ML20033F926
| ML20033F926 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
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| NUDOCS 9004040085 | |
| Download: ML20033F926 (36) | |
Text
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Remarks By Chairman Kenneth M. Carr U.S. Nuclear Regulatory Commission at the
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Joint Meeting of the Local Chapters of the Health Physics Society I
and American Nuclear Society Falls Church, VA.
February 20, 1990 l'
L Some:in our society believe that no matter what the cost, or societal. impact, i
l there are areas of human endeavor from which all risk must be eliminated. ' The l
consumption of. food and the commercial uses of nuclear energy are, generally speaking, two such targeted activities, in these areas, if a new report comes l
out which supposeoly uncovers previously-unknown risks, an immediate campaign-g l
is. launched to eliminate the newly discovered threat--seemingly independent of -
l:
' cost. The supreme irony is1that those engaged is such activities don't think twice about climbing in their car or' hopping-on' an airplane to attend the t
summit conference at which these lof ty-issues are to be discussed.
To add'to
,the irony, the meetings may be held in smoke filled rooms over cocktails.
The risk eliminators have, of course, a quick explanation for this apparent l
---i ncons i stency.
Transportation, cigarettes, and alcohol are somehow " voluntary" risks' over which they-have absolute control.
They " choose" to travel, smokt or drink, and therefore this makes the associated risk " acceptable"--no matter how
-large it may be in relation to other commonplace activities in society. When
-it is pointed out to them that they also " choose" to turn on their light switch, and therefore must also be willing to accept the risks associated with the centralized generation of electricity, the inconsistency escapes them.
The NRC currently is contemplating a policy statement that illustrates what-I
'am talking about. The issue. is "Below Regulatory Concern" (or BRC), and it is i'
tied very closely to thinking about risk.
Quite simply, what BRC says is that there are certain activities related to the uses of nuclear materials where the L
risks are so low ~ that the activity need not be controlled by the regulator and that additional resources need not be expended to further reduce the risk from those activities. Therefore the task before us is quite clearly defined.
Those of us who believe that further risk reduction below certain low levels is unnecessary must convince the remainder of society that the tenet of "zero" or pf Ofc,.
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2 trivial risk with respect to nuclear activities as a criterion for regulation is both unrealistic and inconsistent with practically all other forms of acceptable human activity.
The task may be clearly defined, but it will be extremely difficult--especially since the opposition would appear to have a considerable head start.
Those in opposition to a BRC policy have been hard at work for the past several months..They have attacked the policy at perhaps its most vulnerable point, and certainly from the point most easily understood by the average citizen.
.They would have the American public believe that if our BRC policy is implemented, the sanitary landfiils in this country will be transformed into hazardous, unregulated nuclear waste dumps.
Nothing could be further from the truth.
Our side of the BRC story is obviously not being heard on the street yet.
Since it is the NRC's policy, we are the ones that must get out in front of the issue.
Since we haven't put the final touches on the Policy Statement as yet, it would appear to be somewhat premature to launch a counterattack..However if we. don't start soon, somewhere, we might as well pack our bags and go home.
My discussion with you tonight is an attempt to "get out in front of the issue".
In a sense I realize that I am preaching to the choir; however, the general public must have a clear understancing of what BRC is, and is not; equally important, the public must understand why implementation of a coherent BRC policy benefits society as a whole.
"Below Regulatory Concern" is the phrase that the NRC has chosen to use when referring to those activities related to the use of nuclear materials where the risk associated with the activity is sefficiently low such that the activity need not be regulated.
It is important to differentiate BRC from "de mimimis",
which implies there is no risk, or trivial risk associated with the activity.
There is a definable risk associated with BRC activities; what we are saying is that tIIe risk is sufficiently low as to warrant no additional expenditure of resources to further reduce the risk.
3 In the relatively near future, the Commission will issue the Policy Statement on BRC.
This will be a straightforward statement of how the Commission will make decisions about exemptions involving radioactive materials. This is not a new concept; the Atomic Energy Commission started making these cecisions in the 1960's by exempting certain consumer products, approving some very low level of waste disposal and defining, from a practical implementation standpoint, which materials would be regulated. The NRC continued the practice by exempting nuclear materials that posed very little hazard to the public health and safety.
The NRC is not alone in this practice--other Federal and State regulatory agencies make similar decisions on a routine basis.
For example, the Environmental Protection Agency (EPA) uses the BRC type concept when it defines hazardous waste, approves residual levels of pesticides and decides "how clean is clean enough in site cleanup. The Food and Drug Administration (FDA)
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b-9 ig 1 defines acceptable levels of potential carcinogens in processed foods and approves the use of drugs.
The NRC's motivation for formulating, and implementing, a BRC policy is no different from EPA or FDA's motivation for implementing similar programs. The gual of any regulator is to ensure that.the public is not exposed to unacceptable risks associated with the regulated activity.
In the case of the NRC, those activities include risks associated with very small quantities of nuclear materials'at decommissioned nuclear facilities, in consumer products and in radioactive waste.
Why does NRC need a BRC policy now? Why can't we just continue business as usual as we have for the past 25 years? The answer to these questions is central to the understanding of "Why BRC Now!".
Part of the impetus for the NRC to develop a BRC Policy Statement has come from Section 10 of the Low Level W6ste Amendments Act of 1985.
This act directed us to consider the merits of "...(exempting) specific radioactive waste streams from regulation...due to the presence of radionuclides...in sufficiently low concentration or quantities as to be below regulatory concern."
The NRC needs to establish a-consistent risk framework for exemption decisions.
A practice will be exempted because the risk is sufficiently low. The same risk yardstick must be applied in all cases.
I will not discuss specific-risk numbers with you-this evening--however I can assure you_that our decisions are based on risk calculations that are consistent with those recommended by the
.0EIR Committee and other expert booies.
The NRC regulates the cleanup of contaminated commercial nuclear facilities around the country.
This can be more broadly categorized as the "decomissioning issue".
We need to ensure that the funds put aside by licensees are sufficient to get the job done.
In order to do this, we must decide on how clean is clean enough; i.e., target levels for residual radioactivity must be determined. The NRC's BRC policy will establish the
' framework for those criteria.
't is important to complete this work in a timely fashion.so that the responsible parties are able to provide the necessary resources to perform the cleanup needed to satisfy the regulatory standards.
The exemption of certain consumer products that contain radioactive materials is another area that will be addressed by the BRC policy statement. There is a need to ensure that current and future exemptions of consumer products are adequate and consistent.
Same-degree of inconsistency from a risk perspective may have existed in the past when exempting certain products--this is not good regulation, and it must be avoided in the future.
There also is the issue of categorical exclusion of certain classes of products from exemption--obvious examples are toys, cosmetics, and foodstuffs.
The Comission is still evaluating the question of the advisability and need for that type of exclusion.
l Wastes that contain very low levels of radioactivity, and that need not be disposed of in licensed low level waste sites are at present the most l~
controversial of the BRC issues from the public's point of view.
There exists
4, l' a level of radioactivity in waste products which does not require regulatory control-to protect the public health and safety. Some would argue that that level-does not exist (these in essence are the "zero risk" people). Others will argue about where those levels should be set. The point is that the NRC should-exempt these very low-level radioactive wastes when it is not necessary to place them in licensed radioactive waste disposal facilities to ensure protection of,the public. -Some of these are hazardous wastes that are very slightly contaminated with radioactivity and have been termed " mixed wastes."
At present, both the NRC and EPA regulate this special category of waste. This presents both a practical and a regulatory problem resulting in inadequate capacity in the United States for treatment and disposal of mixed waste. The radioactivity in much of this waste could be considered "BRC" by the NRC in accordance with the Policy Statement under consideration.
This would partially solve the mixed waste problem by permitting treatment and disposal of a significant portion of the " mixed wastes" solely as hazardous waste in accordance with current EPA regulations.
The cost of radioactive waste disposal, and the continuing availability of these disposal facilities obviously are related issues.
However, the NRC must act on this issue in-the relatively near future to provide useful national regulatory guidance, thereby assisting State and Compact development of new disposal facilities in accordance with the Congressional milestones of 1993 and 1996.
If we are able to establish a list of things that we don't need to worry about as regulators, this would obviously give us more time to worry about--and deal with--real problems.
There is a parallel here for the BRC issue.
Both the Federal and State governments are in a budget squeeze.
Available resources need to be focused on those practices which pose a significant hazard to the public health and safety.
If certain activities are in reality "below regulatory concern"--let's not regulate those activities, it's a waste of time and resources. Current fiscal constraints and public demands for accountability mandate a focus on real--not perceived--threats.
What does all of this mean to the man in the street? What will BRC do for him?
Make no mistake about it--this is an economic issue.
Those opposed to a BRC policy would like you to believe that BRC will make the materials users and power generators richer, because they are going to be able to walk away from some costly regulations and their overall operational costs will decrease. The other side of the argument is that unnecessary regulation and ultra-conservatism in handling of wastes is expensive. The current debate over the clean air act is a case in point. The debate is not over whether we should have a clean environment, rather the debate is about how much is it going to cost--and who is going to pay.
The debate over BRC is much the same--unnecessary regulation is costly to the consumer in two ways.
First, in the cost of the services or products, and second through increased Federal and State taxes to pay for the burden of unnecessary regulation.
If it can be established that there is acceptable risk associated with a given practice, then why pay for something one doesn't need?
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- Host automobiles don't have two redundant hydraulic brake systems--although this would reduce the risk of accidents due to brake failure. Automobile manufacturers and the public have decided that the risk associated with brake failure is acceptable, The public is not demanding, and generally will not pay for, redundant brake systems. Air bags, on the other hand, can be shown to substantially reduce the risk of injury or death.
They are being placed in some new cars.. It will be interesting to see where the air bag issue heads in the coming years.
As I indicated at the start of my talk, the BRC issue is tied to risk from a regulatory perspectiva.
I have avoided the use of any numbers in my discussion this evening. The general public does not make decisions regarding risks based on numbers, but will in certain circumstances, make a judgment based on comparisons. The man in the street has no idea of the statistical risk associated with a cross-country plane trip--yet the majority of people will get on the plane without giving it a second thought--even if there had been a plane crash the night.before that killed 245 people. People will accept risk if they feel a certain f amiliarity or comfort with the practice--or--if the media has reported that an " independent" or highly respected body has found the practice to be " safe" (i.e., of an " acceptable" risk).
We already have one strike against us.
The general public isn't " comfortable" with the notion of radioactivity.
You can't see, feel or smell it, yet in l
sufficient doses it can kill you. Things nuclear conjure up visions of the mushroom cloud.
On the other hand, there are a number of benefits associated I
with the safe uses of nuclear energy with which the average person is f amiliar.
l Medical applications, smoke detectors (which are incidentally, already legally being disposed of in regular trash), and tritium exit signs are common uses of radioactive materials which most people don't question.
A well-conceived, and properly implemented BRC policy has a significant number of societal benefits associated with it.
It will permit decommissioning and cleanup of nuclear sites to levels which are environmentally acceptable.
It
- will provide increased assurance that consumer products are safe, it will help solve the growing mixed waste problem in this country.
It will reN ce the financial burden on the consumer both from the aspect of lower fees for services and a potentially lower tax burden. And finally it has the potential for improvements in medical treatment and other services that use radioactive materials by reducing unnecessary costs.
We must get the word out to the general public that a well conceived BRC policy does not pose an unacceptable level of risk, but rather produces desired benefits for society as a whole while at the same time ensuring adequate protection of public health and safety. We are going to do our best in the coming months to get out the word on the foundations for our policy--and the positive benefits which it is designed to accomplish. As I indicated earlier, it is clear that opponents are way out in front of this issue. We have a lot of catching up to do.
If you agree in principle with what you have heard tonight, please help in any way you can.
The battle ahead is a tough one, but with hard work and cooperation, I believe it can be won.
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b A LOGICAL FRAMEWORK FOR RADIATION PROTECTION STANDARDS FOR THE PUBLIC b
Robert E. Alexander
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l fi Current' Presidential guidance to Federal agencies-on radiation protection of the public was issued 27 years ago and.will'probably continue in effect for several. years.
4 However, a Federal _ interagency committee has been formed under the lead of-the EPA to prepare new guidance. Meetings of this committee have indicated the need for a logical framework within which the committee's ~
> deliberations'can proceed. A framework of this nature is now under consideration and'is described in this paper.
It is.~ assumed for the various sources of public~ exposure subject to governmental control that the probability
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of any person being exposed at.the prescribed limit.to more than four of these
~
sources is vanishingly small. Thus if the-annual effective dose equivalent i
limit forLindividuals.is X from the combined sources, limits established for individual-sources cannot exceed X/4. Since X/4 will be small as compared with the 0.5 rem / year -limit given-in the current Federal guidance, a problem arises
'I
'with regard to protection limits for adults who work in the vicinity.of restricted' areas but are not employed in work causing exposure to radiation, 1.e., incidentally exposed workers. An annual limit of 5 X is proposed for them to avoid; unnecessary training and monitoring.
The annual limit for trained and monitored workers in restricted areas.is 50 X.
The framework includes consideration of both individual and collective
. r i s k s'.
The acceptable annual risk level for individuals is designated L
_-(equivalent-to X), and risks exceeding L from all controlled sources combined
'are not permitted.
Between L and the upper bound for each source lies a range
~
L in which individual risks' from all sources combined are permitted, but because.
of the ALARA concept the number of individuals receiving L approaches zero.
i i
Risk levels Below Regulatory Concern (BRC) are established for individuals (BRCI) and for populations (BRCP); these levels are apolicable to each source.
In the risk level range between BRC1/BRCP. and the upper bound for each source
($ L/4), ALARA (optimization) methods are required for each source to control the overall collective r sk.
This control is accomplished by maintaining the i
average individual risk 1 0.1 L from all sources combined.
Thus there would exist a limit L for ir iduals from exposure to all sources combined, below which a dose distribut.wn curve would exist.
The curve woeld be shaped by the AtARA concept to assure an average individual dose not exceeding 0.1 t from the s
comoined sources.
The framework also considers very low risk levels that are below personal interect (BP!) and below community interest (BCI). Between the BRC1/BRCP and BPl/BC1 risk levels a range lies in which individual and collective risk control is voluntary since governmental interference cannot be justified.
- c A LOGICAL' FRAMEWORK FOR RADIATION PROTECTION-
' STANDARDS FOR-THE PUBLIC In 1960 President Eisenhower signed the first guidance to Federal agencies on l
~ the~ subject of radiation protection.
The guidance was brief, but it established s'tandards of protection 'for both workers' and for members of the :
public..The standards for workers endured until January 20, 1987, when President Reagan signed into effect new guidance adopting the current recommendations of the International Commission on Radiological Protection t
(ICRP).
The guidance _ for protection of the public remains in ef fect, but is little~used. 'It provides a dose equivalent limit of 0.5 rem per year (whole body) for individuals and adopts annual average concentrations (or intake limits) for air'and water as published by the ICRP in 1959 (as well as The-by the National Council on Radiation Protect-ion ano Measurements, NCRP).
ICRP " standard man", in equilibrium with one of these Maximum Permissible Cencentrations (MPC's), would receive to the critical (or maximally exposed)
. organ an annual dose equivalent of 3.0 rems, thyroid, or 3.0 rems, mineral bone, or 0.5 rems, gonads, or 0.5 rems, if total body is critical organ, or 1.5 rems, any other organ l
Since these limits 4-depending on the radionuclide or mixture of radionuclides.
I
-are not reduced if exposure to external sources of radiation occurs, 0.5 rem
,1 When a must be added to each one to obtain the total allowed for the organ.
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O radionuclidefenters the bloodstream, a fraction ofLit is not deposited in the L
. critical organ.
The' risk from this fraction was not considered in the s' e[
' calculation of the MPC's.
For any nuclide that does not achieve-equilibrium 7
within 50 exposure years, the MPC is calculated such that the annual dose equivalent to the critical organ at the end of 50 years would be equal to the annual-limit for that' organ (not including the external dose contribution).
7 The importance of this discourse on the old guidance is that it is in effect-today and will probably continue to be for several years.
The Nuclear Regulatory Commission (NRC) is an independent agency, but like its predecessor, the.AEC, has considered Presidential guidance to be binding.
It is interesting to note how the guidance for public protection is actually used' by the NRC.
Title 10, Code of Federal Regulations, Part 20, states that, with respect to the exposure of individuals in unrestricted areas, a license will be Issued if no individual will. receive an annual dose equivalent greater than 500 millirems from external radiation sources.
Dose rates in unrestricted areas are limited to 2 millirems in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and to 100 millirems in any 7 consecutive days.
Regarding internal exposures, the MPC's calculated as described above are applied to effluents.
Thus 10 CFR Part-20 d3es not establish dose limits I
for members of the public.
The regulation does state that such exposures should be maintained as low as is reasonably achievable (ALARA), and this hortatory statement is implemented as described below.
A regulation issued by the Environmental Protection Agency (EPA), 40 CFR Part 190, established annual dose equivalent limits of 25 millirems to the whole body and organs other than the thyroid; the thyroid limit is 75 millirems.
This regulation, which is applicable to effluents and external 2
- - x
. radiation from uranium fuel cycle facilities, is adopted by reference in-10 CFR Part 20.'-
Another EPA regulation, 40 CFR Part 61, is based on the Clean Air Act and applies to all NRC licensees not otherwise covered by EPA regulations..This regulation establishes annual dose equivalent limits of 25 millirems to the whole body and 75 millirems to the thyroid.
Thus, for individuals in unrestricted areas,10 CFR Part 20 is limiting only for a,queous ef fluents f rom non-fuel-cycle f acilities such as radiopharmaceutical plants and medical institutions.- For effluents from nuclear power plants, Appendix I of 10 CFR Part 50 establishes annual whole body and thyroid dose equivalent design objectives lower than the EPA limits, and controls still more restrictive are imposed in license conditions.
It is evident that 10 CFR Part 20 has a minor role in the control of exposures to members of the public from radiation and radioactive materials associated with NRC-licensed activities.
Under the old_ICRP and NCRP recommendations, i.e., under a system of dose limitation which includes an occupational whole-body limit of 5 rems per year average, along with an annual whole-body limit of 0.5 rem for members of the public, very few problems have been occasioned regarding incidentally exposed workers.
These workers normally know about their exposures and accept them voluntarily, but they do not work in restricted areas and are not monitoreo or trained with respect to radiation protection.
Their radiation exposure is entirely incidental to their work.
In the report of ICRP Committee II on permissible dose for internal radiation (1959), these workers are described as Adults who work in the vicinity of controlled areas [an ICRP reference is cited) but who are not themselves employed on work causing exposure to radiation." They are normally in good health, and post-natal children are not included in their numbers.
(Pre nat&l children, of course, are included among 3
I'.
workers without and within restricted areas.)
Incidentally exposed workers r
rarely exceed dose equivalents greater than 0.5 rem per year from sources inside restricted areas.
However, with the advent of much lower dose limits for individuals outside the restricted areas, it has become apparent that the new limits are or will be exceeded by a great many incidentally exposed workers.
If. unnecessary requirements for monitoring and training of these workers are to be avoided, it may be necessary to divide the population into three classifications, rather than the traditional two.
In the past the protection of the public from radiation has been provided by j
i various Federal and State government agencies in a relatively uncoordinated l
manner.
The EPA, NRC, 00E, 000, 00T, State agencies and others have established and enforced standards applicable within their mandated jurisdictions. The amount of attention that has been given in the adoption of these standards to the possibility that people could be exposed to multiple sources is considered by some to be inadequate. There has been a tendency to develop' specific standards, well below 500 millirems per year, on the basis of l
cost / benefit analysis that consider only the source under study.
Logic would l
seem to dictate that an acceptable level of collective risk would be established for public exposure to ionizing radiation susceptible to governmental controls, and that an appropriate fraction of this risk would then i
.be allocated to each contributing source.
Nothing of this nature has happened k
i
.yet, but the problem of exposure to multiple sources is receiving more attention.
An incomplete list of these sources appears below:
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Gaseous;and' aqueous effluents
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Direct radiation from facilities 'and equipment E
F Direct' radiation from radioactive' material: shipments t
Decommissioned lands'and structures j
' Recycled materials and equipment Radioactive material in commercial products g.
~ Radioactive waste disposal-q
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Electronic products Enhanced natural radioactivity b
. 0ther sources that may someday be considered for regulation include radon in a
s homes, and smoking,
. In consideration-of the problems discussed above a Federal interagency committee has been formed under the lead of the EPA to prepare new Federal guidance;for radiation protection of the public.
Several meetings of this l-q committee have already been held, and discussions have indicated the need for a L
logical framework within which the committee's deliberations can proceed in a systematic manner.
The balance of this paper is devoted to a framework of this nature'that has been presented to the committee and is now under consideration.
The framework presented in this paper is summarized in Figures 1 and 2.
In Figure 1 the blocks at the top represent n sources of radiation exposure of the public.
It is assumed that Presidential guidance has already established a limit L on the acceptable annual risk level for individuals, and that this level has been converted to X millirems per year effective dose equivalent (EDE)'that any individual may receive annually from the combined sources 5
- = - - - - - - - - - - - ' -. - - - -, _ _
subject to governmental control.
The effective dose equivalent quantity is used here for purposes of simplicity since it. includes the combined risk from external and internal radiation.
It is further _ assumed that the probability is vanishingly small that any individual will receive annual doses near the limit With this assumption, an upper limit of X/4 millirems from 4 different sources.
per year is established for individual sources.
The occupational limits are 5 X for incidentally exposed workers and 50 X for workers exposed under controlled conditions.
For example, if the principal value for X currently recommended by the ICRP is used, viz., 100 millirems per year EDE, the annual limit for any one source could not exceed 25 millirems EDE.
(ICRP recommendations permit 500 millirems per year EDE if the lifetime average does not exceed 100, same units.)
Incidentally exposed workers could receive annually no more than 500 millirems EDE, while-the annual limit fo-trained and monitored workers is 5 rems E0E, In Figure 2 the framework is extended to include the consideration of risks so small that governmental intervention cannot be justified -- the Below Regulatory Concern.(BRC) concept. This figure distinguishes between BRC levels for individuals, i.e., BRCI levels, and BRC levels for populations, i.e., BRCP levels.
To permit a comprehensive treatment of the subject, levels below personal interest (BPI) and levels below community interest (BCI) are included.
At BPI and BC1 levels the individual and collective risks are of no interest to For levels between BPl/BC1 and BRC1/BRCP, risks are of interest to anyone.
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L ANNUAGEFFEC11v11005EOCQUIVAt.ft(I LIMll'.
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Figure 2 FRAMEWORK FOR RADIATION PROTECTION STANDARDS FOR THE PUBLIC
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Risks to individuals exceeding L, from all controlled sources combined, are not permitted.
b ACCEPTABLE ANNUAL RISK LEVEL FOR INDIVIDUALS From all controlled sources combined, individual risks in this range are permitted.
The risk from any one source does not exceed L/4.
The probability of exposing an individual to more than 4 sources at the L/4 level is vanishingly small.
The number of individuals receiving L approaches zero.
L/4 1 2,3 5
4,5 Source g
6 Upper i
Bounds c
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.n ALARA (optimization) methods are required for each source to f
E control the collective risk, accomplished by maintaining the
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.E average individual risk 1 0.1 L.
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BRCI BRCP 5
s3 Under any conditions, Under specified conditions,
.E individual and collective individual and collective
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risk control is voluntary; risk control is voluntary; governmental interference governmental interference
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is.notjustified.
is not justified.
i BPI BCI Individual and collective risks are of no interest to anyone, f o
o BRCl - below regulatory concern for individuals BRCP - below regulatory concern for populations BPI
- below personal interest BC1
- below community interest 8
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those exposed but are too small for regulatory attention; control: is on'an.
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entirely voluntary basis.
These levels are' of great importance since their establishment could prevent ~1arge-expenditure requirements to protect against trivial risks.
There are two categories in this range:
in the first, risk' control is entirely voluntary on an unconditional basis; in the sc ond, risk
_ control is entirely voluntary but only if specified conditions are met (e.g.,
the BRCI/BRCP level _may apply only-to short-lived radionuclides).
Above the BRCI/BRCP level lies a risk range for each individual source of public exposure;_each source upper bound is 1 L/4 per year.
In these ranges the As low As Is Reasonably Achievable (ALARA) concept is invoked in p
governmental regulations (such as, e.g., the radiological criteria in 10 CFR Part 50,_ Appendix I, previously mentioned) for purposes of controlling the collective risk, as discussed subsequently.
Above the source upper bounds, a risk range appears which is acceptable for people who are exposed to more than This range is bounded by L, the limit established for the combined one source.
sources.
Above L, non-occupational risks are not permitted. -Within the ALARA ranges at least two special cases exist.
First, for a particular source the upper bound could be' equal to BRCI/BRCP, in which case the ALARA concept would not apply.
Secondly, an agency may for special reasons establish exempt items with associated risk = levels greater than BRCI/BRCP, In these cases the ALARA concept would not apply.
Such special cases can be accommodated within the logic framework.
Although an attempt has been made to keep the framework simple, a logical merging of the individual risk concept with the idea of collective risk is essential.
This problem is somewhat difficult, and the solution proposed here 9
LOGICAL FRAMEWORK
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admittedly adds complexity to the framework.
Hopefully, this complexity has been minimized.
The solution is predicated 1on the ideas expressed graphically in Figure 3.
The basic postulate is that an adequate governmental risk control program for i
radiation requires only three-elements -- a dose -limit for individuals, an average individual dose criterion.to control the collective risk, and an ALARA effort imposed to achieve the average dose criterion.
In Figure 3 two sets of dose distribution curves are shown; each set includes four sources of public exposure..In one set the ALARA concept is not employed, so that in theory the individual doses could be clustered near the limit L/4.
Since there are four sources, all of these individuals are subjected to a combined annual risk very near. L.
The average individual dose is approximately equal to the maximum.
The collective risk R may be obtained as the sum of areas under each of tne four curves.
In the other set the ALARA concept is imposed to displace the y
dose distribution curves away from L/4.
Although the maximum individual dose remains unchanged near L, the curves are reshaped suf ficiently to assure that the collective risk is 0.1 R and that-very few if any individuals are subjected to a risk near L.
Thus the average individual risk criterion is 0.1 R.
Translating these ideas into Figure 2, it is assumed that 0.1 R is equivalent to an individual average risk of 0.1 L, and this average is stated as a criterion that is to be met, in fact, the source upperbounds are not allowed to permit an average individual risk exceeding 0.1 L.
It is recognized, of course,-that in a chart representing actual situations the BRCI level would not necessarily align so conveniently with BRCP, nor the BPI level with BCI.
10 LOGICAL FRAMEWORK
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4 People who work in restricted areas are also members of the public, and this paper.would not be complete without mention of how the ICRP risk limitation system works for them.
Figure 4 indicates annual risk levels on the lef t and the corresponding ICRP annual dose criteria on the right.
The 1 X 10' /yr average.is the basic ICRP risk criterion. The theory is that the criterion is to be achieved by imposing a limit of 5 rems /yr, and implementing the ALARA concept' as necessary to achieve a 0.5 rem /yr average.
The " Acceptable Region -
No. Regulatory Involvement" showr4 in the figure is a proposal that the author has made based on personal study of the ICRP system.
The thought here is that af ter the acceptable risk region has been achieved, further implementation of the ALARA concept should be entirely voluntary, that further governmental intervention cannot'be justified.
Figures 5 and 6 indicate the theoretical effect of a successful occupational ALARA program, It is interesting to. note that the nuclear power industry has brought its average annual dose from a peak of 0.94 rem in 1973 to 0.41 rem in 1986.
This: highly simplified discussion of the occupational radiation risk limitation.
system completes the description of a logical framework for radiation
. protection of the public.
12 LOGICAL FRAMEWORK
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Figure 4.- OCCUPATIONAL RISK LIMITATION SYSTEM Risk Unacceptable Region Oose l:
Operations Prohibited by Regulation 5 rems /yr IX10'3/yr SX10 lifetime' ALARA Region Gose Reduction Required Comensurate With Proximity to Unacceptable Region Gradual Oe-emphasis as Objective Is Approached 1X10~4/yr objective 0,5 rem /yr (average) 5X10~311fetime (average)
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i o n; Documents pertaining to Miller Question 4 - Public Release 1. 7/25/88 SRM from S. Chilk to V. Stello; Briefing on the matters of common interest between NRC and EPA in the regulation of radiological hazards; 1000 a.m., Friday, July 15,1988.(For transcript of meeting with NUMARC and BRC in 1989, see Question 1 material) EPA representatives on 2. 9/22/88 Letter from Byron Lee, Jr. to Chairman Lando Zech; subject: Thanking NRC for opportunity to brief them on 9/16/88 addressing "Below Regulatory Concern" 3. 9/29/88 Staff Requirements; From S. Chilk to V. Stello, Briefing on the status of efforts to develop a Below Regulatory Concern Policy,10:00 a.m., Friday, September 16, 1988. 4. 6/26/89 Agenda of meeting held at White Flint Building in Rockville, Maryland;
Subject:
NRC-NUMARC meeting on Contents of BRC Petition 5, 5. 0/25/0^ ":n 'r^- Peu! Tur=r, L'.S. Ca"acH h" rnorgy no-ss _to ,..N.f.,A((0![! M NN.3il b N, n m.N"' 5 2 i 32 'E ....,, ~ s t u io u r vu ns u or 0. 1:/00/0^ :PRI R; pert % =.ry "P-5073; Lj;ct: Sc h.; ^ g; htery .355555_$d,5,di.,7 i..N59 j.9"N.i' ;$M,o'n.q gi,c [ m.. ........ m.,
- y. s.,
7. 2/5/90 Agenda for 2/5/90 Visit of NRC Commissioners Curtiss and Rogers to EPRI Offices in Palo Alto, California 8. Undated NUMARC Vugraphs;
Subject:
Proposed Rule on "Below Regulatory Concern" j i 9. Unlated Viewgraphs from Chairman Carr's and Zech's Heeting with l Reilly on EPA-NRC Interface issues (June 1989) i L 1 $0 $ hus el bits dehl8d 00 & Was 1 l l L
[/ h, UNITED STATES IN RESPONSE, PLEASE ),., 7 q NUCLEAR REGULATORY COMMISSION REFER T0; M880715 t W At HlWGT ON, D.C. #NM 3 +.., July 25, 1988 . OFFICE OF THE SECRETARY MEMORANDUM FOR Victor Stallo, Jr. E:tecutiveDirectorfor%erations i FROMt Samuel J. Chilk, Secre l SUBJECT STAFF REQUIREMENTS - Il ING ON MATTERS OF COMMON INTEREST BETWE TRC AND EPA IN THE REGULATION OF RADICIDGICAL HAZARDS, 10100 A.M., FRIDAY, JULY 15, 1988, COMMISSIONERS' CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCXVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE) The commission was briefed by the staff on issues of common interest between the NRC and the Environmental Protection Agency (EPA) in the regulation of radiological hazards. EPA representatives responding to Commission questions were Floyd Galpin Office of Radiation Protection James Macris Office of Solid Waste and Emergency Response The commission expressed its desire for the staff to obtain EPA's comments and concerns, 12 any, over the staff's proposed definition of below regulatory concern. The Commission requested this issue be of high priority at both the NRC and EPA. Should the staff believe that a Commission letter requesting EPA to elevate the priority of this issue is warranted, the staff should propose such a letter to the Commission. Chairman Zech requested the staff to continue its close working relationship with EPA and to keep the Commission apprised on matters before the two agencies. Where here is dual -)urisdiction between the NRC and EPA, the staff should strive to accomplish NRC's and EPA's regulatory mission without seeking legislative action. ?
f-l l i Chairman toch also requested the staff to closely interact with l the Department of Energy in the areas of mill tailing sites and high level waste. He requested the staff to be aindful of consistency among government agencies and in meeting legislative schedules. l r I cc Chairman Zech f Commissioner Roberts Commissioner Carr f Commissioner Rogers OGC GPA .PDR - Advance f DCS - P1-124 i l h f f 1 i t 5 L 7 L 1
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/ NUCLEAR REGULATORY COMMISbiCHW o REFER To: M880916A 3 W ASHING f ON, D.C. PMN t September 29, 1988 OFFCE OF THE MCRETARY MEMORANDUM FOR: Victor Stallo, Jr. Executive Director for Ope tions FRON: Samuel J. Chilk, Secret I C7
SUBJECT:
STAFF REQUIREMENTS - BRI EF 3 ON STATUS OF EFFORTS TO DEVELOP A BENW EGULATORY CONCERN POLICY, 10:00 A.M., FRIDAY, SEPTEMBER 16, 1988, COMMISSIONERS' CONFERENCE ROOM, ONE WHITE TLINT NORTM, ROCXVILLE, MARYIAND (OPEN TO PUBLIC ATTENDANCE) The commission was briefed by the staff and representatives of the Health Physics Society and NUMARC on proposed options for a Commission policy which establishes a generic radiation activity below regulatory concern. RepresentiDJ the Health Physics Society were: - Dr. Lauriston S. Taylor { Past President, Health Physics Society - Robert Alexander President, Health Physics Society I Representing NUMARC was: - Thomas Tipton Division Director, NUMARC The Commission requested the staff to raise the following issues at the International Workshop on Rules for Exemption from Regulatory Control scheduled for October 17-19, 1988. 1. The need to include a collective dose criterion and possible alternatives for evaluating societal impact. I 2. The possibility of limiting the activity of individual products as an alternative to use of a collective dose l criterion. 3. Allowing the use of radioactive materials under NRC surveillance as an alternative to exemption exclusions. h410050!!? ^ W t
.0 s c+ i 4. The extent to which exposures resulting from any practice should be justified and the process for making such a determination (a) in considering proposals for exemptions, should the Commission evaluate the social acceptability of practices? .(b) should the commission determine a practice to be + unjustified if non-radioactive alternatives exist? The commission emphasized the importance of presenting the proposed policy in terms the general public can relate to (i.e., number of additional cancer deaths expected vs. number of area). I The staff should submit a paper to the Commission summarizing the activities and conclusions reached at the International Workshop, including a revised policy statement which considers the above issues. l (EDO) (SECY Suspense: 1/27/89) The Chairman requested his fellow Commissioners to address in their vote sheets if the staff should publish the proposed l policy, SECY-88-257, for public comment prior to the International Workshop. 4 1 f I cc: Chairman Zech Commissioner Roberts i Commissioner Carr l Commissioner Rogers l OGC GPA PDR - Advance DCS - P1-124 l l -}}