefit analysis.
23 DOCTOR COOL:
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package which I believe, Joe, is publicly available 2
at this point?
3 MR. FOUCHARD: Well, you can get it in the 4
public document room this afternoon.
5 QUESTION:
Dut they were in dollar 6
figures?
7
)
DOCTOR COOL There were dollar figures 8
estimated, yes.
I'm just not prepared today to try 9
and quote to you for different types of facilities.
10 Of course, the dollar being
- changed, what they 11 actually have to spend may be somehow different from 12 what they may have implied a year or two ago.
13 MR. FOUCHARD:
One last one.
Go ahead, 14 ma'am.
15 QUESTION:
(Question off mike. )
Okay.
16 I want to know if ALARA only applies to rem doses or 17 whether it applies also to the actual amount of 18 radioactivity.
You're increasing the amount of 19 radioactivity -- that can go out, even though your 20 rems are calculating that this is the same or less, 21 the biological damage.
You're actually allowing more 22 strontium, cesium, iodine into some of the air and 23 waterways.
How does this comply with your philosophy 24 of as low as reasonably achievable if you're already D
25 achieving levels that are lower and now you're raising (O
1 L
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the amount of radioactivity?
How does that comply 8
2 with AIARA?
3 DOCTOR COOL:
- AIARA, that philosophy 4
applies to all of those provisions, including that 5
licensees should limit their effluence to as low as 6
reasonably achievable.
The values in the public 7
exposure arena in general have gone down to some 8
extent.
I'm not prepared to, and I don't think it 9
would be appropriate for us to try and debate numbers.
10 1 think the gist of the question that you asked right 11 at the beginning was does AIARA apply to those values 12 as well as the dose limits and the answer is yes, it 13 does.
14 QUESTION:
(Question off mike. )
No, does 15 the AIARA apply to what the NRC's limits'are?. You've 16 got concentrations in Appendix B that are now higher 17 than your past Appendix B.
So, you're going to go i
18 higher -- the ones that are in existence are already 19 reasonably achievable tl an from what you've been using i
20 for decades.
So now you're having higher.
21 concentration levels.
Why raise.the ceiling if your 22 philosophy is ALARA?
Why not just leave it the same 23 and for the ones that reduce, reduce?
Why are you 24 raising some amounts of radioactivity and you're 25 putting it through these equations to say the rems are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
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comething cico?
2 DOCTOR COOL:
Yes.
I think you're 3
confusing the two halves of the regulatory framework.
4 One is a limit and the values are calculated to 5
correspond to a limit, by whatever the mechanism is.
6 Separate from that, ALARA applies below the limit, has 7
applied and continues to apply.
8 QUESTION:
Well, it doesn't apply to the 9
limit itself.
10 DOCTOR COOL:
It doesn't apply to the 11 limit.. It applies to what must be achieved underneath 12 that limit.
13 QUESTION:
I understand.
Thank you.
i 14 MR. FOUCHARDt I think it's fair -- I'll 15 make the last comment and that is that anybody who was 16 nearing these limits would be in trouble w1th us.
17 (Whereupon, at 11802 a.m.,
the above-18 entitled matter was concluded.)
19 20 21 22 23 24
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count nemntEns ANDinANsenietns 1323 RHODE ISLAND AVENUE, N W.
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)
,s. u S CERTIFICATE OF TRANSCRIBER 9
This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
l TITLE OF MEETING: NEWS' MEDIA BRIEFING ON FINAL RULE 10 CFR PART 20 FLACE OF MEETING: ROCKVILLE. MARYLAhT DATE OF MEETING:
DECEMBER 13, 1990 were transcribed'by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
1A uo
(
Reporter's namet Peter Lynch I
6 l
[
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