ML20042C776
| ML20042C776 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20037D485 | List: |
| References | |
| FOIA-92-436, TASK-PINV, TASK-SE SECY-83-426, NUDOCS 8310310189 | |
| Download: ML20042C776 (3) | |
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" 428 October 18, 1983 POLICY ISSUE The Com(issionersNotation Vote)
For:
From:
William J. Dircks Executive Director for Operations
Subject:
GENERIC HEALTH EFFECTS RULEMAKING
Purpose:
To respond to the Commission's request for a proposed rule that addresses the health risk of low-level ionizing radiation under nomal LWR operation where Appendix I of 10 CFR Part 50 design objectives are met.
Background:
SECY-81-208, dated April 1, 1981, from Leonard Bickwit, Jr.
to the Comissioners addressed possible topics for generic rulemakingtoexpediteconstructionpermit(CP)andoperating
.l license (0L) proceedirigs. Following Comission consideration of SECY-81-208, a memorandum from Chilk to Dircks, dated April 16, 1981, requested generic rulemaking to eliminate consideration of health effects under normal operation where design objective doses of Appendix I to 10 CFR 50 are met.
In SECY-81-471 the NRR staff responded by recommending that the Comission not proceed with this generic rulemaking on the health risks because more time and effort would go into developing and promulgating the rule than would be l
required to respond to the validity of health risk estimators in the few hearings in which the subject would be introduced.
OPE's analysis of SECY-81-471 while agreeing that the rulemaking approach would likely involve a net increase in NRC resource j
expenditure over the next few years, argued that the paper failed to consider factors such as the likely impact on the resources of industry and intervening parties. which when added to NRC resource expenditures for case-by-case litigation of health effects tipped the balance toward resolving the issue by a generic rulemaking. The Comission accepted OPE's analysis and disapproved the recommendation of SECY-81-471.
A memorandum from Chilk to Dircks dated September 29, 1981 transmitted this Comission decision to the staff and requested that RES prepare a proposed rule on the health risks of low-level ionizing radiation from LWR's under nomal operating conditions.
Contact:
Jerome S. Puskin, RES 42-74564
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The Comissioners.
Discussion:
Since then RES has considered a number of rulemaking alternatives in concert with NRR, ELD, and OGC, giving particular attention to the form such a rule might take. These options included a
" methodology rule" that would prescribe the methodology to be used for estimating health effects in NEPA documents, an
" envelope rule" that would encompass the health impacts from any conceivable reactor site, and a " giant leap rule" that would state that radiological environmental impacts need not be considered in NEPA statements if the proposed facility falls within a defined design norm. Also suggested was a table of health estimates instead.of a. generic rule.
In trying to identify a favored option, RES staff explored with NRR how the rule might be used in future CP and OL licensing proceedings so as to limit debate on health effects issues.
No favored option emerged from these discussions.
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In the meanwhile a major effort relative to the Atomic Bomb Survivor studies'is underway in both the U.S. and Japan to l
reanalyze the dosimetry and the estimated doses received by l
the survivor population.
In addition, further follow-up of the bomb survivors is providing important new insights into the types of cancers induced by radiation and the total number l
of cancers produced by a given population exposure.
In light of these developments, the risk estimates derived by national and international organizations (e.g., those in the National Research Council's BEIR III report) may be substantially modified in the next.few years.
While we believe it is highly unlikely that the Appendix I limits would have to be changed in light of this reevaluation, any generic health effects rule likely would have to be fine-tuned in order to deal with the uncertainties associated with the health risk estimates.
Recommendation:
Because of the factors stated above and the limited availability of qualified staff, it is recommended that the preparation of a generic rule defining health risks of low-level ionizing radiation under nonnal reactor operation be deferred indefinitely.
Alternatively, the l
Commission might wish to consider cancelling this action.
A William J. Dircks Executive Director. for Operations
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3-Commissioners comments or consent should be provided directly to the. Office of the Secretary by c.o.b. Thursday, November 3; 1983.
Commission Staff-Office comments,-if any, should be submitted to the Commissioners _NLT Thursday, October 27, 1983,jwith an-information copy to the' Office of;the-Secretary... If'the paper is'of.such a nature that.it. requires additional; time for. analytical' review and comment, - the Crumni ssioners and -the i
Secretariat should be > apprised of-when. comments may be expected.-
4 DISTRIBUTION:
Commissioners OGC OPE OCA OIA.
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