ML20033F843
| ML20033F843 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1988 |
| From: | Ryan Alexander NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Harold Denton NRC |
| Shared Package | |
| ML20033D930 | List: |
| References | |
| NUDOCS 9004030242 | |
| Download: ML20033F843 (4) | |
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L DATE:
September 13, 1988 To:
Mr. Harold R. Denton FROM:
R. E. Alexander SUBJ: Collective Dose Criterion for the BRC Policy Statement The staff is proposing two numerical criteria for application of the BRC policy:
(1) an annual dose of 10 mrems to the maximally exposed individual, and (2) an annual collective dose of 100 personrems.
These would apply to each exempted practice.
Thus, if a given population were to be exposed to four exempt practices, the most highly exposed individuals '
would be allowed to receive 40 mrems/y, and the entire population could receive 400 personrems.
The purpose of this memorandum is to point out that the collective dose criterion would impose the ALARA concept on individual doses that are already less than the 10 mrems/y BRC level, and would thereby defeat the major BRC objective which is to truncate govern-mental implementation of the ALARA concept.
Regulatory control is achieved by establishing a dose limit with an associated risk considerably higher than is acceptable.
For example, 5 rems /y for workers is associated with a f atality risk near 5%.
Then the ALARA concept is imposed to maintain tN average individual dose at an acceptable level for the worker populatts..
For example, the average'in the nuclear power industry is about 0.4 rem /y.
(This average could have been achieved using a collective dose limit, but such a limit was unnecessary.)
In this manner the limit and the ALARA concept work together to maintain acceptably safe conditions while providing - for necessary operational flexibility. For the population, a dose distribution exists in which few, if any, workers are exposed at the limit and the average is near 10% of the limit.
The same system is applicable to protection of the public, although a lower dose limit is imposed to account (1) for more radiosensitive individuals, (2) for the fact that much less opportunity for control exists, (3) for the involuntary nature of public exposure, and (4) for the much larger number of exposed individuals. The staff is proposing a limit of 100 mrems/y in the major revision of 10 CFR Part 20.
The ALARA concept would be implemented to maintain the average individual dose at an acceptable level.
At such low doses the principal contribution of the ALARA concept is to manage the problem of exposure from multiple practices under the control of dif ferent operators.
(The limit itself is only'1/3 of average annual dose from nature.)
Thus, the EPA uses an annual dose limit of 25 mrems for specific practices.
This is equivalent to assuming exposure to four practices.
9004030242 900316 PDR ORG NGPZ PDC
Mr. H:r21d R. Denton September 13, 1988 Page_2 The problem that the BRC policy is intended to address is that NRC; implementation of the ALARA concept has gone too f ar.
For example, the average individual dose (from effluents) to the 100 million people who live within 50 miles of a nuclear power plant is 7 microrems/y.
Ten percent of 25 mrems/y would be closer to 3 mrems/y. Maintaining 7 microrems/y is very expensive, and the BRC idea is to truncate NRC implementation of the ALARA concept at.some appropriate level, leaving any further ALARA implementation on an entirely voluntary basis.
If the Commission adopts the 100-personrem collective dose criterion proposed ~by the staff, the BRC purpose will be defeated, as shown below.
The collective dose is obtained when the average individual dose is multiplied by the number of people exposed. Therefore, when a collective dose limit is established for a population, an average individual dose I
limit is established as well.
For example, consider the 100 million people l
who live in the vicinity of a nuclear power plant.
If their collective dose (now about 700 personrems/y) had to be limited to 100 personrems/y to achieve exempt status, it would be necessary to reduce the average individual dose to 1 microrem/y.
There would be no regulatory relief or cost reduction opportunity in this application as a result of the Commission's BRC policy.
In fact, the policy would perpetuate into the design of any.new generation of plants a cost that is not commensurate with the risk, if any. The percentage increase in the spontaneous cancer death 50 miles of a nuclear power plant would rate among those who live withg% if the collective doses were limited to theoretically be about 2 x 10 100 personrems/y f rom plant operations.
This is a factor of about 5000
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below the conunission's safety goal.
Commensuration between cost and the theoretical risk is achievable through simple implementation of the Commission's safety goal, i.e.,
l through a BRC level in the range of 10-20 mrems/y per practice for the l
maximally exposed individual, with no limitation on the collective dose.
f R. E. Alexander Special Assistant to the Director Office of Governmental and Public Affairs U. S. Nuclear Regulatory Commission
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BRIEFING F0l' COMISISS:0NER= CARR BY BOB ALEXANDE; AND DR. LAURISTON S. TAYLOR, HEALTH PHYSICS SOCIETY SEPTEMBER-14, 1988 AT 10 AM I.
The need'for a BRC' level h
.- A.
Costs
'i.
. Effluent control
-2.
Residual radioactivity-a.-
Lands and structures b.
. Materials and eouipmert 3.-
Surface contamination contrei
- 4..
Radioactive waste disposal a.- -Mixed wastes b.
Liquid wastes c.
Solid wastes-a 5.
Radioisotope uses l
- 6..
Competitive position in the world market--other hazards 7.
-Public misapprehension v
8.-
Unnecessary governmental intervention
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Regulatory agency costs B;.
Costs commensurate with risk?-
C.
Risks 1.
Early effects 2.
Genetic effects 3.
Cancer a.
Spontaneous b.
Epidemiology--atem bo : survivors, patients, high background areas c.
Risk coefficients d.
Extrapolation; iinear, non-threshold assumotion.
(1) Standards develop.ent, limits (2) Risk assessnent, ;LARA (i) Axioms (ii) Statistical significance
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4.
Ratiorality of tsing risk coefficients in ERC leve' selecticn Conclusion--costs are not commensurate with the risks 11... Selection of a BRC level A.
The basic c:ncept 3.
.DistinguisF from Bel:. Personal / Community Interest Conce::
C.
Technical Criteria.
la. Consistent with :urrent knowledge about radiation **sith effects, includi g full consideration of strengths 19d weaknesses in tre data base Ib. Consistent with :egree of uncertainty in desinetr;.
2.
Consistent with !.RC safety goals 3.
Reasonably conseavative with public health protect':n 4.
Sufficiently hi;* to significantly reduce unnecesst y costs and to make rema'ning costs commensurate with the 'sk 5.
Selected with fu'l attention to probabilistic cons':erations 6.
Selected indepee:ently-of regulatory implementatic-considerations 7.
Selected oa the :ssis of consensus scientific opir':n D.
Non-technical criter'.t 1.
Consistent with :urrent legislation and regulatier 2.
Defensible to.le;islators, jurors, public, other non-technical e tities.
E.
Theoretica' fatality #raction basis--take reasenable a::'on to asjure that irdividua's do not receive more then 25 rers (EDE) y from aay cre sour:e F.
Optimizatien--insuffi:ient data 3.
Statistica' significt ce basis III. Recorrendation
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NUCLEAR REGULATORY COMMISSION-W 3,, e
- ADVISORY CoMMRTEE oN NUCLEAR WASTE (t
WASHINGTON, D.C. 20066 QM, a
Septemb'er 15, 1988 g
The H' onorable. Lando W. Zech, Jr.
Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear ChairmanLZech:
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SUBJECT:
PROPOSED POLICY STATEMENT ON BELOW REGULATORY CONCERN During the' fourth meeting of the Advisory Committee on Nuclear Waste, September 13-14, 1988, we held additional discussions with the NRC staff
= elative to the development of a Proposed Commission Policy Statement on L
r Exemptions from Regulatory Control for Practices Whose Public Health and i
Safety, Impacts are.Below Regulatory Concern (BRC).
This.. topic was previously; discussed with the NRC staff during a meeting. of the ACRS i
. Subcommittee on' Waste Management on May 4,1988.
The ACNW also dis-cussed this topic with the NRC staff during.our second meeting, July l
21-22,1988, and reported to you on this subject on August 9,1988.
We L
also had the' benefit'of the document referenced.
As a result of these discussions, we offer the following' comments:
s 1.
The proposed exemption system is based on-the risks associated with
.the exposures involved, and the system, if. modified as suggested here, will be compatible with most relevant regulations and poli-cies of the NRC and 'other federal agencies, as well as those of international organizations.
2.
We urge the adoption of dose rates.up to,10,. mrem (0.1 mSv) per year to individuals a'nd annual collective doses up to 100 person-rem (1 person-Sv) as acceptable limits arising from a single exemptea practice.
Please note that this is a different use of the dose limits than is proposed in the draft Policy Statement.
Provisions should be'made to ensure. that individuals within' any population group'are.iot. exposed to any combination of exempt'ed practices that results in dose rates greater than one to two times the dose rate l imit.' Experience indicates that such occurrences should be rare.
3.
The current draft of the proposed Policy Statement is in need of extensive revision, partly to comply with the recommendations made under item 2, above.
Additional items that need to be addressed include:
Af0$!0!k &Y
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gy The Honorable Lando W. Zech, Jr.
- 2-September 15, 1988 The draft of - the ' proposed Policy Statement should clearly a.
specify 10 mrem (0.1 mSv) p'er year and 100 person-rem :(1 t
person-Sv) per year as the limits for individual and collec-4'3 tive dose rates, respectively.
The ancillary use of 'a'100 W,6 #y person-rem (1 person-SV) per year limit as a guide to the i
y necessity for' ALARA analysis should be removed (see item b,
&f;p-e10w).
c"\\e b.'
There is a need for a much c'learer statement relative to the role and -ap' plication of.the principle of " justification" in assessing ~ practices being considered for exemption.
c.
Instead of discussing dose rates at which collective dose calculations -should be truncated, it would be better to 'do a comp 1ete calculation, and include within the data a-tabulation of the number of people within each of several dose rate
- ranges, d..
The section ;iertaining to the linear nonthreshold hypothesis needs L to : be ' clarified.
One approach wouid be simply to include a brief statement that risk (cancer) estimates should be based on the assumption that the linear nonthreshold hypothesis applies and that this. approach will result in conservatism in the resulting estimates, Since its use represents a change in NRC po1 icy, the concept e.
of the-Effective Dose Equivalent should be defined within the Policy Statement.
In a similar manner, since SI units are in common usage throughout the world, all dose rates and collec-tive doses should be expressed in these units. as well as in.
the conventional units.
As-the proposed Policy Statement correctly points out, the Agree-4.
ment States will play an important role in the implementation of the proposed exemptions.
For this reason, it is important that the Statement be formally submitted to the Conference of State Radia-tion Control Program Directors for review and comment.
The resulting document, when properly revised, will represent a pio-neering effort in nuclear safety regulation, will help conserve those of a",
our. resources that are available for the control of environmental and
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public. health problems, and. should receive strong support from the e+b.d'Qg professional radiation protection' community.
We believe that the ree
proposed Policy Statement, if revised as suggested above, will serve
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The Honorable I.ando W -Zech, Jr. September 15, 1988.
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- well as a starting point for the position to' be' stated 'at the upcomin'g-internation'ai-meeting on this subject.
Sincerely..
~
/
Dade W. Moeller.
Chairman I
Reference:
Memorandum-dated September 8, 1988 from ' Bill M.
Morris, Office of Nuclear-: Regulatory. Research, NRC, to R. F. Fraley, Executive-Director, L.
- ACNW, ' transmitting Proposed Commission Policy Statement (undated)~
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