ML20096H657
| ML20096H657 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1995 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| NUREG-1530, NUDOCS 9601290154 | |
| Download: ML20096H657 (23) | |
Text
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Reassessment of NRC's Dollar Per Person-Rem Conversion Factor Policy U.S. Nuclear Regulatory Commission Office of Nuclear Regulatory Research
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e NUREG-1530 Reassessment of NRC's Dollar Per Person-Rem Conversion Factor Policy i
Manuscript Completed: December 1995 Date Published: December 1995 Division of Regulatory Applications Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 205554)001
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f ABSTRACT The Nuclear Regulatory Commission has an undiscounted $1000 per person-rem completed a review and analysis of its dollar per conversion factor that served as a surrogate for all person-rem conversion factor policy. As a result offsite consequences (health and offsite property).
of this review, the NRC has decided to adopt a This policy shift has been incorporated in
$2000 per person-rem conversion factor, subject it
" Regulatory Analysis Guidelines of the U.S.
to present worth considerations, and limit its Nuclear Regulatory Commission,"
sc. ope solely to health effects. This is in contrast NUREG/BR-0058, Revision 2, November 1995.
in the previous policy and staff practice of usmg l
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iii NUREG-1530
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i CONTENTS 1
4 Pkge ADSTRACT.............................................................................
iii AB B R EVI ATI O NS.......................................................................
vii 1
BA C KG R O UN D.....................................................................
1 2
HISTORICAL DEVELOPM ENT......................................................
1 3
R EG U LATORY APPLICATIONS....................................................
3 3.1 Routine Emissions from Nuclear Power Plants......................................
4 3.2 Acci dental Releases...............................................................
4 i
3.3 Part 20 ALARA Program..........................................................
4 4
TECHNICAL STUDIES AND REVIEWS.........
5 5
SCOPE OF DOLLAR PER PERSON-REM VALUE.....................................
6 6
APPROACHES TO VALUING THE HEALTH DETRIMENT..........................
7 6.1 H uman Capital Method..........................................................
7 6.2 Willingness-to-Pay Method........................................................ -
8 6.3 Values Implied by Government Agency Expenditures................................
10 i
6.4 Values Implied by Regulatory Requirements Imposed by Government Agencies.........
10 6.5 Values Based on Radiation Protection Activities in Other Countries....................
10 6.6 Representative Value of a Statistical Life..................
11 7
RISK COEFFICIENTS FOR STOCHASTIC HEALTH EFFECTS........................
11 S
DOLLAR PER PERSON-REM CONVERSION FACTOR...............................
12 9
IMPLICATIONS OF REVISED CONVERSION FACTOR POLICY......................
13 10 PROCESS TO INCORPORATE THE REVISED DOLLAR PER PERSON-REM VALU E AS NRC PO LICY............................................................
14
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ABBREVIATIONS ALARA as low as reasonably achievable NCRP National Council on Radiation BEIR V Committee on the Biological Protection Effects ofIonizing Radiation NEPA National Environmental Policy Act BNL Brookhaven National Laboratory NRC Nuclear Regulatory Commission CPSC Consumer Product Safety OMB Office of Management and Budget Commission OSHA Occupational Safety and Health DOT Department of Transportation Administration EPA Environmental Protection Agency PNL Pacific Northwest Laboratory GDP gross domestic product PRA probablistic risk assessment GESSAR General Flectric Standard Safety SAMDA Severe Accident Mitigation Design Analysis Report Alternative GI generic issue TMI Three Mile Island -
HECOM Health Effects Cost Model UNSCEAR United Nations Scientific ICRP international Commission on Committee on the Effects of Radiation Protection Atomic Radiation USI unresolved safety issues MACCS MELCOR Accident Consequence Code System WTP Willingness-to-Pay vu NUREG-1530
L BACKGROUND approaches for arriving at a conversion factor. In addition, questions have surfaced on the For approximately the last two decades, the U.S.
continued validity of the $1000 per person-rem Nuclear Regulatory Commission (NRC) and its conversion factor because basic parameters such pr:decessor agency, the Atomic Energy as the value of the dollar and risk factors (e.g.,
Commission, have used a conversion factor of latent cancer fatality estimates per person-rem)
$1000 per person-rem as the monetary valuation have changed considerably over this period. Such l
of the consequences associated with radiological factors have potentially significant effects on the exposure. That is, an increase or decrease in appropriateness of the $1000 per person-rem person-rem is valued at $1000 per person-rem in conversion factor. In the NRC's view, a thorough order to allow a quantitative comparison of the reassessment of the dollar per person-rem value and its application in NRC regulatory values and impacts associated with a proposed decisionmaking is needed.
regulatory decision.
This value has been used as a reference pom. t in The NRC's revision is based on a relatively simple NRC regulatory analyses including those and straightforward logic in which the new dollar 2
involving (a) routine emissions, (b) accidental per person-rem conversion factor attempts to releases, and (c) 10 CFR Part 20 as low as capture the dollar value of the health detriment reasonably achievable (ALARA) programs.
resulting from radiation exposure. As such, the proposed formulation considers the dollar value The NRC prepare,s regu,latory analyses for of the health detriment, and a risk factor that proposed actions imposing requirements on establishes the nominal probability for stochostic heensees. The pnalyses melude an examination of health effects attributable to radiological the values and impacts associated with alternative exposure. The latter term takes into account fatal approaches to meetmg the particular regulatory ard non-fatal cancrrs, and hereditary effects. It objectives. The conclusions and needs to be emph'. sized that the resulting dollar recommendations included m a regulatory per person-rem convenion factor is not applicable analysis are neither final nor bindm, g, but rather to deterministic health effects, including early are intended to enhance the soundness of fatalities, which could result from very high doses decisions made by NRC managers and the to particular individuals. In this way, the Commission. Regulatory actions needed to ensure conversion factor is compatible with the adequate protection of the health and safety of Commission's Safety Goal Policy wherein the the public [see section 182(a) of the Atomic Commission made clear that no death will ever be Energy Act and 10 CFR 50.109(a)(4)(ii)] from the
" acceptable" in the sense that the Commission operation of production and utilization facilities would regard it as a routine or permissible event.
do not require a regulatory analysis. Thus the
$1000 per person-rem conversion factor does not
- 2. HISTORICAL DEVELOPMENT apply to these actions, except in assessing possible alternative approaches to achieve the necessary level of adequate protection.
The issue of assigning a monetary value to radiation dose in regulatory decisionmaking arose l
Over the years, the NRC Las become increasingly in 1974 during the hearing for a rulemaking l
aware of alternative estimates and methodological addressmg routme emissions from nuclear power reactors (the rule subsequently issued appears at 10 CFR Part 50, Appendix I)3 In adopting design 11n order to be consistent with the Commission's policy on Criteria for limiting routine emissions from power
"* 'IerIn"[n isIev"e"r*i Nt" "'*'Ya[ue $ rYg7u"n5s fNingplants, the Commission argued for a cost-benefit perp the parenthetically. Note that a sievert is equal to 100 rems.
test. The Commission felt that "such a
'Iherefore, for example,51000 per person-rem is equal to $1000 per person csv. Ilowever, for purposes of contmuity and to cost-benefit analysis requires that both the costs laer ew, d Ian per penon-rem shall be the unit used 2Guidance for the preparation of NRC's regulatory analyses is in e r1 is cas b h e ah *f Regulatory Analysis Guidelmes of the U.S. Nuclear Regulatory Commissiort. NUREG/BR-0058, Rev. 2-Radioactive Materisiin Ugnt-water-Cooicd Nuclear Power Reactor IMfluents, Opinion of the Commission, April 30.1975.
1 NUREG-153G
and the benefits from the reduction in dose levels prioritization, and resolution of USI's and generic to the population be expressed in commensurate issues (GI). Guidance relating to the assignment units, and it seems sound that these units be units of priorities was issued in 1982, with the of money. Accordingly, to accomplish the publication of "A Prioritization of Generic Safety cost-benefit balancing, it is necessary that the Issues," NUREG-0933. The guidance included worth of a decrease of a person-rem be assigned the use of the $1000 per person-rem value in monetary values."4 setting the priority of USIs and GIs. Issues identified as high priority were then subject to The Commission stated that "the record, in cur resolution via a more detailed value-impact view, does not provide an adequate basis to analysis that also utilized the $1000 per choose a specific dollar value for the worth of person rem value. In both these contexts, the decreasing the population dose by a man-rem."
$1000 per person-rem value has been used as a Published studies at that time that were figure of merit and as one factor in the respective mentioned in the record of the rulemaking, gave assessments.
values ranging from $10 to $980 per person-rem.
The Commission concluded that "there is no In January and December 1983, the NRC consensus in this record or otherwise regarding published NUREG/BR-0058, " Regulatory the proper value for the worth of a manrem," and Analysis Guidelines of the U.S. Nuclear that "we also recognize that selection of such Regulatory Commission"(Guidelines), and values is difficult since it involves, in addition to NUREG/CR-3568, "A Handbook for actuarial considerations that are commonly Value-Impact Assessment"("1983 Handbook"),
reduced to financial terms, aesthetic, moral, and respectively. These documents were issued to human values that are difficult to quantify."5 The formalize NRC's policies and procedures for final outcome was a Commission decision to analyzing the values and impacts of proposed adopt as an interim measure, the value of $1000 regulatory requirements. The $1000 per per person-rem for cost-benefit evaluations.6 person-rem figure was not mentioned in the 1983 Guidelines or in Revision 1 to the Guidelines Two Executive Orders is. sued during the Ford issued in May 1984, but the accompanying 1983 administration (E.O.11871 and E.O.11949)
Handbook recommended that the analyst use a encouraged Federal agencies to perform range of values, one of which should be $1000 per value-impact type evaluations of proposed person-rem.7 Since the 1983 Handbook provides regulatory requirements to demonstrate adequate the implementation guidance for performing NRC justification for new requirements. The NRC regulatory analyses, it became standard practice i
became committed to this type of evaluation, and of the NRC staff to apply this guidance whenever issued Value-Impact Guidelines in December 1977 a quantitative regulatory analysis or value-impact (SECY-77-388A). This document referred to the analysis was performed.
techniques and detailed consequence analyses used in the Reactor Safety Study, WASH-1400, and The NRC requires a regulatory analysis for a recommended that the person-rem averted from broad range of regulatory actions. In general, all proposed changes be multiplied..."by $1000 per mechanisms used by the staff to establish or man-rem (or other agreed upon value)," in order commumcate genenc requirements, requests, or I
to place the benefit (value)in the same units as staff positions, that would affect a change in the cost (impact).
use of resources by its licensees will include an
)
accompanying regulatory analysis. These In 1977, Congress added Section 210 to the mechanisms include rules, bulletins, generic Energy Reorganization Act of 1974, directing the letters, regulatory guides, orders, standard review NRC to develop a tlan for the identification and plans, branch technical positions, and standard analysis of unresolved safety issues (USI) relating technical specifications. Thus, staff guidance on to nuclear reactors. In response, the NRC value-impact and regulatory analyses has developed a program for the identification, provided the NRC with a mechanism to consider
$1000 per person-rem as a figure of merit in most Clideral Register. May 5,1975 (40 l'R 19439), page 19439.
W 7s. W. Ileaberlin, et al.. "A llandtxxik for %lue-Impact CIbid.
Assessment," NUREGCR-3568 section 3.2.2.,1983.
regulatory decisions affecting power reactor as Operations to the Commissioners.10 His well as nonpower-reactor licensees. In practice, interpretation was subsequently adopted in all however, a number of regulatory analyses did not NRC regulatory analyses and value-impact quantify the person-rem averted and thus did not analyses in which offsite radioactive releases were use a dollar per person rem value, subject to monetary valuation.
In 1983, the NRC issued an interim Policy In February 1982, as part of the nree Mile Island Statement on Safety Goals for the Operation of (TMI) Action Plan, the Commission promulgated Nuclear Power Plants for use during a 2-year trial 10 CFR 50.34(f)(1)(i) that required certain nuclear period.8 In this statement, the Commission power plant license applicants to prepare adopted qualitative anJ quantitative design goals plant-specific probabilistic risk assessments for limiting individual and societal mortality risks (PRAs) to identify possible design alternatives for from severe accidents. Also in this Statement, the nuclear power plants. As a result of this rule, Commission stated that the benefit of an value-impact analyses were prepared in 1985 for incremental reduction of societal mortality risks the GESSAR (General Electric Standard Safety should be compared with the associated costs on Analysis Report) design. Eighty design-specific the basis of $1000 per person-rem averted as one enhancements were analyzed with $1000 per consideration in decisions on safety person-rem used as the screening criterion. PRAs improvements. The value proposed was in 1983 are now used for existing operating nuclear power dollars and was to be modified to reflect general plants (as a result of NRC Generic Letter 88-20) inflation in the future. At tne end of the 2-year and for future reactor designs.
interim period, a number of comments were received on this value. Widely different values In February 1989, the U.S. Court of Appeals were suggested ranging from about $100 per directed the NRC to consider Severe Accident person-rem to values in excess of $1000 per Mitigation Design Alternatives (SAMDA) as part person-rem. Respondents who believed the $1000 of the NRC's environmental review process under value was too low did not provide another the National Environmental Policy Act (NEPA) before granting a full wer license to owners of number, but merely indicated that the value should be raised. Discussion of $1000 per nuclear power plants.pI De staff subsequently person rem, and any proposed use, were deleted performed SAMDA analyses for the Limerick and m the Final Policy Statement on Safety Goals Comanche Peak nuclear power plants. A when published in August 1986 (51 FR 30028),
SAMDA analysis was also prepared for the following completion of the 2-year trial period.9
" Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants" In 1985, the NRC staff revisited the $1000 per (NUREG-1437). In all these cases, the staff used person-rem valuation and its use in regulatory the $1000 per person rem value as a screen to analyses of nuclear power plant improvements compare values and impacts. If designs were designed to enhance safety. Although the withm an order of magnitude of being justified, monetary value of averted person rem of radiation they were analyzed further. No design changes exposure up to that time referred only to averted were deemed necessary as a result of these health effects, (for example, averted latent cancer SAMDA analyses.
fatalities), the use of $1000 per person-rem was evaluated and subsequeatly defined at that time
- 3. REGULATORY APPLICATIONS as a surrogate for all as erted offsite losses, health De $M er Person-rem conversion factor has P
et r nat n s na o r
,1 85, e
memorandum from NRC's Executive Director for gulato appi cat o s includi t.
aluation of (1) routine emissions from nuclear power plants, sU.s. Nuclear Regulatory Commission. " safety Goals for Nuclear 30 Memorandum. w. J. Dircks to Commission. ** Danis for Power Plant Operauon." NUREG-0880. Rev.1. May 1983.
Quantifying off-site Property lonnes." october 23.1985.
o mmiss r
n (51I 3 33) 3 3
(2) accidental releases, and (3) radiation
$1000 per person rem criterion because of the protection practices.
relatively high cost of the design alternatives.
3.1 Routine Emissions from Nuclear Power 3.2 Accidental Releases Plants A frequent use of the $1000 per person-rem The only place the $1000 per person-rem value valuation has involved NRC programs, reviews, currently appears in the NRC's regulations is at and decisions in which accidental radiological 10 CFR Part 50, App. I(Sec. II)(D)in a releases are a consideration. This is because 3aragraph relating to items to be included in a safety enhancement regulatory actions constitute a
.icense applicant's radwaste system. Essentially, in major NRC initiative, and accidental releases tend designing the radwaste system, the licensee is not to be a dominant factor m these regulatory required to install additional effluent controls to decisions.
reduce routine emissions below 3 millirem per From a procedural standpoint, the $1000 year for water effluents and 5 millirem per year conversion factor has also appeared to function as for airborne effluents if the cost of the resultant.
a useful guide in regulatory decisions in which reduction in the exposure of the population within accidental radiological releases are a 50 miles is greater than $1000 per total body consideration. As noted in Section 2 of this l
person-rem or $1000 per person-rem to the report, since 1985, the $1000 value has been thyroid.
nterpreted by the NRC to include an allowance The $1000 per person-rem criterion has served as f r all offsite property consequences of a nuclear a significant decision factor in NRC's radwaste power plant accident. This broader design approval decisions for nuclear power nterpretation can be problematic for the reasons plants. Guidance for performing the dose n ted in Section 5 of this report.
calculation and resulting dollar valuation is 3.3 Part 20 ALARA Program contamed in the NRC,s Regulatory Guides 1.109 and 1.110, respectively. Procedurally, applicants The regulation 10 CFR Part 20 establishes for a nuclear plant license are to use $1000 per standards for protection against radiation hazards person-rem in a cost-benefit analysis in order to arising out of activities under licenses issued by justify their radwaste system design. The design the NRC. A guiding principle for Part 20 is then subject to NRC approval and, depending (codified at 10 CFR 20.1101(b)) is for licensees to upon the outcome of this review, possible revision.
make every reasonable effort to maintain Essentially, all nuclear power plant operating radiation exposures, and releases of radioactive licenses issued after 1975 have followed this materials, as low as is reasonably achievable. Part procedure. Although NRC's regulations only 20 applies to all NRC licensees (power reactor, speak to the use of the $1000 per person-rem nonpower reactor, fuel cycle facilities and value in consideration of the radwaste system radioactive source and materials licensees) and design, the staff believes that to some extent it has concerns the release of radioactive material and also influenced licensees' design considerations associated occupational and public dose incurred for radwaste storage facilities.
as a result of normallicensee activities.
From a procedural standpoint, use of the $1000 ALARA is defined at 10 CFR 20.1003 as making per person-rem value as a deterniinant in every reasonable effort to malatain exposures to decisions involving radwaste systems has generally radiation as far below the Part 20 dose limits as is worked well. The decision criterion is well defined practical, taking into account the state of and effective staff procedures and licensee technology, the economics of improvements in guidance are in place. However, from a practical relation to benefits to the health and safety of the perspective the $1000 per person-rem value public and occupational workers, other societal appears to have had relatively little effect on the and socioeconomic considerations, and the raowaste system designs proposed by applicants utilization of nuclear energy in the public interest.
and ultimately approved by the NRC. The reason Given this definition, it would appear that a is that system designs are relatively insensitive to dollar value per person-rem should play a pivotal an increase, within an order of magnitude, in the role in cost-benefit tradeoffs used in establishing NUREG-1530 4
reasonableness under the Part 20 ALARA
- 4. TECHNICAL STUDIES AND program. However, Part 20 itself does not REVIEWS address the use of the $1000 per person-rem value although one regulatory guide 12 (Regulatory Guide 837) suggests its use. In this regard, the As part of the NRC's overall reassessment effort NRC is aware that current industry practice, of an appropn, ate dollar per person-rem particularly in _the power reactor arena, is to value conversion value, the Brookhaven National an averted person rem at a higher dollar value Laboratory (BNL) completed two studies for the owing to manpower constraints and other labor NRC that addressed dollar per person-rem rost considerations that are integral to the valuation. The first, entitled " Cost-Benefit licensees' cost-benefit tradeoffs. Licensees are Considerations m Regulatory Analysis," by V.
encouraged to continue to use such higher values Mubay:, et al.,13 assessed the contm, ued validity of for their own ALARA determinations.
the $1000 per person-rem value. In addition, this study re-evaluated the dollar per person rem value
- Regulatory Guide 837 advises materials licensees based on the more recent state of knowledge that they should consider engineering options to including reports issued by the International achieve ALARA goals in the release of effluents Commission on Radiation Protection (ICRP), the and that modifications should be implemented National Council on Radiation Protection and unless an analysis indicates that a substantial Measurements (NCRP), the United Nations reCetion in collective dose would not result or Scientific Committee on the Effects of Atomic the costs are considered unreasonable. One basis Radiation (UNSCEAR), and the Committec on for reasonableness identified in this regulatory the Biological Effects of Ionizing Radiation (BEIR guide is a quantitative cost-benefit analysis which V) of the National Research Council.
requires the use of a dollar value per unit dose The second BNL study is entitled "Value of Public averted. The Regulatory Guide indicates that
$1000 per person-rem is an acceptable value for Health and Safety Actions and Radiation Dose Avoided," by John W. Baum.14 This report this purpose.
incorporates and builds upon the literature review In 1992 for an enhanced participatory rulemaking contained in the Mubayi work with a focus on recent literature on the value of a statistical life on radiological criteria for decommissioning, the NRC issued a notice (57 FR 58727) that identified that can serve as a representative measure of the issues to be discussed at forthcoming workshops dollar value of the health detnment. In addition, on the proposed rulemaking. One subissue
!he report includes related values of dose avoided dealing with ALARA considerations asked:". if in radiation protection, and agencies and a cost versus benefit analysis were used, what orgamzations m sev,eral countnes were contacted t
monetary value per averted collective dose (i.e.,
by Baum to obtam mformation on the values dollar / person rem) should the Commission use as bem, g used or considered by them.
a basis for making the determination?" In Baum's review identified a wide range of responding to the subissue, only two commenters references and estimates that were categorized mentioned specific values. One recommended a into 11 broad subject areas. The 11 subject areas value of $50,000 per person rem for general pubh.c and corresponding median values for the value of dose reduct,on. Anothe,r stated that even m 1993 saving a statisticallife are as follows:
i dollars, the $1000 value is still higher than most assessments of the dollar value placed on health transportation safety, $0.26 million a
impacts based on real safety or medical policy a
health care actions, $0.37 million decisions. Neither commenter provided a basis for their recommendations.
)
uV. Mubayi, G. Anandalingam, L. Neymotin, and V. Sailor.
" Cost-nenefit Considerations in Regulatory Analysis."
NURIICER4349, Brookhaven National laboratory, Upton, New York, october 1995.
i 1
l'J. W. Inaum. "Value of Public IIcalth and safety Actions and uRegulatory Guide 8.37,"A1 ARA levels for Effluents from Radiation Dose Avoided," NURI!G/CR4212. Brookhaven Materials Facilities." July 1993.
National laboratory, Upton. New York, May 1994.
i 5
o consumer products safety, $0.49 million into account in deriving such a value. The NRC also recognizes that there is a wide divergence in o
values employed by U. S. Government agencies, $ 1.5 views, some of which are highly philosophical in milh,on nature, and thus there is unlikely to be one clearly Preferable choice that will please all interested
)
o consumer choices, $2.2 million parties. Furthermore, the NRC recogm,zes that l
o wage / risk compensation, $2.5 million simplicity, ease of calculation, and providing a readily understandable approach with practical o
willingness-to-pay surveys, $2.7 million application to a wide range of regulatory issues is i
desirable if the dollar per person-rem value is to o
chemical carcinogen regulation, $2.9 million be effectively employed. Overall, the NRC believes' that a reasonable or representative value i
o risk reducing regulations, $6.1 million approach is best suited for NRC regulatory o
. occupational safety, $9 million decisionmaking. The NRC emphasizes that such a value serves as only one mput to the o
radiation related activities, $15 million.
decisionmaker and in fact is unlikely to be a sole determinaat to that decision. The most common The median value of saving a statistical life for application of dollar per person-rem conversion these 11 subject areas was $2.5 million, while the values is as a screening tool in value-impact i
mean was $3.9 million.
analyses where "close" calls would be subject to more detailed follow-up analysis, and more Mubayi's report is somewhat more ambitious in careful scrutiny by NRC management.
that it also translates the value of a statistical life to a dollar per person-rem value. There is In terms of scope, and specifically whether the however a noticeable difference between Mubayi's dollar per person-rem value should cover both conversion and that considered by the NRC in health effects and all other offsite consequencests this paper. Mubayi's translation explicitly of exposure or contamination, the NRC proposes includes present worth considerations whereas in that the dollar per person-rem value serve only as the NRC's formulation presented herein, the a dollar proxy for the health effects associated dollar per person-rem va'ue appears on an with a person-rem of dose, and should not be
'undiscounted basis. However, when used in any used as a surrogate for these other consequences particular regulatory application, NRC value that could be attributable to radiological impact guidance would require it, too, to be exposure. 'Ib the extent other considerations exist, subject to present worth considerations. The these should be calculated separately and difference is largely perceived as procedural incorporated into the overall value-impact although in comparing the staff's and Muhayi's assessment.
dollar per person-rem results, the staff's estimate appears to be significantly larger than Mubayi's Thus, for example, under this approach, for issues result.
involving severe power reactor accidents, offsite property consequences will be estimated based on Readers interested in a more detailed results from the MELCOR Accident understanding of the data and issues underlying Consequence Code System (MACCS). This this report are encouraged to review the Mubayi computer code was developed for the NRC at the and Baum re x>rts. The Baum and Mubayi Sandia National Laboratories and represents a reports have xen published as NUREG/CR-6212, significant advancement in the development of and as NUREG/CR-6349.
severe accident analysis methods, and results in improved offsite economic cost estimates relative
- 5. SCOPE OF DOLLAR PER to earlier consequence code results (CRAC and PERSON-REM VALUE CRAC2). MACCS' economic parameters are in the process of being updated. When completed,
'Ihe NRC acknowledges that the dollar conversion "offsite consequences could include such items as lost wages, Zi" *g"pses ifheeje ted ula na on factor of a person rem is a highly complex issue e
and that a myriad of factors can logically be taken limitations on huntmg and fishing.
representative values for a spectrum of severe exposures involve labor cost considerations, these power reactor accidents will be developed and impacts would be addressed as a separate incorporated in NUREG/BR-0184, " Regulatory additive element in the value-impact analysis.
Analysis Technical Evaluation Handbook." For The intent. therefore, is to provide a generic requirements, these estimates should representative dollar per person-rem threshold provide an acceptable and relatively easy way to value, tied exclusively to health risks, that can be incorporate direct and explicit consideration of used in all NRC regulatoy applications.
offsite property consequences. As noted previously, this would be a departure from the
- 6. APPROACHES TO VALUING THE current NRC practice where the dollar per HEALTH DETRIMENT person-rem value is assumed to include an allowance for offsite property losses.
In this proposed formulation, computation of the Three fundamental considerations underly an updated dollar per person-rem valuation requires approach that separately values the health and consideration of(1) the dollar value of the health other consequences of radiological exposure:
detnment and (2) a nsk factor that establishes tge nommal probability for stochastic health effects (1) Offsite property consequences can vary attributable to radiological exposure. The dramatically depending on the nature, timing, Product of these two elements is the dollar per k) cation, and magnitude of the radiological Person-rem conversion factor.
release. For example, in the case of the Three Mile Island Unit 2 (TM1-2) accident in 1979, With respect to the dollar value of the health r
detriment, the NRC has reviewed the literature on offsite property damage was almast nonexistent.16 the value of a statisticallife. As discussed Alternatively, if a Chernobyl-type release occurred in the United States and led to the same physical previously, the literature is highly diverse and consequences as actually happened in the dollar estimates vary dramatically. Based on the environs of Chernobyl, the offsite damage costs various methodological approaches and individual (not meludmg health-related costs) would likely be case results reported in the two BNL studies, it is in the billions of dollars. Thus, the dollar apparent that vaging degrees of justification exist quantification needs to take mto accou'st the full over a very wide range of values. A review of the spectrum of potential accidents.
more common and relevant approaches to valuation of a statisticallife follows.
(2) Combining health-and nonhealth-related consequences together would overstate he dollar 6.1 Human Cap.tal Method i
valuation of radiation exposure in certain The value of a life saved has often been estimated applications such as occupational doses routine using purely economic considerations. The emissions, doses from contaminated sites, and simplest of these is the human capital approach nonpower reactor accidental releases where offsite in which health effects and life shortening are property losses are not an expected outcome.
typically estimated in terms of lost production and a dollar allowance for medical care. The (3) The sole purpose of the dollar per person-rem production loss, which is the dominant dollar value is to allow the values and the impacts from consideration, is often calculated based on the a change in radioactive exposure to be compared expected lifetime earnings of the individual whose to other factors in commensurate units, that is, life is prematurely ended. For unidentifiable dollars. There is consequently no need to include individuals in the general public, this calculation other impacts such as offsite property or the value is sometimes based on per capita gross domestic of destroyed foodstuffs m the dollar per product (GDP), or per capita income. This model persop eem conversion factor since these items can be and are normally expressed directly in DStochastic health effects,i.e., cancer and heredity disorders, result dollars. Similarly, to the extent that occupational in>m ce is being modified rather than killed as a result of a low dose of radiation. The probability of a cancer resultmg from radiatior increases with increments of dose, probably with no threshold. ICRP Pubhcation 60. "1990 Recommendations of the SU.s. Nuclear Regulatory Commission, special Inquiry Group, International Commission on Radiological Protection." Vol. 21,
'"nuee Mile Island. A Report to the Commissioners and the No.13, pubhshed for the ICRP by Pergamon Press, Oxford, Pubhe," NURIDCR-1250, Vol. II, Part 2.
UK, p. 69,1991.
does not directly attribute a monetary burden to pain and suffering, a best-estimate for the value of physical and psychological suffering.
a statistical life is on the order of about $500,000.
According to Baum, per capita income in 1990 The human capital approach reduces the value of was about $50 per calen' ar day. The average human life to only economic considerations, and d
value of a statistical life saved can then be as such, has many recognized shortcomings.20 estimated from the average life-span shortening This approach typically ignores pain and expected if the risk is not avoided. For -
suffering, lost enjoyment of life, and the value to radiation-induced cancers, this averaps about 15 family and community that is not reflected in years,18 yielding a value of statistical life saved of GDP. It also has an implicit assumption that about 15 yr x 365 day /yr x $50/ day = $270,000.
nonproductive individuals, (e.g., retired,
- Adding costs of medical treatment would increase unemployed) have minimal value. A report this by about 20 percent, whereas discounting prepared for the Administrative Conference of the future earnings and costs using a representative
' United States concluded that by 1988, use of the discount rate would approximately halve the value human capital method to value a statistical life in of a statisticallife on a present worth basis.
regulatory situations had lost whatever adherents it formally had.21 Mubayi's report includes discussion of NRC-sponsored research conducted by the Pacific Interestingly, note that in 1993, the Health Physics Northwest Laboratory (PNL). PNL developed the Society issued a policy statement that linked the
" Health Effects Cost Model"(HECOM), which dollar valuation of a person rem to the portion of utilizes the health effect incidence estimates from gross domestic product currently being spent on accident consequence models to calculate the -
extending life expectancy.22 Computationally, this discounted sum of the economic costs associated valuation is very similar to the human capital with population exposure to ionizing radiation.19 approach although its intention is not to assign a Direct costs include expenses for medical value to human life, but rather to optimize the use treatment for specific acute injuries, and delayed of limited resources for improving life expectancy somatic and genetic effects. Indirect costs are and health benefits, when all risks are considered.
evaluated in terms of " loss of human capital" (i.e.,
This approach produces recommended values the productivity loss to society as a result of ranging from $40 to $200 per person-rem.
illness and premature death). Productivity loss is m:asured in terms of wages, modified to melude 62 Willingness-to-Pay Method nonwage-earning labor (household services).
HECOM does not directly attribute a monetary The value society (i.e., an average person) places burden to physical and psychological suffering.
on improving safety is frequently based on the
" willingness-to-pay"(WTP) approach. In theory, Estimates of the value of avoided dose were made if there were a market for " buying" safety, then by Mubayi using the HECOM model.
this approach would yield the price that the -
Calculations were based on 20s and 30-year old average " consumer" would be willing to pay to male and female populations, and future medical reduce the probability of death or what they costs and the loss of future earnings were subject would accept to have that probability increased.
to present worth considerations based on 3 By using such an approach, the valuation of risk percent and 7 percent real discount rates.
reduction is believed to reflect societal Mubayi's results were updated to 1990 dollars preferences and when applied in a cost-benefit using the inflation data from the medical costs framework will, in theory, reflect correct public and consumer price indices over this period, allocation decisions. Quantification can, however, Based on Mubayi's adjustments to the HECOM D,".'1, January-February 1984.M M,*,"f' AP model, exclusive of any adjustments to account for 123,No aslCRP, op. cit., p.134.
"L A. Nieves and J. J.~Ihwil. "Ihe Economic Costs of 4
N Nort b
ory' 22 Health Physics society," Position sasement on Radiation Dame August 1988.
Umits for the General Public, Part II." March 1993.
%,,4
.z m
m
1 l
I l
I be very difficult and the method is criticized relatively inexpensively should have little bearing l
because of the large uncertainties in derived on this consideration.
values. Nevertheless, many believe that such an approach is preferred to alternatives for A second WTP approach involves wage-risk estimating the value of a statistical life, compensation. This is one of the most thoroughly particularly the human capital approach. The studied approaches and presumes that the value WTP approach is recommended by the Office of that workers place on their hves is measurable Management and Budget (OMB) as the preferred based on observed wage differentials in methodolgo for monetizing changes in the risk of occupations of varying risks. An advantage of fatalities. In addition, Recommendation No.
this approach is that quantification is relatively 88-7 of the Administrative Conference of the easy because it is based on situations where real United States states that "WTP provides the most markets actually exist. Limitations of the inclusive analysis currently available for wage-risk approach include workers (1) that may evaluating the benefits derived from regulatory not know the extent of risk in particular reduction of fatalities."
occupations:(2) that may not be able to change occupations freely where risks are of concern; and WTP studies related to valuing a statistical life (3) that may not incorporate the pain and can be grouped into three categories: consumer suffering of friends and relatives, some of whom market studies, w may be economically dependent on the worker, in valuation studies.3a 'e-risk studies, and contingent their decisionmak?ig. Further it has been argued a
that, in many instances, wages and job-related The first category of WTP studies involves fatalities seem to be inversely related since society's WTP based on actual consumer market low-wage occupations tend to have a higher studies. Such studies typically examine the fatality rate than high-wage occupations. The tradeoffs between risk and benefits that people Baum report identifies over 30 individual wage make in their consumptive decisions (e.g., seat risk studies. For many of these studies, belts, medical diagnostic tests, etc.). Based on adjustments were made to try and make the their cost and probability of saving life, the cost studies as comparable and consistent as possible.
of saving a life could be viewed as a proxy for the On this basis, Baum reports value of statistical value of a life saved. In reality, however, many of life estimates in 1990 dollars in a relatively narrow these safety features reflect highly cost-effective range ($1.2 million to $3.7 million) and a median ways to save lives and may understate wir '
value of $2.5 million.
society is willing to spend to avert death... s a result, although such estimates provide an The third WFP approach, contingent valuation interesting and important perspective (i.e., what studies, involves survey techniques to elicit society is spending to save life), the upper end responses to questions that postulate hypothetical values of $2.2 to $3.4 million from Baum's market choices. The respondents are presented consumer market review appear to more factual information, often during a personal appropriately reflect the value of an averted interview. This information includes a detailed death. This is because the dollar conversion description of the goods being valued and the factor of concern to the NRC is a threshold value circumstances under which they are being made that reflects how much society is or would be available. Respondents are queried on the price willing to spend to avoid a statistical death. The they would be willing to pay for the goods, as well I
fact that, for certain risks, life can be saved as the respondent's own personal characteristics i
(e.g., age and income). The questions are carefully designed to minimize bias, and various techniques are used to randomize the sample and "ofrice of Manrgement and nudget. *' Regulatory Impact Analysis eliminate " poor" quality data. Although in theory this approach should most closely define society's 8
ni ed st tes ernm nt: April 1 9 - h rc 31, 9..
Document No. s/N 041-001-003884, U.s. Government Printing price for buying safety, it is also thC most difficult Office, washington. DC.
to quantify. Moreover, the public's perception of MA Fisher, L G. Chestnut. and D. M. Wiette. "Ihe Vaiue of Reducing Risks of Death: A Note of New Evidence."lournalof obtamed from analytical studies. Also, the means j
hiicy Analysis and Managment. Vol. 8. No.1, pp 89,1989.
or approaches to measure the public's perceptions l
l 9
are often open to a variety of interpretations, Travis, et al. concluded that when lifetime cancer resulting in answers that are inconsistent or risk exceeds about 4 x 10-3, chemicals were inappropriate because of differing and undefined regulated regardless of cost. Alternatively,if the assumptions. Given these considerdtions and lifetime risk ranged from 104 to 4 x 10 limitations, Baum reports value of statisticallife regulations were only implemented if the value of estimates in 1990 dollars ranging from a low of a statistical life was less than $2 million. Thus,
$0.1 million to a high of $15.6 million, with a the relevance of relatively high dollar estimates of median value of $3.1 million, the value of a statistical life derived from previous regulatory decisions is uncertain or unclear, since 6.3 Values Implied by Government Agency it is most likely that in these instances the Expenditures decision was not based on a cost-benefit analysis but rather was based solely on the unacceptability The Baum report summarizes studies where the of the risk.
value of saving a statistical life can be implied by the expenditures of Government agencies in the Baum cites examples of other regulatory actions United States. Baum groups these studies into taken by the Department of Transportation expenditures on health care, traffic safety, and (DOT), the Environmental Protection Agency programs to reduce radiation exposure. The (EPA), the Occupational Safety and Health studies imply values of saving a statistical life over Administration (OSHA), and the Consumer a wide dollar range: all amounts are in 1990 Product Safety Commission (CPSC) where the dollars.
implied value of a statisticallife in 1990 dollars ranges from $130,000 to $91 billion. Recent work The health care expenditures data imply a value by Van Houtven and Cropper suggests that the of a statisticallife ranging from $12,000 for implied value of a statistical life used by EPA in scoliosis and neuromuscular disease to $2.6 regulating asbestos under the Toxic Substances million for kidney dialysis. The traffic safety data Control Act and pesticides under the Federal imply values ranging from $85,000 for regulatory Insecticide, Fungicide, and Rodenticide Act falls and warning signs to $710,000 for clearing between $49 and $52 million (measured in 1989 roadside recovery areas. Implied values from dollars). 26 OMB has compiled a list of a large government expenditures to reduce radiation number of Federal agency actions where the cost exposure range as high as $490 million to reduce of a premature death averted (in 1990 do'lars) as exposure in the defense high-level radioactive a result of an agency's regulatory actions ranges waste program. The comparable figure for the from $.1 to $5,700,000 million. 2 civilian radioactive waste program is $44 million.
6.5 Values Based on Radiation Protection 6.4 Values Implied by Regulatory Activities in Other Countries Requirements Imposed by Government Baum's review included contacting other countries Agencies to obtain information on their cost-benefit Baum also includes a number of examples in his guidance in dealing with radiation protection, report where a value of a statisticallife can be issues. In the United Kmgdom (UK), the National inferred from the costs associated with Radiological Protection Board (NRPB) has implementing safety-related regulations. His considered both the human capital and Wrl, report reviews data published by Travis, et al.25 approaches m estimatmg an appropnate value of on the costs and risk reduction of 11 regulations statisticallife. Up until about 1990, the NRPB issued by Federal agencies involving chemical
'.sted usmg values based on WTP because of, m, carcinogenic products. Values (in 1990 dollars) their view, the paucity of reliable WII data, per fatal-cancer avoided range from $0.04 million Recently, the NRI B has cited with approval a for chromium to $25 million for chlorobenzilate.
recommendation for a value of statistical life m, The median value is $2.9 million (Baum, Table 8).
the range of about $3 milhon to $4.5 milh,on, and 2G. L Wn Iloutven and M. L Cropper, "When is a life 'Em Catly to save? The !!vidence from linvironmental Regulations,"
25C. C. ' Davis. s. R. Pack. and A. Fisher, " Cost-I!ffectiveness as a Resources, Resources for the Future, p. 6, Winter 1994.
rtetor in Cancer Risk Management," EnvimnmentalInternational.
Vol.13, pp. 469-474,1987.
2'oMH. r,p. cit., p. 28.
NUREG-1530 10
a study 28 indicating a value of statistical life on is representative of values used by other Federal the order of $2.4 million in 1990 dollars, agencies responsible for public health and safety; (4)is in general agreement with values used for it is interesting to note that the UK also h>oked at regulatory decisionmaking in other countries; and the value of statistical life in ddaling with 5)is specifically cited by OMB as a "best transportation safety issues. In 1988, a report estimate" for the value of a statisticallife using sponsored by the UK Department of Transport the WTP approach.29 proposed that the then current reliance on the human capital approach be abandoned in favor of A representative value of a statisticallife and not the WTP approach and that the value of life be an upper bound is appropriate for several set at about $1.0 million (in 1990 U.S. dollars). In reasons. First, the value will influence national 1989, the UK sponsored a WFP survey involving energy-related decisions, and realistic safety-cost over 1000 respondents and professional tradeoffs help to ensure an equitable treatment of interviewers. This study concluded that residents all energy sources or options. Second, a value in the UK were prepared to spend $3.2 million for that is in reasonable agreement with values used certain highway improvements to save a life.
by other Federal agencies involved in health and safety will help ensure risk harmonization and 6.6 Representative Value of c Statistical that decisions throughout the Federal Life Governmer.t reflect an efficient and proper alk> cation of society's resources. Third,if too As noted earlier, the variation in the value of high a value is chosen, money that would statistical life as estimated and used for a number otherwise be available to society to save lives of applications is tremendously broad (less than would not be available, and a regulatory
$100,000 to billions of dollars). However, when requirement could have the perverse effect of viewed critically,it appears that median values for increasing overall mortality risk.30 Finally, a a realistic value of a statistical life tend to sange representative value is a useful guide in making from a low of about $1.3 million to a high slightly decisions on " worthwhile" regulatory initiatives over $3 million. Both higher and lower estimates and reflects one reference point. NRC's were identified and evaluated; however, higher regulatory decisions are ultimately based on estimates seem to result from decisions based numerous considerations of which the results of a primarily on motivations other than the WTP regulatory analysis are but one input. Also, it concept, and lower estimates seem to reflect more bears repeating that the dollar value ultimately the cost of saving a life rather than the value of attached to averted dose will have no effect on life. The NRC also chose to dismiss the human actions deemed necessary by the NRC to ensure capital approach for estimating the value of a adequate protection to the health and safety of statistical life because it understates value by only the public, addressing one aspect of human life.
- 7. RISK COEFFICIENTS FOR The NRC contends that the dollar per person-rem STOCIIASTIC IIEALTH EFFECTS conversion factor should be reasonable and representative, and thus should be consistent with the preponderance of the estimates. A value of a Once an appropriate value of statistical life has statistical life of $3 million seems to best match been estimated, the parameter needed to convert these objectives. This value (1) is consistent with that value to a dollar per person-rem figure is the results from the WTP approach, which is risk coefficient that establishes the nominal recommended by OMB and the Administrative probability for stochastic health effects Conference of the United States, and is most attributable to radiological exposure. 'Ihe favored in the literature; (2) reflects median values national and international bodies (NCRP, ICRP) of a statistical life estimated in many studies;(3) responsible for evaluating and recommending 2*oM n, op. cit.. p. 27.
2nD. Ives. D. 'Ihieme, and R. Kemp. "The statistical value of life "oMn op. cit..'nus concept. rcferred to by oMrl as and safety Investment." Rescach Report No.13. linvironmental "hcalth heahh analysis," is discussed at pages 19-30 of oMll.
Risk Assessment Unit. Unversity of I!ast Anglis. Norwich. UK,
" Regulatory Program of the United states Government" 1993.
document.
11 NUREG-1530
such a value are in close agreement. The NRC accidental releases, and 10 CFR Part 20 ALARA proposes to use the latest recommendations of the programs (i.e., occupational exposures).
ICRP as presented in their Publication No. 60. In Pertaining to occupational exposures, the NRC general, for doses to the general population, their acknowledges that, for ALARA determinations, recommendation is a risk coefficient of 7.3 x 104 many licensees employ conversion factors in per rem.31 This coefficient accounts for the excess of $2000 per person-rem. This is probability of occurrence of a harmful health particularly true in nondesign ALARA effect and a judgement of the severity of the determinations where licensees consider trade offs effect. The coefficient includes allowances for between occupational dose and alternative fatal and nonfatal cancers and for severe technologies and procedures (e.g., additional hereditaiy effects. He nonfatal cancers and shielding, remote or robotic tools). These higher hereditary effects are translated into loss-of-life values are typically influenced by utility-specific l
measures based on a perceived relationship manpower constraints and other labor cost l
between quality of life and loss of life. In this considerations. These are valid utility way, the value of statistical life is applicable considerations in evaluating occupational across all contributors to the total health risk exposures, and licensees are expected to continue coefficient. For NRC regulatory applications, it is to use these higher conversion factors. Further, proposed that the risk coefficient be reduced to such values are not necessarily inconsistent with one significant digit to better reflect the level of the NRC's $2000 value that only captures health accuracy inherent in its derivation. The risk effects, as other impacts such as labor cost coefficient of 7.0 x 104 per person-rem can than considerations can be treated as additive elements be used with the value of a statistical life to derive in the NRC's value-impact analysis.
a dollar conversion factor per person-rem. Using the risk coefficient in this manner has the effect of The NRC acknowledges that there may be unique attributing proportional risks to very small doses circumstances where other dollar conversion even though there is no convincing evidence of factors may warrant consideration. For example, proportional risks at background levels. However, doses to a population whose age distribution is in the absence of such evidence, scientific not representative of the general population could organizations such as ICRP and NCRP have be subject to a different risk coefficient because concluded that it is prudent to assume a linear health risks are directly related to the age relationship for the purpose of planning and distribution of the affected population. Further, implementing radiation protection programs.
recognizing the uncertainties mherent in establishing a representative conversion factor, l
- 8. DOLLAR PER PERSON-R.EM lternative values to capture the uncertainties may CONVERSION FACTOR be warranted. Thus, it would be reasonable to expect an analyst to include alternative valuations in regulatory analyses in order to show the 1
The dollar per person-rem conversion factor for decision maker the sensitivities of the proposed health effects can now be calculated as the action to relevant considerations. However, the product of the value of a statisticallife and the base case computations in a regulatory analysis risk coefficient. Based on the preceding will normally use the recommer.ded dollar recommendations concerning the value of a conversion factor of $2000 per person-rem.
statistical life ($3 million) and the risk coefficient far stochastic health effects (7.0 x 10 ), the dollar The dollar per person-rem conversion factor is for 4
determimstic effects.y2 stochastic effects onl and is not to be a conversion factor for health effects would equal It should also not be
$2100 per person-rem. Given the large uncertainties already inherent in this approach, it applied to any individual dose that could result in would appear reasonable to adopt a dollar an early fatality. Rese omissions are consistent conversion factor rounded to the nearest thousand with NRCT view that the monetmng of mortality dollars. Thus, the NRC proposes that $2000 per nDeterministic health effects in humans can result from general or person-rem be used for routine emissions, kicahzed tissue irradiation causing an amount of cell killing that cannot be compensated for by the prohferation of viable cells.
ne resulting loss of cells can cause severe and clinictlly
{
detectable impairment of function in a tissue or organ. ICRP, op, j
3'1CRP. op. cit., p. 70.
cit., p. 99.
NUREG-1530 12
effects as it relates to the value of any single would increase from $20,000 to $53,000, an individual's life is not appropriate. Rather, its use increase of about a factor of 2.5. Further, under is as an estimate of the value of small reductions unique circumstances the differential could be far in the probability of death for a given population.
more significant. For example, consider a From a practical perspective, the NRC believes proposed regulatory re(luirement that reduces the that regulatory issues involving deterministic probability of severe power reactor accidents in effects and or early fatalities would be very rare, which there is typically a long delay in offsite and can be addressed on a case-specific basis, as release. Since interdiction measures can be very the need arises.
effective !n such cases, the public health and safety benefit based solely on person-rem averted
- 9. IMPLICATIONS OF REVISED would be very small. This however, would l
C mP etely omit the large offsite property,
CONVERSION FACTOR POLICY consequences associated with the mterdiction effort.
The $2000 per person-rem conversion factor discussed in this report reflects a two-fold As part of the NRC's overall reassessment of an increase from the $1000 per person-rem appropriate dollar per person-rem conversion conversion factor that has historically been used factor, the NRC considered the potential impact by the NRC. However, as discussed in Revision 2 of any change in the $1000 per person-rem factor of the NRC's Regulatory Analysis Guidelines, any on current regulations and past regulatory increase in the dollar value of health effects will decisions. In the introductory sections of this now be subject to present worth considerations report, the NRC attempted to characterize the that will decrease the apparent effect of a new, role that the $1000 per person-rem played, and is higher dollar per person rem conversion factor.
expected to exert in future NRC regulatory decisions. First, with regard to regulatory For most regulatory applications, the net effect of decisions concerning radwaste system design these two changes is a wash. For example, the alternatives for nuclear power plants (10 CFR total dollar value of averting one person-rem per Part 50, Appendix I), the NRC staff involved in year over a 20-year timeframe is $20,000 based on those assessments have indicated that increases in an undiscounted $1000 conversion factor policy.
the conversion factor of at least an order of Applying a $2000 conversion factor and assuming magnitude would be necessary to justify any the Guidelines recommendation of a 7-percent reassessment of these decisions. Thus, the real discount rate results in a total dollar value of changes in the conversion factor policy as
$21,200.
considered in this report would not bring into question these past decisions. Second, for all Another change in NRC's conversion factor policy other regulatory applications where $1000 per involves separate quantification of offsite property person-rem has been used by the NRC, the NRC consequences. The NRC recognizes that separate is not proposing that previous decisions be quantification of offsite property will have limited reviewed or updated based on this revised application in regulatory decision making. This is conversion factor policy because in most because offsite property consequences are not an regulatory applications the difference in total expected outcome for most radiological releases, dollar valuation is minimal between these two This is true for occupational doses, routine options. Furthermore, even for regulatory
(
emissions, doses from contaminated sites, and decisions involving safety enhancements for severe most accidental releases from nonpower reactors.
power reactor accidents where the potential However, in those regulatory applications difference in total dollar valuation could be large, involving severe power reactor accident scenarios, the NRC does not propose revisiting these past the difference in total dollar value could be regulatory decisions unless, on a case-specific important. For example, applying the same basis, an unanticipated need to do so arises.
assumptions just stated, but this time including a There are several reasons for this position. First,
$3000 per person-rem allowance for offsite the $1000 per person-rem value has been used by property consequences, the total dollar value of the NRC as a figure of merit, and as one input averting one person-rem per year over 20 years among many in the regulatory decision. Second, 13 NUREG-1530 l
in recognition of the uncertainties inherent in Appendix I (Sec.II)(D) that concerns routine such a figure of merit, NRC staff and emissions for radwaste system designs at power decisionmakers would typically rely more heavily reactors. Regulatory Guide 1.109 contains on other considerations when the break-even guidance on performing dose calculations and the conversion factor was close (within a factor of 5) use of $1000 per person-rem for the dollar to the $1000 per person-rem guide. Finally, it is valuation for radwaste system design alternatives very likely that the cost of making an for power reactors. Also, Regulatory Guide 8.37 improvement to a licensed facility to reduce the suggests the use of $1000 per person-rem in probability of radiation exposure has increased determining ALARA levels for radiological commensurately with the increase in dollar effluent from materials facilities. NUREG-0933, valuation that would result from the changes in "A Prioritization of Generic Safety Issues" utilizes conversion factor policy under consideration in
$1000 per person-rem in assigning priorities and this report, resolving generic safety issues. In other regulatory applications [e.g., regulatory analyses, backfit
- 10. PROCESS TO INCORPORATE analyses, SAMDA analyses, and analyses in TIIE REVISED DOLLAR PER response to 10 CFR 50.34(f)(1)(i)], the NRC PERSON-REM VALUE AS NRC cunently dr ws upon the 1983 "Handpook for Value-Impact Assessment,, as the basis for its POLICY valuation of radiological dose and will correspondingly draw upon the revised Handbook The $2000 per person rem conversion factor and related changes in NRC's conversion factor policy The NRC recognizes that updating the dollar per have been incorporated in " Regulatory Analysis person-rem conversion factor may be appropriate Guidelines of the U.S. Nuclear Regulatory m the future. Consequently, the NRC intends Commission," NUREG/BR-0058, Revision 2, that the dollar per person-rem conversion factor November 1995. In addition, the NRC intends to be subject to periodic review. The dollar per provide more detailed guidance on implementing person-rem conversion factor would only be this policy in NRC's " Regulatory Analysis adjusted if changes in the underlying parameters Technical Evaluation Handbook"(Handbook),
cause the base conversion factor (when rounded which is scheduled to be published in 1996.
to the nearest thousand dollars) to shift up or down by a thousand dollars or more. The NRC's The deletion of all references to the present $1000 update will consider such factors as changes in per person-rem value in existing regulations and the value of the dollar, new research addressing guidance will be considered. The only reference the appropriate value of a statistical life in in the Code of Federal Regulations to the $1000 governmental decisionmaking, or a change in per person-rem value is in 10 CFR Part 50, recommended radiation risk coefficients.
NUREG-1530 14 l
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISS:ON
- 1. REPORT ICJMBER RC 1102, ev r.nd Ptam 32o1, 3202 BIBLIOGRAPHIC DATA SHEET b*-
" *"Y - )
(See instructions on the revers.)
- 2. TITLE AND SUBTITLE Reassessment of NRC's Dollar Per Person-Rem Conversion Factor Policy
- 3. DA1E REPORT PUBLISHED l
MONTH YEAR December 1995
- 6. AUTHORt6)
- 6. TYPE OF REPORT
'Ibchnical
- 7. PERIOD COVERED (inclusive Dates)
- 8. PERFORMING ORGANIZATION - NAME AND ADDRESS (if NRC, provide DivMon, Office or Region, U.S. Nuc' ear Regulatory Commidsu:in, and malling address; if contractor, provide name and malling address.)
Division of Regulatory Applications Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
- 9. SPONSORING ORGANIZAI'lON - NAME AND ADDRESS (if NRC, type "Same as above"; if contractor, provlde NRC Divlakin, Office or Region, U.S. Nuclear Regulatory Commission, and malling address.)
Same as item #8
- 10. SUPPLEMENTARY NOTES 11, ABSTRACT (200 words or less)
The U.S. Nuclear Regulatory Commission (NRC) has completed a review and analysis of its dollar per person-rem conversion factor policy. As a result of this review, the NRC has decided to adopt a $2000 per person-rem conversion factor, subject it to present worth considerations, and limit its scope solely to health effects. This is in contrast to the previous policy and staff practice of using an undiscounted $1000 per person-rem conversion factor that served as a surrogate for all offsite consequences (health and offsite propeny). The policy shift has been incorporated in " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission," NUREG/BR-0058, Revision 2, November 1995.
f
- 12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)
- 13. AVAILABILITY STATEMENT Unlimited
- 14. SECURlW CLASSIFICADON Value-Impact Analysis (This rise)
Regulatory Analysis Radiological Exposure Unclassified Dollar Per Person-rem Conversion Factor (This Report)
Value of Statistical Life Unclassified Health and Safety Benefit
- 15. NUMBER OF PAGES
- 16. PRICE NRC FORM 335 (2-89)
. - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ ~
i I
I Printed
- on recycled Paper l
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