ML20043B916

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Forwards Draft Commission Paper Submitted to ACNW for Formal Review & Comments
ML20043B916
Person / Time
Issue date: 09/08/1988
From: Morris B
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Fraley R
NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
Shared Package
ML20042C963 List: ... further results
References
FRN-53FR49886, RULE-PR-CHP1 NACNUCLE, NUDOCS 9006010030
Download: ML20043B916 (51)
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c5 i MSmWG TON, D. C. 30665 f-[,.((' [~J c a S..* SLP 8W B7 i MEMORANDUM FOR: R. F. Fraley, Executive Director, ACNW FROM: Bill M. Morris, Director, DRA.RES

SUBJECT:

TRANSMITTAL OF DOCUMENTATION FOR ACNW REVIEW The enclosed revised draft Comission paper is submitted to the Advisory t Comittee on Nuclear Waste (ACNW) for their formal review and coment. The l Comission paper and the enclosed proposed policy statement have been revised t to reflect the coments of both the ACNW, made in their August 9 1988 letter t to Chaiman Zech, and other coments generated as the paper proce,eded through the NRC concurrence process. The ACNW's agreement with the staff's position on " justification of practice" and " frivolous" practices has been reflected in the Comission paper together l with the ACNW's caution that considerable care should be exercised in describing L frivolous practices. In response to the ACNW's coment regarding logical presentation, the discussion in Section IV, " Principles o' Exemption", has been revised. The revision emphasizes the

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proposed policy and now defines 10 mrem per year as an individual dose criterion and 100 person-tem per year as a collective dose criterion which, l if both are met by a practice under consideration for exemption, would serve as a demonstration that ALARA has been achieved. The staff's response to other ACNW coments is included in Enclosure 6 of the Comission paper. l i Since the revised Comission paper has not been presented to the Comission, the distribution classification of this material is predecisional. I would appreciate your sending a copy of this memorandum to the Comittee members with the revised draft Comission paper. / 5<. 8 />1 # 7, M L Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research 900601oo30 e91130 ~' Y b$i$$FR49886 PDC 1

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4. _a _m,..' ~ ~ ~ ~ ~ ' ~ ja 'f OUTLINE OF PRESENTATION r BRIEF OVERVIEW OF PROPOSED POLICY AS PREVIOUSLY DESCRIBED CONSIDERATIONS UPON WHICH POLICY IS BASED GENERAL CONDITIONS OF EXEMPTION A KEY ELEMENT OF THE POLICY CURRENT PROPOSAL AS OF SEPTEMBER 13, 1988 ACTIVITY AND PROGRESS FOLLOWING JULY 1988 ACNW MEETING f 4 EFFECT ON STAFF CONCENSUS CURRENT IMPACT ON STAFF CONSENSUS (- i 1 CURRENT PROPOSAL VS. OTHER ACNW COMMENTS l RESPONSE TO ACNW COMMENTS l l l e i 2

D L;i _m. -- l j 4, CONSIDERATIONS UPON k'HICH-POLICY iS BASED o. i FUNDAMENTAL PRINCIPLES OF RADIATION PROTECTION { JUST!FICATION OF PRACTICE DOSE LIMITS TO DEFINE MAXIMUM ALLOWED RADIATION LEVELS ENHANCED PROTECTION BASED ON ALARA PRINCIPLES l LINEAR NON-THRESHOLD RELATIONSHIP BETWEEN LOW RADIATION DOSE AND STOCHASTIC CANCER RISK l RECOGNITION THAT INDIVIDUALS MAY BE EXPOSED TO RADIATION FROM MORE THAN ONE LICENSED OR EXEMPTED SOURCE l 3.

pqyr m m.< y,.. 5 -l GENERAL. CONDITIONS FOR EXEMPTION 4 4 I COSTS OF ADDITIONAL REGULATORY CONTROLS TO REDUCE INDIVIDUAL OR COLLECTIVE DOSE ARE NOT BALANCED BY THE REDUCTION IN RISK. ALTERNATELY, APPLICATION OF REGULATORY CONTROLS DOES.NOT RESULT IN A SIGNIFICANT REDUCTION IN RISK. i

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-i 1 p p 'i PROPOSED EXEMPTION POLICY SCHEMATIC i + 1000 a i t 100 Regulatory Dose Limit - For Public i _~ ALARA Cost / Benefit Analysis-Required .- R ~ ,g 10 --.~.-.-._._.q c y ,g -- ~ Exemption decision based.l -T l L ![:.f - ~ on simple justification l t ~ of practice. l; ; _, -PracticeconsideredALARAl g w/o further analysis. I' 4 1 .l-t m l i L U.S. Population

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-- j 'y CURRENT PROPOSAL 9/13/88 = I EXEMPTIONS POSSIBLE BASED ON JUSTIFICATION OF PRACTICE AND C/B ANALYSIS IF INDIVIDUAL EXPOSURES BELOW 100 MREM PER YEAR r [ EXEMPTIONS LIKELY IF PRACTICE JUSTIFIED AND ALARA DEMONSTRATED BY: INDIVIDUAL EXPOSURES EQUAL TO OR LESS THAN 10 MREM PER YEAR g e 5 AND COLLECTIVE DOSE LESS THAN 100 PERSON-REM E h OPEN APPROACH TO TRUNCATIONS OR' WEIGHTING OF COLLECTIVE kk DOSE FOR C/B ANALYSIS BASED ON PRACTICE BEING CONSIDERED 0-FOR EXEMPTION, REllANCE ON PRACTICE DEFINITION COLLECTIVE DOSE CRITERION, AND TIMELY POLICY REVIEW TO ADDRESS MULTIPLE EXPOSURE ISSUE 7

ps; g -- j p.c i.j l.' t' Msg ACTIVITY AND PROGRESS FOLLOWING JULY'1988 ACNW MEETING -r 1'. ADDRESS ACNW COMMENTS I RESPOND TO CONCERNS REGARDING: DECREASING " RIG 0R OF C/B ANALYSIS" AS INDIVIDUAL. l L DOSE FROM EXEMPT PRACTICE DECREASE NUMERICAL DOSE CRITERIA FOR DEMONSTRATION OF ALARA L CALCULATION AND USE OF COLLECTIVE DOSE ASSESSMENTS 1 l l..

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g.,g.m_m., . -j. - p-1 EFFECT ON STAFF CONSENSUS SOLIDIFICATION OF VIEWS ON JUSTIFICATION OF PRACTICE AND EXCLUSION PROVISIONS FOR FRIV0LOUS PRACTICES INCREASED EMPHASIS ON RISK FOUNDATION FOR POLICY DIVERSITY.0F VIEW ON TRUNCATIONS AND WEIGHTING OF. COLLECTIVE DOSE DIVERSITY OF OPINIONS ON HOW T0 CHARACTERIZE BROAD RANGE OF EXEMPTION POSSIBILITIES THROUGH USE OF NUMERICAL GUIDANCE = 9 -=

1 43y. .-._.e-.- A i :, L !=c CURRENT IMPACT ON STAFF CONSENSUS m DIFFERENCES IN OPINION ON INDIVIDUAL DOSE CRITERIA FOR-DEMONSTRATION OF ALARA (PREFERENCE FOR 1 MREM PER YEAR VS 10 MREM PER: YEAR) MULTIPLE EXPOSURES 9 TREND IN RISK COEFFICIENT RELATIONSHIP T0.0THER APPLICABLE INTERNATIONAL / NATIONAL VALUES 4 ) I e 10

W8 m~w ~.- - --.~.- g ' gi i: .= y o CURRENT PROPOSAL VS OTHER-ACNW COMMENTS 7 ENCLOSURE 6 IN COMMISSION PAPER c. 1 l NEED.-FOR COLLECTIVE DOSE CRITERIA WEIGHTING OF COLLECTIVE DOSE INCLUDED IN CALCULATION AND USE OPTIONS REVIEW OF PAST EXEMPTIONS TO IDENTIFY BENEFITIAL CHANGES q j IMPROVE RESPONSE TO COMMISSION QUESTIONS u I ? s i 1 1 e n 11 --

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Q46.,g_. l ~ ~ ~~^ w . /j' as; UNITED STATES l ,n NUCLEAR REGULATORY COMMISSION i$[ ADV150RY COMMITTEE ON NUCLEAR WASTE WASHINGTON, D.C 30566 Revised: September 12, 1988 5 SCHEDULE AND OUTLINE FOR DISCUSSION 4TH ACNW MEETING SEPTEMBER 13 AND 14, 1988 BETHESDA, MARYLAND ' Tuesday. September 13, 1988, Room P-114, 7920 Norfolk Avenue. Bethesda, MD 1) 8:30 - 8:40 A.M. - Chairman's Coments (0 pen) 1.1 Openingremarks(DWM) h 1.2 Itemsofcurrentinterest(DWM/RFF) ACNW Administrative and Procedural Matters (0 pen) 2) 8:40 - 10:45 A.M. Preparation of ACNW Reports (DWM/MWL) 2.1 2.2 1989 ACNW Meeting Schedule (DWM/MWL) 2.3 Procedure for NMSS Participation in ACNW Meetings (DWM/MWL)- 2.4) Staff Requirements Memo Following the First ACNW/Comission Meeting: Proposed Response (DWM/MWL) 2.5) Better Provision of Infomation to ACNW: Proposed Memo to EDO (DWM/MWL? 2.6) Distribution of Mail to ACNW (DWM/MWL). Chaiman's Meeting w)ith~ Comissioners' 2.7) Assistants (DWM/MWL SecondACNWMeetingwithCommission(DWM/MWL) 2.8 2.9 Miscellaneous Matters 10i45 - 11:00 A.M. BREAK Below Regulatory Concern (BRC) Policy Statement

3) 11:00 - 12:30 P.M.

_(0 pen)Discussion and coment on Proposed BRC Policy 1 3.1) StatementwithRESrepresentatives(OSM) 12:30 - 1:30 P.M. LUNCH 4) 1:30 - 3:00 P.M. Cement-BasedLLW(0 pen) Presentation, discussion, and connent on the 4.1) Status of the HMSS Staff's Study (SJSP) 3:00 - 3:15 P.M. BREAK

.J.. 3-awmjy, p~., 7 7 E -. 14'th'ACNWMeetingAgenda 5) 3:15 - 5:00 P.M. Status of NRC Staff Study on Pointhylene. High Integrity containers (HICS) (Upen/Glosed) NM55 s".aff will svamarize this study on HICs 8.1) anddiscussalternativerecommendations(SJSP) Note:. Portions of this session may be closed to protect proprietary information. Executive Session - Outline and-Draft Letters (0 pen) 5:00 - 5:45 P.M. Wednesday. September 14, 1988. Room P-114. 7920 Norfolk Avenue. Bethesda, MD 6). 8:30 - 8:40 A.M. Chaiman's Opening Comments ASME Letter on Regulatory Responsibility for Mixed 7) 8:40 - 10:00-A.M-Waste (0 pen) ETT NMSS Staff will present and discuss the ASME letter and.the Staff's position (OSM) 10:00 - 10:15 A.M. BREAK Low-level Waste and Decommissioning Division-(LLWDO)- ' 8) 10:15 - 12:00.N00N (Open) 5.1) FY 1989 Program for LLWDD presented by i DivisionDirector,M.Knapp(SJSP) 1 J 12:00 - 12:45.P.M. Executive Session-- Draft Letters. 12:45 - 1:45 P.M. LUNCH 9) 1:45 - 2:15 P.M. DecommissioningRule(0 pen) NM55 staff will discuss this rule (OSM) 9.1) 2:15 - 2:30 P.M. BREAK 2:30 - 4:00 P.M. Executive Session - Finish Letters l l

-,_ s _ - ^ ^ ~~ ~ ~ ^ ~^ ~~ ~ ^ ^ ^ g 37 t .4 POTENTIAL METHODS FOR IMPLEMENTATION L L -o Rulemaking which provides generic exemption to do a certain practice. Licensees would not be required to apply for a new l license or license amendment to take advantage of the exemption. i l L-o- Rulemaking which provides exemption subject to certain preconditions. Licensees wishing to use such a provision would be required to apply for a new license or license amendment for the practice, and would - be subject to certain conditions related to the exempted practice. The conditions would be specified in the regulation, o Case specific findings by the NRC staff for a particular situations and practice. The release of a facility after decounissioning is an example of such a case specific exemption. Conditions related to the' exemption would be part of the specific license amendment or termination. =, m - --- mm.

f ,P .. M4 # Wy 6 '4-# . :W t 4 .c .e; -n i LIMITS ON COLLECTIVE DDSE COUPLED WITH INDIVIDUAL DOSE THRESH 0LD' o. Collective dose serves as a measure of. population detriment as a result of a practice. The linear hypothesis suggeststhat circulative small exposurescanhavethesameimpact(statistically)aslargerexposuresto small population. A simple limitation on individual dose will not prevent population dose effects. o~ A' limitation on individuci dose, while assuring that each individual is potential, does not provide a mechanism to limit a practice's extent or duration. Thus, widespread environmental radioactivity and contamination could result. Recycle of material Discharge to oceans ~ - o Collective dose can serve, in some instances, in controlling or limiting the likelihood for multiple exposures due to exempt practices, o A policy with no collective dose limit is likely to raise concerns'in the international comunity regarding environmental contaminalton leading to exposure of their populations. o International leadership is important. If U.S. Doesn't have a limit other nations might follow. -This could lead to multiple exposures from several national practices, e.g., discharge into oceans. l

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4 NEED FOR ASSESSING IMPACT OF POLICY o

The exemption policy opens new opportunities for exposures and products. ~ The potential impact and extent of these products cannot be predicted a priori, The proposed policy is less conservative than previous positions held by o the NRC staff. Thus the staff should be examining the impact of the policy. o Over the course of time, the assumptions used in determining the validity of an exemption may not remain valid. The product may change, the market may change, major exposures pathways not predicted. QA may not remain adequate, etc.... Thus, periodic assessment is necessary to assure that granting an exemption is still valid. o The potential for multiple exposures for a critical group could be unrecognized if assessment program is not maintained..

x; i Li^ ~~~ ~ ~ ~ ^ ~ ^ ~ ~~~~[T~ ~ ~" ' ~ ^""~~ .,3 u_- C v Beckjord for propriate ActionL N )S.f*',"'% g,TA7,, _ W Signatugys:Stell' K T NUCLEAR REGULATORY COMMISSION -Taylor i n 8 y, i aovisony couwtvas ow wuctsAn wasts No e wasmwatow. o.c-asms e l-WFORMATION ROUTING ONW %w . Jordan L 1) Sep 88 Murray / CFiles -1 HES fg l L op The Honorable Lando W. Zech, Jr. Chairma" OTHER: l U.S. Nuclear Regulatory Comission Washington, D.C. 20555

Dear Chairman Zech:

SUBJECT:

PROPOSED POLICY STATEMENT ON BELOW REGULATORY CONCERN j During the fourth meeting of the Advisory Comittee on Nuclear Waste. September 13-14, 1988, we held additional discussions with the NRC staff relative to the development of a-Proposed Commission Policy Statement on L Exemptions from Regulatory control for Practices Whose Public Health and l Safety Impacts are Below Regulatory Concern (BRC). This topic was P previously -discussed-with the NRC staff during a meeting of-the ACRS Subcomittee on Waste Management on May 4,1988. The ACNW also dis-cussed this topic with the NRC staff during our second meeting. July 21-22, 1988, and. reported to you'on this subject on August 9, 1988. We also had:the benefit of the document referenced. As a result of these discussions, we offer the following comments: e 1. The proposed exemption system is based on the risks associated with the exposures involved, and the system, if acdified 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 mrom (0.1 mSv) per year to individuals and annual collective doses up to 100 person-res (1 person-Sv) as acceptable limits arising from a single exempted practice. Please note that this is a: different use of the dose limits than is proposed in the draft Policy Statement. Provisions l should be made to ensure that individuals within any population group are not exposed to any combination of exempted practices that results in dose rates greater than one to two times the dose rate limit. 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 l include: mV W /w9 O

m 4~.p 4 The Honorable Lando W Zech, Jr. -September 15, 1988 a. The draft of the proposed Policy Statement should clearly specify 10 mrom (0.1 mSv) per year and 100 person-rem (1-person-SV) per year as the limits' for individual and collec-4 tive dose rates, respectively. The ancillary use of a 100 person-rem (1 person-SV) per year limit as a g(uide to the necessity for' ALARA analysis should be removed see item b. below). b. There is a need for a much clearer statement relative to the role and application 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 complete calculation, and include within the data a tabulation of the number of people within each of several dose rate

ranges, d.

The section pertaining to the linear nonthreshold hypothe' sis needs to be clarified. One approach would be simply to include a brief statement that risk (cancer) estimates should be based on the assumptien that the linear nonthreshold hypothesis applies and that' this approach will result in-conservatism in the resulting estimates. e. Since its use represents a change in' NRC policy, the concept of the Effective Dose Equivalent should be defined'within the policy Statement. In a similar manner, since $1 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. 4. As the proposed policy Statement correctly points out, the Agree-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 doeur.ent, when properly revised, will represent a pio-neering effort in nuclear safety regulation, will help conserve those of our resources that are available for the control of environmental and public health problems. and should receive strong support from the professional radiation protection community. We believe that the proposed Policy Statement, if revised as suggested above, will serve a AOvh s e.* ]) 4 - - - - - - =. - - -. - - -. - -

W;,, pn ~ ~,... 3 1 t 4 e o-4l t The Honorable Lando W. Zech, Jr. September 15, 1988 well as a starting point' for the position to be stated at' the upccaing-international, meeting on this subject. Sincerely. JC Dade W. Moeller Chairman

Reference:

Memorandum dated September 8, 1988 from Bill M. Morris, Office of Nuclear Regulatory Research, NRC, to R. F. Fraley, Executive Director $ ACNW, transmitting Proposed Commission Policy Statement (undated b e i 1

pygsL. _, ~ ~ ...-_.i.^ 9 9/16/88 -(/[ .'~ SCHEDULING NOTES 1 ' TITLE: BRIEFlHG ON STATUS OF EFFORTS TO DEVELOP A BELOW REGULATORY CONCERN POLICY.- i . SCHEDULED:. 10:00-A.M., FRIDAY, SEPTEMBER 16, 1988 (OPEN) j a DtFRATION: APPROX 1-1/2 HRS-'

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' PARTICIPANTS: HEC 45 MINS r -BILL MORRIS, RES - WILLIAM LAHS, RES - FRANK CONGEL, NRR - ROBERT BERNERO, MNSS - RICHARD CUNNINGHAM, NM.SS -HEALTH PHYSICS SOCIETY 15 MINS - DR. LAURISTON S. TAYLOR i NUMARC 10 MINS - THOMAS TIPTON 1 for.h & k t ~~husqin mema.a as J.J q bd

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.i 4 Commission Briefing on Generic BRC Friday, September 16, 1988 Good morning. I-am Tom Tipton, Director of the Operations, Management and Support Services. Division of the Nuclear Management and Resources Council (NUMARC). Byron Lee and Joe Colvin are on travel and send their^ regrets for not being able to be here today. I'd like to thank the Comission for the opportunity to appear before you at this meeting to present a statement on behalf of NUMARC with input from' representatives of Edison Electric Institute (EEI), Electric Power Research Institute (EPRI), Utility Nuclear Waste ~ Management Group (UNWMG) and U.S. Council for Energy Awareness (USCEA). With me today are the following industry representatives; Mary Birch, Technical System Manager, Radwaste Engineering, Duke Power Company, and Chair of EPRI's BRC Owners Group Technical Advisory Committee; Lynne Fairobent, NUMARC Project Manager; Pat Robinson, Director of EPRI's Below Regulatory Concern (BRC) Owner's Group; Steve Kraft, Director of UNWMG; and Dixon Hoyle, Project Manager, Nuclear Fuel Cycle, USCEA. [ The nuclear industry has supported and continues to support NRC's efforts t.o designate levels of radiation that are Below Regulatory Concern. Since the -generic BRC issue involves several industry organizations and addresses a generic issue, NUMARC is responsible for coordinating these industry j activities. To accomplish that, we established a BRC Ad Hoc Advisory Committee, which has representation from all industry groups addressing = different aspects of the issue. A draft industry program plan is being 1

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prepared and will be distributed in.the near future. It describes the range and scope of industry activities relating to the BRC issue and the key milestone dates. We plan to make it available to your staff so that you - will be fully aware of industry's programs. However, we think it is important to briefly highlight today some of the . industry activities already completed and those in progress that address .this issue and then mention some important points for your future consideration. Again, we appreciate you allowing us this opportunity. 1 L -There have been several detailed industry studies addressing the issue of BRC dating back to.the late 1970s. Some examples are identified in l [ Attachment A to my presentation. In July 1984, EE! and UNWMG filed a petition for rulemaking with the L i NRC regarding the disposal of radioactively contaminated waste oil from nuclear power plants with levels of radiation that should be classified as being below regulatory concern. We are pleased that NRC published for comment in . the August 29, 1988 Federal Register a proposed amendment to its regulations to permit the on-site incineration of slightly contaminated waste oils generated at nuclear power plants. The nuclear industry will be submitting { l: comments on the proposed rulemaking. l l L The industry has also been involved in related activities. Extensive comments on the proposed revisions to 10 CFR Part 20 were provided in October 1986 by the former Atomic Industrial Forum and EEI: Detailed comments on 2 m.

%, u~x-nm 7 y L" , NRC's BRC recommendations were included. The industry also commented L extensively on NRC's Advance Notice of Proposed Rulemaking on Radioactive I Waste'Below Regulatory Concern published in-the December 2,1986 Federal Register. These comments included a strong endorsement of the Comission's proposal to develop BRC regulations. 1j NRC published in the August 29, 1986 Federal Register a policy statement and staff implementation plan regarding, " expeditious handling of petitions for rulemaking to exempt specific: radioactive waste streams from disposal in a licensed low-level waste disposal facility.' This policy statement provided the long-sought opportunity for the nuclear industry to pursue the exemption of wastes with very low activity levels from NRC regulations. -In response to the August 1986 Policy Statement, EPRI and UNWMG initiated a joint program in early 1987 to develop a petition for rulemaking to exempt very low-level waste produced at nuclear power plants. EPRI is providing the research and technical data to support the petition, and UNWMG is providing I ,Jogramsupport,includinglegalsupportanddraftingapetition. The EPRI p research effort is nearly complete. It alone represents an expenditure of l approximately 2.2 million dollars. The present target is to submit the l petition by the end of this calendar year. The petition will propose that the regulations allow the disposa'l of it slightly contaminated wastes in on-site landfills,' off-site sanitary landfills, l L and on-site and off-site incinerators. It will fully comply with the detailed criteria set forth in the Commission's August 1986 Policy Statement and the l 3 y 1 L

wx -.n. + 4 . staff's implementation plan, and will therefore qualify for expedited processing. t Now, I would like to briefly summarize some important points for your consideration during future discussions on the issue. First, it is important that any NRC action identifying a' level of radiation risk or dose below which government regulation would be limited or l' unwarranted be consistent with, and not negate in any way, the August 1986 policy statement. We need to preserve the options it provides as well as the investment the industry has made in preparing the petition. Second, we feel that a process should be established to determine appropriate BRC levels, including the performance of a cost / benefit analysis for higher BRC exempted dose levels. Less rigorous inalyses would be required l for lower dose values. We generally support an approach similar to that 1 presented by the staff at the September 13, 1988 meeting of the Advisory Committee on Nuclear Waste. Prior industry comments on the issue support individual doses in the range of 10-20 mrem per year as the generic BRC. Third, since protection of the individual assures adequate protection of the overall population, the establishment of an annual collective dose (person-rem) standard for BRC is not appropriate. Finally, it is our understanding that the staff currently intends to make BRC standards a " matter of compatibility" for Agreement State Regulatory 4 a

6.: i,. y Programs. In ords.;r to realize the full benefits from the Commission's BRC initiatives, it is crucial that BRC standards be adopted by Agreement States identical with federal requirements, in a manner similar to the Connission's other radiation protection standards.

c In conclusion, the industry strongly supports initiatives to address the BRC issue, as reflected in the work that has been initiated over the past decade. Further, the industry believes that the development of BRC is important to the conduct of good radiation protection programs while at thg same time making it possible to minimize the expenditure of resources on matters that pose trivial levels of risk.

We support the need to address the generic BRC issue in a timely manner and encourage the continued exchange of information as it becomes available. l-Establishing regulatory cut-off values would assure that our limited' resources are being used most effectively in protecting public health. Thank You. l. t-- I 5 L L i e

(,4fuy~_.- ~ [ s. ,6 Attachment A L EXAMPLES OF' INDUSTRY STUDIES COMPLETED l ATOMIC INDUSTRIAL FORUM L .AIF/NESP016(1978): "De Minimus (sic) Concentrations of itadionuclides in Solid Wastes" AIF/NESP-035-(1986): " Evaluation of the Potential for De-ngulated Disposal of very Low-Level Wastes from Nuclear Power Plants" AIF/NESP-037 (1986): "A Guide for obtaining Regulatory Approval to Dispose l l of Very Low Level Wastes by Alternative Means". l: EDISON ELECTRIC INSTITUTE GP-33040 (1981): "The Feasibility of Establishing a 'De Minimis' l.evel of Radiation Dose and a Regulatory Cut-off Policy for l Nuclear Regulation" GP-R-72005 (1982): " Summary of Potential Benefits of Proposed Regulatory Cut-Off Policy Based on De-Minimis Radiation Dose Criteria - Results of a Survey of Nuclear Utility l Personnel" ELECTRIC POWER RESEARCH INSTITUTE l 1 l EPRI NP-3299 (1983): " Segregation of Uncontaminated Dry Active Waste" EPRI NP-3370 (1984): " Identification of Radwaste Sources and Reduction l Techniques" EPRI NP-5099 (1988): " Update Characterization of Radwaste Sources, Vol. l' and Vol. 2 s EPRI NP-5670 (1988): "Below Regulatory Concern Owners Group: Evaluation of Candidate Waste Streams" EPRI NP-5671 (1988): "Below Regulatory Concern Owners Gmup: Radionuclide Prioritization Study" EPRI NP-5672 (1988): "Below Regulatory Concern Owners Group: Selection of Plants for Sampling Program" v. s

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g Y H EALTH PHYSICS SOCIETY = September 8, 1988 Connaissioners Lando W. Zech, Jr. 7-Thomas M. Roberts Kenneth M. Carr Kenneth C. Rogers U.S. Nuclear Regulatory Commission Washington, DC 20555 It has come to the attention of the Health Physics Society that, because of concern over the unwise use of available trained manpower and resources associated with the regulation of radiation exposures at very low doses, the Nuclear Regulatory Co'umission is considering the adoption of a policy to define a meaningful generic level of exposure below which it would have no regulatory concern. Although the unnecessary regulation of very low-level radiation creates employment opportunities for our members, we would like to inform you that this Society shares your concern and is prepared to provide consensus scientific assistance and support for yobr position. In particular, it is the position of the Society that the efforts mentioned above are in many cases not commensurate with the riska, if any, that are averted. The Health Physics Society, founded in 1956, has a membership of more than 6,400 health physicists and other scientists who specialize in the protection of people from ionizing radiation, including physicists, chemists, radiobiologists, epidemiologists, physicians, engineers and mathematicians drawn from industry, academia, research and medical institutions, national laboratories and governmental agencies. The Society is believed to fully encompass and represent consensus technical opinion in the field of radiation protection and health effects. Today a considerable fraction of the regulatory effort is concerned with radiation exposures that are much smaller than those received from variations in natural radiation due to altitude changes and other causes. We currently suffer from what appears to be an irrational public fear of low levels of radiation exposure; this has been fostered, in part, by associated governmental pressures to further reduce them below risk levels found and accepted in nearly all other factors of life. This, in turn, has resulted in the incurrence of inordinate pressures on all phases of the radiation industry, the cost of which is ultimately passed on to the public. We believe a real, and much greater saving of life could be accomplished by the alternative expenditure of our resources on safety operations where the risks are citarly demonstrated, as compared with the low-level radiat' ion riska n. are so miniscule that they may never be unambiguously established. 1 O 3p0

w.y .~% 4 E September 8, 1988 Page 2 It has never seemed logical to try to regulate radiation exposures that are miniscule relative to those we receive from nature. We believe that the Commission's objectives can be accomplished within the framework of the existing standards of radiation protection as recossaended by the International Comission on Radiological Protection (ICRP), and the National Council on Radiation Protection and Measurements (NCRP). These bodies have recomended dose limits for the public that are far below the level where specific health effects have been observed for h aans. It is not known whether any health effects in the general range of those recommended dose limits do or do not occur. If they do occur, they occur so f,adeequently that present scientific p methods are incapable of detecting them using the best laboratory and epidemiological methods. The system of dose limitation reconnended by standards bodies does more than provide dose limits which are not to be exceeded without regard to cost-benefit considerations. In addition all radiation users are admonished that doses should be "kept as low as reasonably achievable (ALARA), social and economic considerations being taken into account", and that unnecessary exposures should be avoided. This is not a standard in the sense of a dose limit but is an essential advisory to be applied on a case-by-case basis. The dose limit, when coupled with the ALARA concept, provides an average individual (or collective) dose that is associated with an acceptable risk. A BRC level, would, in effect, truncate governmental involvement in the implementation of the ALARA concept, placing further implementation on an entirely voluntary basis. Thus we believe that the BRC level should, at least in theory, be near the threshold of a public rien of sufficient magnitude to warrant governmental intervention in the lives of its citizens. The current NRC safety goal for operation of a nuclear-power plant is theoretically associated with doses of some 10 te 20 millirens in a year for an entire lifetime, which would seem an appropriate range in which to start considering a BRC level. Pertinent technical issues are addressed in more detail in the enclosed attachments No. I and II. Respectfully submitted by the Health Physics Society, O M./ e7e* Lauriston S. Taylor Past President Health Physics Society

p j h 92 .. = ATTACHIENT B0. I 1. Conservatism of current radiation protection sem aards. The recommendations of the ICRP and the NCRP are put forward with extreme caution and in expectation that the responsible bodies (e.g. BRC) will apply.the necessary politic adjustaant of practical limits to meet the technological and social needs of the nation. Because of the absence of obaarved health effects in the low dose region (below the order of 5 rem in a year), both the ICRP and RCRP make the conservative assus.ption thas..she frequency of occurrence of p health effects, per unit of dose at the low dose levels in the range of the dose limits, is the same as at high doses where health effects have been quantitatively observed and aztensively studied in both humans and animals.. This process allows the theoretical establishment of upper limits on the number of effects-if any-that might occur in the low-dose range. There has been remarkable agreement among the ICRP, NCRP, R&B, and URSCRAR on all of the quantitative methods by which the effects should be estimated. At the same time there has been agreement that, if used for projecting Ital effects that will occur following low-level exposures of the public, the assumption of proportionality is inappropriate and misleading, and should not be so used. 2. Balancing costs and doas reduction. The taking of social and economic considerations.into account is the nemesis of the-radiation regulator and is the least understood by the public. Standards bodies have emphasised that in the commitment of resources to reduce doses below the dose limits, there should be an appropriate balance between re6ources committed to reduction of dose and the real benefits derived in the subsequent reduction of health effects. It is recognized that a point is reached.where the effort (cost) required to further reduce dose exceeds the benefit from the small incremental reduction of health effects that is theoretically achieved. In such cases the further expenditure of resources to reduce dose is not justified. While several regulatory limits have been determined using this approach, it appears that a generic BBC level would more appropriately be based on other considerations such as an increase in the theoretical risk as u s used in the development of the Commission's safety goals. 3. The public perception of safety. Failure to clearly explain the ALARA concept has, in some instances, resulted in public perceptions of health effects from very low-level radiation which are irrational and without factual basis. This, in turn, has led to the needless expenditure of substantial resources by individual members of the public, and by public agencies, because of an unreasonab.le concern with exposure to low-level radiation. This is all done in the name of reducing health effects which, if they exist at all, are so small as to be meaningless in comparison with the general health effects suffered by the public and as caused by ordinary substances to which people are exposed in everyday.living. This type of unwarranted concern with possible health effects from low-level radiation exposure can also lead to a failure to take advantage of the use of radiation-related technologies, even though in many cases a radiation technology may be the method of first choice. 1

m 3 g_7 Attachreat I (page 2) 4. The public perception of Risk. Perhaps the most difficult phase of the stC problem is that of dealing with the public's perception of radiation p risks and its concept of safety of any kind. The average person in the general public does not realize that there is no such thing as absolute safety. They see that if a given condition is not safe, it must be unsafe-that there is a sharp dividing line between the two. Webster defines safe as, " free from or not liable to danger of any kindi free from er having [ escaped hurt, injury or damage...." Obviously, absolute safety is not obtainable for most human activities. Therefore the questica is not "What is a a safe level of asposuret", but "gow safe is safe enought". We know that p. .mafety is a relative ters, but most of the~peblic and the news media do not understand that. A major national effort is probably needed to educate the P public as to what safety means and what they are to expect of it. { 5. Cantaminated asterial. Our discussions at this juncture relate only to hesith effects in the population. A separate, but related, problem e w arns levels of contamination of material that may be returned to Laustrial use. Under many circumstances such matettal nav mot pose any health problem but can introduce difficulties if, by chance, it should be incorporated into devices or instruments where extremely small amounts of radioactivity could interfere with their proper operation. Thus, crintamination levels far below any conceivable risk to humans may still be a costly nuisance to the very few manufacturers of radiation instruments or certain shielding materials. Strict regulation of the many thousands of facilities at levels lower than those designed primarily for hunca risks would be costly out of all propertion to the value of sipch contan61 cation-free p materiab. When there is need, let it be a part of the manufacturing costs to find and test the required materials. 6. science and technology in radiation protection. There is another role of the Commission that must be undertaken, and recognised not only by the general public but the scientific consunity generally, and especially those in radiation science as distinguished from radiation protection practitioners = F (e.g., health physicists). With his normal background and training, the scientist speaks on the basis of facts or theories (or assumptions or g models). For azample in discussing possible low-level radiation health effects, he accepts the asistence of meaningful data in the range above, say, 10 ram. gelow 10 ran, his data are of questionable value, if existing at all, bnt it appears as though the higher range data might (more or less)'1ogically ~ aztend straight down to zero dose. When pressed, he speculates that it we ,T, could find some data in that unexplored low-dose range, it uould almost Y certainly not be far out of proportion with the high-dose data. Bowever, he can't osy for certain that there are no effects in the low region since it has y not bean poselble to obtain any data there at all. The best he can do is to point out that in such case there is a possibility that for any dose, no matter how small, there must also be the possibility of some health effect. As far as the public is concerned, the associated low probabilities so unrecognized and Pandora's box has been opened. They believe that any radiation exposure whatever will lead to cancer. e _ _ ~ _ _. _. - - - - _. _. _ -. _ _. _ -... _. _ - _ _ _ _ - -. _ _. _ - _. _ _ - _ - _ - - - - - _ _ - - _ - _ _ _ _. -. - - - - - _ _ _ -. _ _ _ ~ - -

%i - wave.ww.h, 2 l l i Attachment I (page 3) 7. The role of the Socisar Rossistory Commission. What is the point of all thief The point is that our scientifically derived radiation protection standards, by themselves, are inadequate for some radiation azposure situations, specifically for defining acceptable conditions of " safety" in the low-dose range. The only solution for this is a politic decision by a properly authoritative governmental organisation, such as the Nuclear Regulatory Commission. (By politic, Webster means, " prudent and sagacious in devising and pursuing measures to promote the public welfare.") The obvious step is that the Rtc must establish, and make clear, its role in the radiation protection standards arena, that 1) it is making the necessar/' politic utilization and adjustment of the,et.isatifically derived radiation protection data, as far as they 30, 2) it is accepting the responsibility for clarifying the concept of nuclear safety, or relative safety, and 3) it is setting a level of radiation that is below regulatory concern. l i 1 i e e i t 9 P

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e i ATTACBC:NT II _ In its more than 30 years of direct arperience with the public and radiation protection, many points have come to the attention of the Esalth Physics Society that we believe should at least be thought about in considering.the adoption of a Stc concept. Many of them are based on questions that are asked of our members, individually, or stataments-and misstatatats-that appear in the various news media. We are reasonably certain that you are already aware of sop Q f not all, of the items to follow F but offer them, largely in outline, by way of emphasis. Some additional itano are in saplification of statements in the preceding pages. A. Emanmies. There is about a 70 ares / year difference in the dose from l i arternal radiation one receives from natural sources, depending on whether one lives on the coastal plane or in the hilly areas in the West. (RCEP toport 93.) The higher exposure to radiation of people who live in the hills and hountains dess not seem to make them less desirable to those who want to live l there. Average natural-background radiation levels vary by 100 millirea in a year. Studies have shown a generally lower cancer incidence rate at the higher background locations, thus indicating that a BBC below 100 area could be scientifically defensibl.t. i The upper limits of risk that result from levelt of arposure comrarable to the variations in the natural background are well below the riska from commercial activities that are generally accepted as good neighbors in the consunities in which they exist. Normal living habits such as working on the 10th floor as compared with the let floor of a building, or living in Bethesda as compared with downtown Washington, add a few milliress per year to one's dose. So aisc does consercial flying, medical procedures and so on-none of which are normally considered in individual radiation exposure concerns. Something is considered acceptably safe when extensive study and experiment demonstrate that one's individual chances of injury or accident are exceedingly small. It shonid be noted that nothing is absolutely safe, but that all activities and nasural events have varying degrees of risk. B. Data Limitations. In establishing personnel protection standards it is considered by some as scientifically and morally defensive to use the l alinear-nonthreshold" approach into the low dose regions as a practical aspedient, because it overestimates the dose effect. However, it was never intended that risk evaluation be made using this approach. m. c _ _,... _,. -. _... ~. -.._.--__.y,-_.-__ , _....... -,. _ _ ~ _. _.. _

u ama-+... u. ^ ~ 7~~~ ~ ' ~~ ~ ~~ ~ ~ ~ ~ ~ ~~- ~~~~'~~"m ji! e. l, Attachment II (Page 2) 4 To postulate a large number of deaths frm.. very low exposures (less than I O a single dose of 10 reas, or an anntial dose el 4 rea in a year) to a very large 'r pulation is' fundamentally indefensible; it consunicates a o l. uisconception in-the ainds of the laypublic and legislators / administrator 9. + One possible reason for the lack of low-dose-effect data for humana is l that such effects any not asist. Another reason is the fact that very large esposed populations (millions of subjects) are required for statistically l defensible studies that must aztend over 25 to 50 years. Equally large uneaposed, but othervice control populations, are also required. .o. - Estimated Population Sise to Provide Statistically Meaningful Effects Values DOSE POPULATION SIZE 10 red 50 thousand 1 rad 5 million 100 arad 500 million 10 arad 50 b1111on j f C. Judament in the abaance of farts. Because the general public is not equipped by education and experience to evaluate complax technical matters, o i the government or some type of public body with suitable arpertise must,1) develop guidelines, excluding conditions outside the area of knowledge, 2) base any guides on facts as far as they exist, 3) clearly define conditions where they do not exist ahd, 4) apply professional judgment in lieu of facts when necessary, but make the action cle$r. In the application of judgment, the reasons and need'for any action that is not amenable to quantitative evaluation must be explained. D. Pon_mible obiections. It is quite possible that some individuals or groups will bring charges of vasted interests on the part of the Health Physics Society because of this submission. Such a claim is the opposite of common sense since the personal interests of health physicists would appear to be better served by more severe rather than apparently less stringent radiation protection regulations. It can be foreseen that objections assy be raised to the implementation of the SgC concept because of the frequently stated misconception that we "know nothing about the effects of low levels of arposure." Objections may also be s raised on grounds that "there is no such thing as a safe dose of radiation." Both points are discussed in Attae.hment I. %HM ,w/ e .-_.,__m-mm-,=,,me,. , ~ ."vc ww- - = e.

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Y% t t.c: 4 g YY d. e f i o r, PROPOSED POLICY STATEMENT 1; ON EXEMPTION OF PRACTICES WHICH ARE BELOW REGULATORY CONCERN STAFF PRESENTATION TO COMMISSION ig ' h SEPTEMBER 16, 1988 f I s' 1 l l' l .z-b

.. a - ~ .- ~ ' h j a L- ) i e' f, i 1 0 i i OUTLINE OF PRESENTATION PURPOSE OF PRESENTATION t BACKGROUND OBJECTIVE OF POLICY STATEMENT CONSIDERATIONS UPON WHICH POLICY STATEMENT IS BASED l' KEY ELEMENTS OF POLICY STATEMENT PLANS FOR INTERNATIONAL WORKSHOP-I. G 's I d g +'/. ' i w w e e.- w g,. .,s p f

rn c;aa- *x___ j 1 v l i e I PURPOSE OF PRESENTATION: + 10 DISCUSS THE PROPOSED COMMISSION POLICY ON EXEMPTION FROM REGULATORY f CONTROL FOR PRACTICES WHOSE HEALTH AND SAFETY IMPACTS ARE BELOW REGULATORY CONCERN TO DISCUSS PLANS FOR THE INTERNATIONAL WORKSHOP t y 'N 4 k i s 9 I r 2 3 4

p ,L.~ .y l i r I BACKGROUND STAFF REQUIREMENTS MEMORANDUM OF 3/30/88 DIRECTS STAFF TO " SUBMIT FOR COMMISSION CONSIDERATION OPTIONS FOR A POLICY STATEMENT WHICH ESTABLISHES A GENERIC NUMBER FOR EXPOSURES THAT ARE BELOW d/ REGULATORY CONCERN." I i r 5 3 b v

.g - 1 L: i f L OBJECTIVE OF P01.lCY STATEMENT 1 TO ESTABLISH BASIS FOR DEVELOPMENT OF REGULATIONS OR LICENSING DECISIONS j DEFINING COFD'TIONS FOR EXEMPTION FROM REGULATORY CONTROL. [ s i + , + -.. - a

, - v .s._,m._ m._ ~ y 1. i i a i i t P CONSIDERATIONS UPON WHICH-POLICY IS BASED FUNDAMENTAL PRINCIPLES OF RADIATION PROTECTION JUSTIFICATION OF PRACTICE DOSE LIMITS TO DEFINE MAXIMUM ALLOWED RADIATION LEVELS ENHANCED PROTECTION BASED ON ALARA PRINCIPLES 4 1 5 A ,..y...

v -n e + CONSIDERATIONS UPON WHICH-POLICY IS BASED LINEAR NON-THRESHOLD RELATIONSHIP BETWEEN LOW RADIATION DOSE AND STOCHASTIC CANCER RISK s G l l l' l l' l l 1 i. l-i ( - 1 l, 1 ll ____'_________ij) i;

mama _. F i 1 s ) 1 ) i t t I + r I i CONSIDERATIONS UPON WHICH-POLICY IS BASED Y RECOGNITION THAT INDIVIDUALS MAY BE EXPOSED TO RADIATION FROM MORE THAN L ONE LICENSED OR EXEMPTED SOURCE d f 1 7 . - a mW i = =

Q : -+.a. ~., q .. = -. .r. i t-t .(. C ELEMENTS OF POLICY STATEFF)'I t GENERAL CONDITIONS FOR EXEMPTION COSTS OF ADDITIONAL REGULATORY CONTROLS TO REDUCE INDIVIDUAL OR COLLECTIVE DOSE ARE NOT BALANCED BY L' THE REDUCTION IN R1SK. [. 1 L l lL 8 ,.{

1 .-a w... r l a l r i i L i ELEMENTS OF POLICY STATEMENT ALTERNATELY, APPLICATION OF REGULATORY CONTROLS DOES NOT RESULT IN A SIGNIFICANT REDUCTION IN RISK. = ! + [' l != 1, e 9 E w -e y v re,

r .4ms (. l I' 5 i KEY ELEMENTS Of POLICY 3 PROPOSES 10 MREM AND 100 PERSON-REM AS THE INDIVIDUAL AND COLLECTIVE ANNUAL DOSE LEVELS BELOW WHICH RISKS ARE I SUFFICIENTLY SMALL THAT ALARA CAN BE CONSIDERED TO HAVE BEEN ACHIEVED WITHOUT PERFORMING COST BENEFIT ^ ANALYSES. I L l l 10 e e

7 -._._ ~ s..;._.- "' gs .._') l, y ' 4 l KEY ELEMENTS OF POLI (y EXCLUDES FROM CONSIDERATION FOR EXEMPTION PRACTICES WHICH INVOLVE INTRODUCTION OF RADIOACTIVITY INTO TOYS OR PRODUCTS INTENDED FOR INGESTION, INHALATION, OR DIRECT APPLICATION TO THE SKIN. i i i i

f. L.a. _w, ^ ^ ^ a E I [ i t KEY ELEMENTS OF POLICY t ALSO EXCLUDES F RELEASE OF RADIDACTIVITY WHERE [ I THERE ARE' CLEAR ECONOMICAL ALTERNATIVES OR THERE ARE NO UN!QUE BENEFITS FROM THE USE OF RADIDACTIVITY. f f 4 12

? . 4.-...wm t l i t 1 KEY ELEMENTS OF POLICY PROVISIONS TO LIMIT POTENTIAL IMPACT . 7 0F MULTIPLE EXPOSURES SELECTION OF DOSE CRITERIA FOR WAlVER OF C.0ST BENEFIT ANALYSES EXEMPTIONS INVOLVING UNJUST!FIED RELEASE OF RADIOACTIVITY WOULD BE EXCLUDED 0 m t r 4 P 13 t,

pp-g.: o-.- ^ i i - a, :. i i l t i s KEY ELEMENTS OF POLICY FOR EACH EXEMPTION DECISION ANALYZE COMPONENTS OF EXPOSED POPULAT10N TO [ IDENTIFY THOSE WHO MIGHT RECElVE DOSES NEAR 100 MREM WHEN 0THER. PRACTICES ARE TAKEN INTO ACCOUNT. 4 i e 14 l

il , i,'Qww.. ~ ~ -[::a. ~ l i j..>- i.,.: 1 I 1 ? k F i i KEY ELEMENTS OF POLICY I REEVALUATE POLICY AND ITS IMPLEMENTATION AS EXPERIENCE IS f GAINED DEllBERATE FRACTIONATION OF-PRACTICE NOT ALLOWED + I l l l 15

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i KEY ELEMENTS OF P0,j,J U ALLOWS APPLICATION OF TRUNCATION OR WEIGHTING FACTORS WHEN CALCULATING l COLLECTIVE DOSE TRUNCATIONS IN SPACE OR TIME *. CUT OFF AT LOW DOSE (E.G., 0.1 MREM). t I 16 m-- m +

~ - a:" i I + i i i KEY ELEMENTS OF POLICY WElGHTING FACTORS FOR COLLECTIVE DOSE IN VARIOUS RANGES OF INDIVIDUAL DOSE (E.G., $1000 PER PERSON REM ABOVE 1 MREM AND $100 BELOW). I 1 I l 1 l' l' 17

e .y _ _m,.. > l 4 f 5 t i L i INTERNATIONAL WORKSHOP PURP0sE: P L TO Discuss DIVERSITY OF INTERNATIONAL l REGULATORY VIEWS i p W 0 G l. 1 e 18 i e-g-

r ;.:au.-.an-- . 7 INTERNATIONAL WORKSHOP CURRENT COMMITMENTS: REGULATORS FROM 10 c0UNTRIES INTERNAT10NAt ORGANIZATIONS (ICRP, NEA, CEC) EPA, DOE, NCRP, ACNW l 19 ~;;;* 1 o

xa_< ^ 1 1. k j i I L i+ I \\ I 5 k BACKUP SLIDES s STAFF PRESENTATION ON PROPOSED BRC POLICY STATEMENT l l. SEPTEMBER 16, 1988 O g l. l l 'M.s 4r w

,. 2LA.-_m j = 4 / 1 i t I h b' I-INTERNATIONAL WORKSHOP WORKSHOP SCHEDULED FOR OCTOBER 17-19 3 IN WASHINGTON, D.C. STAFF NEEDS GUIDANCE FROM COMMIS$10N-l REGARDING DISCUS $10N OF PROPOSED POLICY AT 4 WORKSHOP ISSUANCE OF POLICY FOR PUBLIC COMMENT [ N i 20 f ,c

r; U, INDIVIDUAL RISK AS A FUNCTION OF DOSE LIFETIME RISK INCREMENTAL INCREMENTAL FROM CONTINUING ANNUAL DOSE ANNUAL Risk ANNUAL DOSE 100 MREM 2 x 10-5. I x 10~3 l 10 MREM 2 x 10-6 1x10'l 1 MREM 2 x 10~7 O.1 MREM 2 x 10-8 1 x 10'6 1 x 10-l l-1 1 k

'.. - _ ~. ' ~ y. m. ay =- l t-i 1 l q e 1 1 PROPOSED EXEMPTION POLICY SCHEMATIC J l e sum 1000 Regulatory D'se Limit l o 100 For Public ALARA Cost / Benefit l Analysis Required (l 10 ( j ~ - Exemption = decision based. I l on simple justification j ~ of practice. ~ PracticeconsideredALARAj l~ I w/o further analysis. I j l ~ l U.S. Population .. Possib.1A.j ndi.yi@ g l _d.Dit.l _1............. __,.. i Max. Impact 0.1 - cutoff for collective 1 dose hssessmen't us'ed in' l - C/B analysis. l e* a l l i I l 0.01 ..,,,i,,, e i i i i i iii e i i i iiii, ,,,,i,,,, 1 10 100 1000' 10',000 Annual Collective Dose (Person. Rem) P W --m--v* __y -4 r

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+ c w e >c p, y s a a i f. j '. - UNCERTAlNT1ES IN DOSE-RISK RELATIONSHIP i 3 j UNCERTAINTIES'IN DOSES RECEIVED BY b I ' POPULATION-INCLUDED IN EPIDEMIOLOGIC -STUDIES E-EPIDEMIOLOGIC DATA ONLY AVAILAllLE AT. T HIGHER DOSES w. 4 m s A e E 3 i g

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-J ~ )%L 5 i l (', l f 3 l {. u UNCERTAINTIES IN DOSE-RISK'REl.ATIONSHIP 4 / VARIOUS HYPOTHESIS FOR' EXTRAPOLATION p TO LOW DOSES. f VARIOUS HYPOTHESE5 FOR PROJECTING J >FATAllTY RATES.INTO FUTURE s 4 e* k .\\ J ,l i 0 fi i .s I c. ameen 1m s g g p( =,}}

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