ML20043C228
| ML20043C228 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1990 |
| From: | Gagner S NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Bernero R, Cunningham R, Morris B NRC |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006040256 | |
| Download: ML20043C228 (28) | |
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5E UNITED STATES t
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NUCLEAR REGULATORY COMMISSION a
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wassincioN, D. C. 20655 gs.**/'
February 27, 1990 e
-NOTE TO:-
Robert Bernero-Richard Cunningham Bill Piorris Don Cool Joe Fouchard Bob Newlin N
5 FROM:
Sue F. Ga ner Public Af airs Officer Public Affairs
SUBJECT:
DRAFT BRC PAMPHLET Enclosed for your review and comments is a copy of a draf t text for an informative pamphlet on the BRC policy, as requested in the October 13,.1989,.
Stan Schneider is developing the pamphlet under a Staff Requirements Memo.He is still developing a few graphics to be included in contract with GPA/PA.
the pamphlet.
If possible, we would like to have your comments on the draft by March 7,1990.
Enclosure:
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RADIATION, REGULATION AND REASON A Citizen's Guide To The Exemption of Radioactive Materials, Wastes and Practices Below Regulatory Concern l
u Draft by:
Stanley D. Schneider 14901 Braemar Crescent Way Darnestown, MD. 20878 (301) 670-0233 4
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INTRODUCTION t?
the Nuclear Regulatory Commission (NRC), i s the Federal i
agency whose mission it is "to ensure that the civilian uses of l
nuclear materials, facilities,ind activities are conducted in a manner consistent with the the needs of public health, safety and environmental quality..."
In order to carrying out this mission more effectively, the NRC is introducing a new policy related to the safe management of extremely low levels of radiation.
That policy defines levels of radiation exposure so low that further efforts to reduce do not warrant regulation by the Federal i
Government.
Such hvels serve as points below which new and more reasonable approaches to the control and management of nuclear materials, facilities and activities can be considered.
This new policy does not represent a decision to exempt any s
specific consumer product, waste or any other material or service from regulatory control.
Instead it creates a new framework and guidelines for exemptions based on levels of rad $ation exposure so low as to be equal to or less than the change in radiation one i
would be subject to from a change in one's natural surroundings or normal daily activity.
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In the past, the NRC has exempted radioactive mettaitis from regulatory control on a case-by-case basis.
Now, it is introducing a policy that will allow it to consider exemitiins on a broader, more generic and less burdensome basis.
Why this change?
The NRC has always recognized that tht use of radiation and radioactive materials, like many of soc'itty"s activities, involves some risk.
Thus, it has traditiona51y strived to ensure that any radiation dose received by workee$ or members of the public is reduced to a level that is as io, is reasonably achievable -- the ALARA principle.
However, vten the point is reached where the radiation is so low as to be only a tiny fraction of that received from nature, any expenditure to reduce the exposure further outweighs the benefit to be gained.
At that point, deemed below regulatory concern (BRC), the Nuclear Regulatory Commission believes its new approach to very-low-level radiation management is essential.
Among other things, pursuing a BRC policy would allow more of the Commission's limited resources, as well as.those of its licensees, to be allocated to more important health and' safety measures.
i Seen in this light, BRC clearly is not a policy to reduce the Commission's role or responsibility.
It is one designed to g;
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deal with an. issue of growing national importance -- the safe o
L management of nuclear activities, materials and wastes, o
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This booklet 0111 explain thy a SRC l'olicy t:as created and how it will work. It will also explafn what it will mean in terms of radiation risks to the public -- to all of us who live in a i
world where nr.tural radiation is a fact of life and man-made l
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radiation offers benefits and risks we can learn to deal with in L
an intelligent, constructive and cooperative way.
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RADIATION: A FACT OF LIFE -- AND SOME OTHER FACTS It has been often said, "We live in a sea of radiation."
1 What does this mean?
For one thing, it means that our planet is i
continually bathed by various kinds of radiation from space --
from our sun, our universe and beyond.
From the sun and the stars we receive the photons that produce visible light.
The sun also gives us infrared rays that provide heat and ultraviolet rays that help give us Vitamin D, tan our skins and, if we're not careful, j
burn it.
From deeper space we receive such radiation as microwaves and x-rays, some of which reach us from the deepest 1
recesses of the cosmos.
We even receive cosmic radiation in the form of neutrinos, particles so tiny and energetic that they can t
pass right through the Earth.
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That's the radiation we receive from above.
But the Earth itself is also a source of radiation.
This comes from many radioactive materials in its soil, rock and water.
These materials, called radioactive isotopes -- or radioisotopes -- are L
unstable variations of natural elements, and they, along with certain cosmic rays, are nature's sources of ionizing radiation.
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lonizing radiation is of most concern to us because, in its l
various forms -- X-rays, alpha and beta particles, and gamma rays, it can disturb the structure of the atoms it strikes, and therefore damage the cells of our bodies.
In most cases these damaged cells repair or replace themselves.
But we also know that l
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in' sone. cases the daaage can result in sonatic or genetic changes.' y And these can lead to mutations and cancer.
The possibility and incidence of this depend to a great extent on the exposure to the radiation -- the intensity and length of time of the exposure called the dose.
Therefore, we can think and talk in term of-radiation risks.
This is a matter that has been well researched and we'll discuss it in more detail later.
But first, it's important to understand a bit more about the sources of this radiation here on Earth.
Some of these, such as carbon-14, tritium and sodium-22, have been made radioactive by cosmic rays.
Others, such as potassium-40, thorium-232, and uraniun-238, were created by the primordial process that made the Earth itself.
And some of these, like uranium, create still other radioactive substances', such as the gas radon, which can seep into our homes and pose a health problem.
We can also receive a small l
amount of radiation directly from the walls of our homes, if they l
are made of a stone or brick that contains uranium.
There is one further aspect of natural radiation.to consider.
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Since plants and animals absorb and ingest radioactive substances from their nutrients and surroundings, we humans who live off them also take in and emit a certain amount of this natural
-l radioactivity.
This can vary greatly, for example, from the relatively high amount of activity in a Brazil nut to the relatively small amount in a piece of fruit such as an orange.
And the.very fact that the food and water we consume contain a
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l certain amount of radioactive potassium, Ceans that ce ourselves 7
are slightly radioactive.
Therefore, to a very small extent each of us irradiates the person we sleep next to, i
Putting all this together, it's estimated that about 83 percent of all the radiation to which the average person is exposed comes from these natural sources.
Individually, the amount _can vary somewhat, depending on factors such as where one lives and one's lifestyle.
For example, if you live at a place of higher altitude you receive slightly more radiation than someone living at sea level because the atmosphere acts as a filter.
The same effect takes place if you do much air travel, as each flight you take adds a bit to your annual radiation dose.
But similarly, you could get additional radiation if you stayed on the ground and did rock climbing or went white water rafting down some canyon river.
And if you smoke cigarettes, you should know that in addition to the nicotine, tar and resin you are inhaling, your lungs are also receiving some radiation from the polonium-214 in tobacco smoke.
If 83 pers.nt of the average person's radiation is received from these natural sources, the remaining 17 percent comes from I
l so-called man-made sources.
And these are also varied.
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them the greatest exposure, estimated at about 15 percent, is from medical technologies for diagnosis and treatment.
These range l
l from periodic chest and dental X-rays to specific tests and treatments using radioisotopes.
The medical profession has i
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. developed a large arsenal of the latter, including, iodine-131 to L,,
test thyroid function; technetium-99 to diagnose liver, brain and kidney disease; cobalt-60 and cesium-137 used in teletherapy devices to treat some forms of cancer, and many other beneficial applications of radiation.-
All these are used in thousands of medical centers and hospitals around the country and throughout the world.
And they have been increasingly saving and prolonging lives.
Other sources of man-made radiation are various occupational activities, consumer products and the spectrum of nuclear power activities called the nuclear fuel cycle, which today is responsible for about a fifth of U.S. electricity.
But from all these sources combined, the average person receives little more than 2 percent of his or her total annual exposure.
And, as we indicated earlier, all or any of this radiation exposure --
natural and man-made -- can vary slightly depending on where and how one chooses to live -- choices we make freely, and free of any government regulation.
Having given this broad picture of our radiation exposure, we can now get a bit more specific about radiation measurements and standards, as well as put in some perspective the reasons for proposing a new policy.
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F i-RADIATION -- IN PERSPECTIVE
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Since the advent of the Nuclear Age - ' and particularly following World War 11, when its dangers were so vividly demonstrated -- ionizing radiation and its biological effects have been among the most studied phenomena.
The fact that nuclear power to generate electricity and other uses of radiation followed the use of atomic bombs meant that all peaceful uses of nuclear energy and radiation were treated with the greatest attention to safety.
Having witnessed the most deadly and dangerous side of this new source of energy how could one do otherwise?
As was often said at that time, it would have been the same with electricity if it were first introduced via the electric chair.
One result was that ionizing radiation and its biological effects fell under great scientific scrutiny.
And over the years that has increased, not lessened, as we learned more about radiation and its effects, in addition, we have become more aware of radiation in our environment -- even in the very smallest amounts -- as the scientific instruments we use to detect and measure radioactivity have been greatly improved in terms of their
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sensitivity and sophistication.
Today some of these instruments can detect the radiation coming from just a few unstable atoms.
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.A third point of enlightencent -- and fear -* about radiation
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has.come from our increasing biologic'al and medical knowledge, and
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particularly from our awareness of the many environmental causes of cancer.
While scientific research is still struggling for more exact knowledge of how various environmental Egents -- whether chemical or radiation or any other kind -- set in motion the cellular change that causes the uncontrolled growth of a cancer, we do know that in some people a very small change can initiate that process.
Therefore, we have become increasingly conservative when it comes to adding any radiation to the environment and to each individual's exposure.
In fact, o have come to accept and operate on the principle that there is no lowest level -- no threshold -- below which radiation can be deemed absolutely safe.
How do we measure radiation and the amount of it we receive?
The unit of ionizing radiation dose is the rem, and the millirem, abbreviated mrem, which is one-thousandth of a rem.
To put things in perspective using the rem and mrem, let's start by considering the higher ano most dangerous doses.
A quick dose of 1,000 rems, such as that received by victims of the atomic bomb in World War 11, would result in 100 percent mortality.
A dose of 450 rems, also received quickly, would result in death in about 50 percent of the people irradiated.
There is also a high F
probability that the immediate survivors of this dose would eventually develop leukemic or other forms of cancer.
Such radiation can also cause genetic effects in future generations.
although this danger has proved to be auch less than cas thought to be the case in the decade following World War !!.
As the size of the dose, and the concentration of the exposure, decrease so does the probability of injury and effects.
Most of our knowledge of radiation effects is based on relatively high doses (greater than 10 rems) administered over a short time.
But it is not a simple matter to estimate the effects of low doses of radiation, or any other injurious agent for that matter, received over a long period of time.
For ixample, as one health expert has pointed out, a quart of alcohol consumed within an hour would be disastrous, perhaps lethel, to most people.
But this would not be so if it were taken at the rate of an ounce a day over a period of 32 days.
As we move down the scale of radiation dosage, there is some l
evidence that the risk of cancer following radiation exposure is proportionate to dose, is dependent on the rate at which the dose i
i is received, and that there is no threshold below which there is e
no potential problem.
While there is also some evidence that the opposite is true, the first set of assumptions has been adopted in l
the interest of safety.
The International Commission on Radiation Protection (ICRP) and the U.S. National Council on Radiation j
Protection (NCRP) have both endorsed the "no threshold" approach, h
therefore specifying that re.diation dosage should be kept far below the recommended limit as is practicable.
The U.S. Nuclear Regulatory Commission (NRC) follows this principle.
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c Bearing in mind the higher levels of radiation we discussed, let's move way down the scale to the level of radiation dosage the average citizen receives in the course of his or her daily life.
And to do this we must begin at a level that is only a minute fraction of those higher doses, for the fact is that the average annual effective dose of radiation in the U.S. population is about 360 millrems (mrem).
That is well below one-thousandth of the lethal dose we initially discussed.
And it is over a period of one year, not in a matter of seconds.
Now let's put things further in perspective.
Of that 360 mrems, about 300 comes from natural sources -- the earth, cosmic rays, our food, bodies and natural surroundings, as we pointed out earlier.
About 53 mrems comes from medical diagnosis and treatment using radioactive sources.
And the remaining amount, less than 10 mrems, comes from a variety of sources, such as occupational exposure, the nuclear fuel cycle and consumer l
products.
l Our life-styles and daily activities very these amounts to some extent.
For example, if you live in Denver, "the Mile High 4
City", rather than a sea-level town such as Boston or San Diego, you receive an additional annual exposure of some 50 mrems, as the dose from cosmic radiation essentially doubles with each 6,600 feet of altitude in the lower atmosphere.
By the same token, air travel increases your exposure to cosmic rays at the rate of about i
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m 5 creas per transcontinental flight.
So if you're a " frequent 1.;.
e flyer" who clocks many thousands of miles of air travel, and collects free trips for the mileage you cover, you also collect a bit more radiation at the same time.
But you don't have to leave town, or home, to find that your exposure to radiation can vary.
For example, if you choose to live in a brick home instead of one of wood you may add a small amount of radiation to your annual exposure.
The difference can exceed 10 mrems per year.
Also, should your home be in a certain area of the country where there is more uranium or radium in the soil you may get a higher concentration of radon in your house.
Radon in the home has become recognized as the largest and potentially most dangerous of these natural variations of radiation exposure.
As a result, more attention is being devoted to reducing its concentration in the home through ventilation i.
systems and other technologies.
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None of these variations of raciation exposure, however, come under federal regulation.
The reasons for this should be obvious.
With the exception of any large radon exposure, the l
amounts of radiation involved are relatively small, compared to 1
our exposure to normal background radiation.
And their added health risks are relatively low, as compared to other risks we freely face every day.
Therefore, the costs of regulating such i
variations, if indeed it were at all practicable to do so, would ifar, outweigh any benefits to be gained.
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It is at a level of radiation dosage even below these that i
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the NRC is creating the framework for its new policy.
It is at these very low levels, involving very low health risks, that the NRC would consider broader exemptions from regulation and deem i
certain sources and practices "below regulatory concern."
But specifically just how low is very low, in terms of risks and l
regulation?
Let's turn to that next, as well as describe, specifically, how exemptions would be granted and the exempted materials and services managed.
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p REGULATION AND RISK 24h r.
x We have talked about the nature of radiation and its sources.
both natural and man-made.
We have pointed out some of their
~ dangers and benefits.
And we have discussed the detection and measurement of radiation.
With this as background let's consider the situation facing the nation as its uses and management of radiation and radioactive materials grow.
And along with that grow the responsibilities of the NRC in carrying out its mission to safeguard the health and safety of the public and the environment, In this situation a basic dilemma facing the NRC involves the balancing of risk with regulation, as well as considering costs and benefits.
People look to regulation to protect them, and turn from regulation when its negative effects clearly outweigh any benefits it brings.
In every field where regulation is involved we make such judgements, otherwise life and all its activities would be too restricted and costly.
Take, for example, our use of the automobile, which gives us such tremendous mobility and freedom and has so shaped the economic and social life of our country.
We know the dangers involved in driving a car. It is obvious at higher speeds.
But a one-ton vehicle moving at almost any speed, even down to just a few miles an hour, can cause significant injury and damage. Yet should we impose regulations to eliminate even that possibility, we would find ourselves in cars
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too costly to buy and with rules too oppressive to drive.
We C-t would be driving cars built like tanks or cocoons, on roads lined with signs and traffic controls every inch of the way.
And half our population would have to be police to enforce them.
- Instead, we pass and enforce reasonable laws and regulations and rely on the education and judgement of the individual to determine his own safety and that of his fellow citizen.
As a result we risk a certain number of deaths and injuries.
But, even though we continue to strive to reduce these, both as individuals and a society we accept the risks involved.
We must do so similarly with radiation if we wish to protect ourselves yet enjoy the large and varied number of benefits of the i
atom.
And to a great extent we have.
Then why make changes now?
Why at this point is it necessary for the NRC to alter any rules regulating radiation, rules that have been in effect for years and l
l seemed to have been working?
And how has the Commission arrived at the basis of its new policy, one which will allow certain-i radioactive materials and service to be considered Below Regulatory Concern (BRC) and therefore subject to exemption?
One answer to "why now?" has to do with the large amount of I
low-level waste from the nuclear industry.
Most of this is being j
created by the 115 nuclear power plants in the U.S. today, it is 1
estimated that these plants generate about 60 percent of the low-level wasted disposed of at the three licensed low-level waste i
sites in the country.
Plans have been made to increase this
nu;ber of sites to 16 as well as distribute thea better geographically.
But the development and use of these sites is still a number of years off.
And even then, should any material, no matter how low its radiation, be required to be shipped to and disposed of in these sites, we would soon run out of space not to mention the growing burden of costs that would'be involved.
Actually, of all the low-level waste material that originates from nuclear power plants, both the Environmental Protection Agency (EPA) and the nuclear industry have estimated that about 30 percent -- by volume -- might have a radiation level so low as to be considered "below regulatory concern."
And thet includes clothing, rags, paper and plastics that have been used in radiation areas.
The level of some of these materials is often such.a small fraction of natural background radiation that it is scarcely detectable.
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At the same time that we are talking about the relatively large volume of these potentially exempt materials, it is important to note that the total amount of radioactivity in them
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will be very small.
It is expected to represent only about 0.01 percent of that contained in all low-level waste generated at nuclear power plants.
Thus, the major amount of radioactivity L
associated with low-level waste would continue to be disposed of only at licensed facilities.
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y, Among other things, it was concern with.the large and growing I?g7 volume of these materials that prompted the Congress to pass The Low-Level Radiation Waste Policy Amendments Act of 1985 (PL 99-240), directing the NRC_"to consider the merits of exempting specific radioactive wastes streams from regulation... due to the presence of radionuclides...in sufficiently low concentrations or quantities as to be below regulatory concern."
In addition to nuclear power plants, what other sources mi-ght generate wastes or involve activities that have radiation levels so low as to be possibly considered for BRC exemption?
As we mentioned before, the medical and health professions in dealing with nuclear medicine and biological research generate low-level i
radioactive wastes.
Again, large in volume but very low in radioactivity, this waste might range from swabs, gauze, and other hospital trash, to disposable medical and laboratory materials, to the packaging they came in and the gloves used to handle them.
Under_ current practices, dealing with all this is imposing a growing burden on these fields.
Important health and research
~ facilities must devote an inordinate amount of resources -- both money and the time of trained personnel -- in the special handling y
and disposal of these very low-level radioactive wastes, much of which has already decayed to a barely detectable half-life.
The time and talent of these people, as well as the limited funds of their institution could otherwise be devoted to activities far more beneficial to the public health and safety.
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What other materials and services involve radiation and radioactive wastes in the range low enough to be considered below regulatory concern, and therefore exempt from regulation?
Included in the long list are many that have already received specific exemptions: timepieces (watches and clock with luminescent dials); automobile lock illuminators; marine compasses and navigational instruments; smoke detectors; incandescent gas mantles; glazed ceramic tableware; photographic film; static eliminators; measuring, gauging and controlling devices; luminescent fish lures, and even the release of patients containing radiopharmaceuticals or permanent or temporary radioactive implants.
All this is but a small part of the long list of products and services which could be considered below regulatory concern and therefore be more broadly and expeditiously exempted from regulation.
What levels of radiation and risk place all these products and services in the category considered below regulatory concern?
And how did the NRC arrive its new criteria, along with its principles of exemption, for a formal BRC policy?
First the principles: A major consideration in exempting any practice from regulatory control hinges on the question of whether the control is necessary and cost effective in reducing a small risk.
When it comes to radiation, as the dose and its risks to the exposed population decrease below the public dose limit, the need for regulatory control decreases.
At a sufficiently low level of risk, the NRC believes that the granting of specific
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exemptions from regulatory controls should depend essentially on an evaluation of whether the overall individual and collective 1..
risks are sufficiently small.
Therefore, the NRC believes that individual and population dose criteria should be basic features f
of its overall policy.
That policy should define the region where expending more resources to-bring about further incremental-compliance with the principle of reducing radiation "as low as reasonably achievable" (ALARA) is no longer warranted.
The question then is:
How low is low?...or more precisely sufficiently low...when it comes to risks and rems?
At what point would there be little merit in paying more to further reduce the risk or dose?
In deciding this in terms of radiation dose to the individual, the NRC looked at the matter from two perspectives.
The first related to quantitative risk levels.
Here the Commission learned that most members of society would not expend resources to reduce further an annual fatality risk below approximately 1 chance in 100,000.
Now compare that risk level to the-1 in a 2 million selected by the NRC in the development of its
-- a risk level
'safety goal policy for nuclear power reactors equal to 0.1 percent, or 1/1000, of the sum of cancer fatality risk from all other causes.
The second perspective is based on those variations in dose, and therefore risks, knowingly or unknowingly tolerated by l
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they live.
Related to this the Commission noted that people don't
-spend resources to reduce the differential exposures associated with variations in natural background radiation; for example, the 50-60 mrem per year difference between annual doses received in Denver, Colorado vs. Washington, D.C.
Nor do they spend more to reduce the difference in doses between living in a brick or frame house, or to eliminate the 5 mrem dose one would receive in a round trip coast-to-coast air flight, or to lower the dose from other activities involving a small fraction of background radiation.
Taking all this into consideration, as well as the uncertainties involved in risk assessment at low doses, NRC decided that an individual dose of 10 mrem per year would be appropriate for use as the initial criterdon that would define whether or not additional resources need to spent to comply further with the ALARA principle.
However, until they gained more experience with the potential for individual exposure from multiple sources, the Commission decided that an interim individual dose criterion of 1 mrem per year would be applied to those practices involving widespread distribution of material containing radioactive substances, such as consumer products or recycled material and equipment.
How do these dose levels translate into risks?
The 10 mrem per year corresponds to an annual risk of 5 in 1 million.
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The 1 crem per year corresponds to 5,in 10 Dillion.
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almost any risks considered in our society these risks are extremely small.
J NRC considers these criteria to be appropriate even given the uncertainties involved.
And it notes that, with these values, 1
implementation of its policy in future rulemaking or licensing i
decisions should be a practical undertaking, it alsS believes i
that reasonable assurance can be provided that individual exposures to the public from all licensed activities and exempted practices would not exceed 100 mrem per year.
Such assurance is based on the fact that the Commission intends to:
- define practices broadly
- evaluate potential exposures over the lifetime of the practice
- monitor and verify how exemptions are implemented under this policy, and
- impose a companion collective dose criterion in
- defining when further application of the ALARA
- principle is unwarranted.
What is a " collective dose?"
Jt is the sum of individual l
doses received in a given period by e specified population from l
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a specific source of radiation.
In deterraining the collective dose criterion, the Commission believed that if the collective Y
dose resulting from a given practice is less than 1,000 person-rems per year (equivalent to 100,000 individuals receiving 10 mrems per year), resources would be better spent addressing more significant' health issues.
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With these criteria for both individual and collective exposures the NRC would have a strong basis for granting exemption j
from regulatory control for certain products or activities.
But they represent only a basis.
Other specified conditions would also have to'be met, such as lack of significant risk from accident or misuse.
And the Commission would place cC.ditions or constraints, such as limits on the total quantity of radioactivity and the transfer of materials from controlled to uncontrolled in addition, NRC would continue its program of inspection
- status, and enforcement for that process, i
It should be emphasized that the BRC policy statement -- more precisely the setting of the dose criteria -- does not constitute a decision to exempt any specific consumer product, waste or other material from regulatory control.
It is instead a guideline for such exemption.
Just how would such a policy be implemented?
Its provisions would be carried out principally through the NRC's rulemaking l
process.
However, exemption decisions could also be made through l
specific licensing actions.
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In the first case, a proposal for exemption, whether initiated by the NRC or requested by outside parties in a petition for rulemaking, would have to provide a basis upon which the Commission could determine if the basic policy conditions have been satisfied.
Such a proposal would have to address the 1
individual and societal impact that could result if the exemption were granted.
To do this the proposal would have to consider the uses of the radioactive materials, their pathways of exposure and their levels of radioactivity, it would also have to consider the methods and constraints for assuring that the assumptions used to define a practice remain appropriate as the radioactive materials move from a controlled to an uncontrolled status.
Any such rulemaking action, it should be emphasized, would have to follow the Administrative Procedure Act.
And this requires publication of the proposed rule in order to solicit public comment on it.
The rulemaking action would also include an appropriate level of I
environmental review under the National Environmental Policy Act.
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The second means of implementing BRC policy would involve exemptions granted through licensing actions.
Such actions may be subject to public hearings, in addition, before any specific exemption is granted, an announcement would be published in the l-l Federal Register to explain clearly the details and particular circumstances associated with the proposed exemption.
The public would then have an opportunity to comment on'the proposed exemption.
And their comments would be considered before the Commission made its final decision.
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AND BEYOND BRC?...
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Now, having gone through all this examination and consideration on its path to exemption, would the material or i
practice now "below regulatory concern", move beyond all concern to the NRC7 Absolutely not.
It would, in effect, move to exempt status in accordance with specific controls and conditions established in the exempted regulation.
And that might include, for example, labeling requirements for consumer products so that consumers can make informed decisions about the products.
- Also, NRC will conduct periodic research to evaluate and confirm the
$6fety bases of the exemptions.
In short, BRC is not just a way of placing radioactive substances, no matter how low and relatively harmless, out of l
sight and hence our of mind.,And it is certainly not
" uncontrolled dumping" as some uninformed people might fear.
It is instead a comprehensive program, one researched and thought out l
fully by the most knowledgeable and concerned people in the field i
L of radiation standards, protection and regulation.
It is also one that take into consideration and is based on the latest research, information and judgements of the world's foremost authorities L
dealing with radiation.
Among these are the National Council on i
i Radiation Protection and Measurements, the International Atomic Energy Agency, the International Committee on Radiation Protection, and groups and individuals associated with the National Academy of Sciences.
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- 7 In. addition to all this, it should be emphasized that even af ter materials and practices, including wastes that might go into l
local landfills, are exempted as below regulatory concern by the NRC, they would still be subject to State and local regulations.
I And federal agencies, such as the EPA and the Consumer Products I
Safety Commission, as well as the NRC, would cooperate closely with State and local governments in their handling of these.
The end result should be, then, that the pursuit of a BRC policy should result in greater protection of the public from radiation, as more enlightened and efficient ways of dealing with l
1 it come to light and into use.
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in general, we need.to move into a more enlightened and efficient era in managing the atom -- both its benefits and risks.
The Nuclear Age is here to stay, regardless of those who may still want to wish it away.
And natural radiation is a fact of life that can never be wished away.
Together they must be dealt with intelligently and knowledgeably.
Fear und ignorance are our worst 1
enemies when it comes to controlling radiation,'just as they are l
im our dealings with any of the other'new and powerful tools and technologies modern science is now giving us.
All these make new demands on us -- physically, mentally and morally.
They require us to work harder, smarter and more cooperatively to create and share new benefits and to avert and reduce new risks.
T i
s nu I *,
e ML That is what the NRC is attempting to do in pursuing a It is in reality showing policy called Below Regulatory Concern.
more concern for the ways that radiation is managed, and for the ways our resources are allocated in order to focus more effectively on the health and safety of the public. In doing so it will be accomplishing an important part of its proscribed mission.
And it will be better meeting its responsibility to the American people.
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