ML20128H557
| ML20128H557 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/1996 |
| From: | Dudley N Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20128H560 | List: |
| References | |
| ACRS-GENERAL, NACNUCLE, NUDOCS 9610090387 | |
| Download: ML20128H557 (6) | |
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NUCt. EAR REGULATORY COMMISSION n
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,1 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS o
WASHINGTON, D. C. 20555
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May 31, 1996 MEMORANDUM T0:
ACRS Member i
FROM:
Noel Dudley, Senior Staff Engineer Nuclear Reactors Branch
SUBJECT:
HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION During the 432nd meeting of the ACRS on June 14, 1996, the Committee is scheduled to hear briefings by and hold discussions with representatives of the NRC staff and the Health Physics Society, and invited experts concerning the health effects of low-levels of ionizing radiation.
The Advisory Comittee on Reactor Waste (ACNW) held a similar session and approved a report to the Commission on the subject.
The ACRS members on the ACRS/ACNW Subcommittee reviewed and comented on the ACNW report. Dr. Powers' two sets of comments regarding the ACNW report are included in the attached status report.
The ACRS us expected to act on the report approved by the ACNW and comented on by the ACRS/ACNW Subcommittee.
Attachment:
Status Report cc (E-Mail) w/o att:
J. Larkins R. Savio S. Duraiswamy ACRS Fellows ACRS Technical Staff i
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 432ND MEETING HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION JUNE 14, 1996 ROCKVILLE, MARYLAND
- TABLE OF CONTENTS -
1 M
- 1. T a bl e o f C ont e n t s....................................................
I
- 2. Proposed Agenda.....................................................
2
- 3. Status Report........................................................
3
- 4. References Minutes dated April 10, 1996, certified by Dr. John Garrick, ACNW, 1
Subject:
Joint ACRS/ACNW Subcommittee Minutes March 26, 1996 Final Draft IB of ACNW Report dated May 17, 1996, from ACRS/ACNW, to Ms.
Shirley Ann Jackson, NRC Chairman,
Subject:
Health Effects of Low-Levels of Ionizing Radiation i
Memorandum dated May 18, 1996, from Dr. Dana Powers, ACRS, to Ms. Roxanne I
I Summers, Technical Secretary,
Subject:
Health Effects of Low-Levels of Ionizing Radiation Memorandum dated May 5,1996, from Dr. Dana Powers, ACRS, to Ms. Roxanne Summers, Technical Secretary,
Subject:
Health Effects of Low-Levels of i
Ionizing Radiation Memorandum dated May 18, 1996, from Dr. Martin Steindler, ACNW, to Dr.
John Garrick, ACNW,
Subject:
Health Effects Letter Letter dated April 1,1996, from Prof. Ronald Kathren, Washington State University, to Dr. Martin Steindler, ACNW,
Subject:
Forwards a Pre-Publication Copy of a report titled, " Pathway to a Paradigm: The Linear Nonthreshold Dose-Response Model in Historical Context" Bioloaical Effects of Low Level Exoosures: Dose-Resoonse Relation, Chapter 11, Positive Health Effects of Low Level Radiation in Human Populations, Lewis Publishers, Boca Raton, FL,1994 American Nuclear Society Transactions for the ANS Annual Meeting, November 1994, pages 36-37 Health Physics Society Newsletter, Volume XXIV Number 3, March 1996
=
Health Physics Society Newsletter, May 1996, pages 5-12 1
l
\\
4 j.
?*
" Effects of Low Dose Radiation" by R.
ry in Health Physics:
The Radiation Protection Journal, Vol. 70, No.6, June 1996
" Current Misinterpretations of the Linear No-Threshold Hypothesis" by V.
Bond et. al., in Health Physics: The Radiation Protection Journal, Vol.
70, No.6, June 1996 Memorandum dated March 24, 1996, from Mr. Jay Carroll, ACRS, to Mr. John Larkins, ACRS Executive Director,
Subject:
3/26/96 ACRS/ACNW Joint Subcommittee Meeting Draft Work Scope dated May 2,1996, by Mr. Carl Paperiello, NMSS,
Subject:
BEIR VII " Scoping Study" Technical Proposal Summary dated February 10, 1995, from National Council on Radiation Protection and Measurements, to NRC,
Subject:
Assessment of Biological Studies Associated with Health Effects of Low-Levels of Ionizing Radiation Coanizant ACRS Member:
R. Seale Coanizant ACRS Staff Enaineer:
N. Dudley 1
),
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 432ND MEETING HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION JUNE 14, 1996 ROCKVILLE, MARYLAND
-AGENDA-i Presentation Lenath Time I.
Introduction - Dr. Robert Seale 5 min 8:35-8:40 a.m.
II.
Staff Presentation - Mr. John Glen, 30 min 8:40-9:10 a.m.
NNSS III. Dr. Myron Pollycove, NdSS 25 min 9:10-9:35 a.m j
IV.
Dr. Goldman, Invited Expert 25 min 9:35-10:00 a.m 2
.),
f.
s ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 432ND MEETING HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION JUNE 14, 1996 ROCKVILLE, MARYLAND
-STATUS REPORT-l PURPOSE The Comittee will hear briefings by and hold discussions with representatives of the NRC staff and the Health Physics Society, and invited experts concerning the health effects of low-levels of ionizing radiation.
BACKGROUND The ACRS/ACNW Subcomittee met on March 26, 1996. Mr. Carl Paperiello, NMSS, Mr.
James Muckerheide, Massachusetts Emergency Management Agency, Prof. Ronald Kathren, National Council for Radiation Protection and Measurements (NCRP), Mr.
Charles Willis, Health Physics Society, and Dr. Myron Pollycove, NMSS, briefed the Subcomittee on the health effects of low-levels of ionizing radiation [pp.
5-14]. The ACNW met on March 26, 1996, heard briefings, held discussions, and 4
approved a report to the Comission on this issue.
ACNW REPORT On May 17, 1996, members of the ACRS, ACNW, and ACRS/ACNW staff participated in a conference call to discuss the ACNW report.
Subsequently, changes were made to the report [pp.15-22] and the ACRS decided to hear a briefing on this subject in order to act on the ACNW report. Dr. Powers provided coments on the report
[pp.23-26]. Dr. Garrick provided coments [pp. 27-28] on the suggested changes to the ACNW report made by Dr. Kress and Dr. Shack.
LINEAR NO-THRESHOLD DOSE-RESPONSE MODEL Prof. Kathren provided the ACNW a Pre-Publication Copy of an article titled,
" Pathway To a Paradigm: The Linear No-Threshold Dose-Response Model in Historical Context." [pp. 29-76] The model was originally used to provide an upper limit estimate of the risk of radiation exposure and was developed by extrapolating data of fatal cancers caused by high radiation doses to low-level doses. Prof.
Kathren stated in his cover letter that a large body of evidence supports response curves other than the linear no-threshold curve.
He cautioned against changing the curve until a "more definitive and less equivocal understanding to the shape of the low dose response curve is obtained," and suggests establishing an interim de minimis annual level between 10 and 1000 pSV (1-100 mrem).
4 j
OBJECTIONS TO THE LINEAR NO-THRESH 0LD DOSE-RESPONSE MODEL For years researchers and health physics professionals have been questioning the no-threshold model and have proposed various changes to the curve.
- Studies, articles, and data on the effects of low-levels of radiation exist and research in this areas is continuing.
Examples of recent activitie:; include:
3
l.
an article by Dr. Pollycove that identifies significant positive health effects associated with low level radiation based on a review of five epidemiologic studies (pp. 77-96],
I the 1994 American Nuclear Society Annual meeting session on the results of l
a nuclear shipyard worker study that refutes the no-threshold model [pp.
97-98),
the March 1996 Health Physics Society position staterr.ent that recommends e
against quantitative estimations of health risk below an individual dose I
of 5 Res in one year and a lifetime dose of 10 Rem in addition to background radiation [pp. 99-101],
the May 1996 Health Physics Society's Newsletter that includes reactions to the Health Physics Society's position paper (pp. 102-109),and the June 1996 Health Physics: The Radiation Protection Journal that includes several papers associated with the linear no-threshold model and the dose effects of low levels of radiation [pp. 110-122].
NRC ACTIVITIES RELATED TO THE NO-THRESHOLD MODEL In a March 23, 1996 memorandum, Mr. Jay Carroll stated that the ACRS and ACNW
" Committees, either individually or jointly, should recommend to the Commission that the agency develop a proactive strategy to settle the question of health l
effects of low level radiation exposure." [pp. 123-124]
On May 2,1996, Mr. Carl Paperiello, NMSS, approved a position paper (pp.125-128), which proposed that the Board on Radiation Effects Research organize a small expert panel to investigate what issues a BEIR VII study might address.
The position paper outlined the issues and areas the expert panel should consider.
On February 10, 1995, the NCRP submitted a technical proposal summary (pp.129-135]totheNRC. The objective of the proposal is to make a critical scientific assessment of all biological studies of the effects of ionizing radiation, and radiobiological theory of effects, in the low-dose and the dose-rate region and then to sumarize these effects.
SUBCOMITTEE ACTION The Committee is expected to act on the report approved by the ACNW.
4 i
ETll lit:
Certified By:
l Issued on: 4/9/96 B. John Garrick gh 4/10/96 JOINT ACRS/ACNW SUBCOMMITTEE MEETING MINUTES MARCH 26, 1996 ROCKVILLE, MARYLAND INTRODUCTION The Joint ACRS/ACNW Subcommittee held a meeting on March 26, 1996, in Room T-2B3, 11545 Rockville Pike, Rockville, Maryland to hear from the NRC staff and representatives of the Massachusetts Emergency Management Agency and the National Council on Radiation Protection and Measurements (NCRP)on three subjects: the activities of the Spent Fuel Project Office, decommissioning, and the health effects of low-level radiation.
The meeting was open to public attendance.
Roxanne Summers was the Designated Federal Official for this meeting.
Several written comments were received from the public but no requests for time to make oral statements.
The meeting was convened by the Subcommittee Chairman at 8:30 a.m. and adjourned at 6:05 p.m. on March 26, 1996.
ATTENDEES L
ACRS Members T.
Kress, Vice Chairman i
R. Seale W.
Shack D. Miller ACNW Members J. Garrick, Subcommittee Chairman M.
Steindler Princioal NRC Sceakers W.
Travers, NMSS C.
Haughney, NMSS M. Weber, NMSS:
S.
Weiss, NRR C.
Trottier, RES J.
Glenn, RES C.
Paperiello, NMSS M.
Pollycove, NMSS C. Willis, NRR Invited Sceakers J. Muckerheide, Massachusetts Emergency Management Agency V i-1nT lo,,
,. e yv uw-
l l
6 for Cperations shortly and would go to the Commission in April.
In responding to Dr. Kress' question regarding the impact of the public comments on the initial draft, Ms. Trottier noted that although a few changes were made to the rule as a result of public comments, she did not consider any of them to be " major."
l-Dr. Garrick asked if any reactor decommissioning had been completed under budget.
It was believed that both Shoreham and Ft. St. Vrain had been decommissioned for less than the anticipated cost level.
Dr. J. Glenn next discussed the rulemaking issues associated with the Radiological Criteria for License Termination (a topic l
previously discussed with the ACNW).
After discussing the background and history of the rule, he noted that 101 comments had been received, representing a broad spectrum.
The general reaction to the issues raised in the Federal Register Notice (15 millirem / year, use of ALARA (as low as reasonably achievable),
restricted release, 100 millirem / year cap, use of Site Specific Advisory Boards] varied, as did the reaction to the general provisions related to use of the Environmental Protection Agency (EPA) drinking water standard and the requirement for a 1000-year post-decommissioning performance analysis calculation.
In response to a question from a Subcommittee member, he stated that he was unable to provide final staff recommendations since the document is in the rulemaking process.
Dr. Glenn indicated, ia response to another question, that the staff would have to look into the question of whether NRC muga comply if the EPA should decide to set a lower standard.
Conclusion The Committee will consider this topic again when the related l
Brookhaven National Laboratory study is. completed, HEALTH EFFECTS OF LOW-LEVFTA OF IONIZING RADIATION
(;Ms. Roxanne Summers was the Designated Federal Official for this portion of the meeting.]
Dr. Garrick began the afternoon portion of the meeting by reading written statements submitted by members of the public and by entering into the record those that were too long to be read aloud.
Dr. Steindler noted that the proceedings of an international conference in 1992 stated that epidemiological l
studies of human populations cannot definitively show the existence of adverse effects of low doses of radiation.
He also mentioned the recent Health Physics Society position that quantification of radiation doses of less than 5 rem per year or 10 rem per lifetime is unwarranted.
Dr. Steindler concluded by
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stating that more studies on this subject are being published and i
the NRC would have to address the issue.
He then introduced Carl l
Paperiello.
NRC Presentation l
Carl Paperiello, Director, NMSS, began by stating that, as a physicist, a scientist, and a health physicist, he did not believe the linear no-threshold theory was valid.
However, as a regulator, he applied that theory every day.
The application of a collective dose is based on that theory and both are pervasive at the NRC, explicitly and implicitly.
Dr. Paperiello pointed out that the 5-rem limit for workers has an empirical basis and that, in fact, no health effects have ever been found in the working population.
Nevertheless, the basic principles of Part 20 are derived from a linear model, and much of the NRC procedures and guidance are derived from 10 CFR Part 20 regulations.
The ALARA principle is a consequence of the linear model.
If it were found to be erroneous, the practical implications would be broad and deep, particularly for nonoccupational exposure, and would affect limits imposed by NRC, j
Department of Energy (DOE), and EPA.
He stated that the costs associated with establishing dose limits in the range of 10 to 20 millirem / year and the methods to demonstrate compliance are resource-intensive for the NRC, and clean-up costs for NRC licensees and DOE facilities are likely to be in the billions of dollars.
This suggests that the theoretical basis for these risk estimates should be reexamined, particularly when comparable limits are not being applied to other, more widespread sources of radiation at ccmparable levels.
He recommended that Subcommittee members study the background documents showing how the linear model grew from a pragmatic hypothesis to what appears to be presented as an unquestioned given scientific fact today.
James Muckarheide
~A-Mr. Muckmehmide, Massachusetts Emergency Management Agency, began by stating that, as a result of a request by the Massachusetts Governor's Advisory Council on Radiation Protection, he became aware of a large body of information on the health effects in terms of human populations and to a lesser extent, radiobiological data.
He referred to a report from 1973 by Norman Frigerio that could not prove the linear model through a rigorous analysis.
Mr. Muckerheide pointed out that parts of Massachusetts contain levels of naturally-occurring radiation that vary by a factor of 100.
Therefore the level of clean-up cf Yankee Rowe, for example, might, if applied to another part of the State, require removing granite from the earth or even removing the State House building.
8 Mr. Muckerheide gave detailed descriptions of a number of other studies (e.g.,
in China, by Sohei Kondo; by Walinder from Sweden; by Jaworowski, of Poland; and by Bernard Cohen and Robley Evans in the United States) that questioned the linear theory based on the fact that high levels of naturally occurring radiation did not produce the expected higher cancer or mortality ratios.
Mr.
Muckerheide also referred to studies of certain human populations exposed to high industrial radiation doses, such as the radium dial painters, who also had lower-than-expected levels of cancer.
He pointed out that a number of biological studies have found a lack of correlation between health effects and the linear model, or even a inverse correlation, and these studies were consistently termed " anomalous."
He traced the fear of radiation to a well known industrialist named Eben Byers who drank large quantities of Radithor (a mineral water containing large amounts of naturally occurring radioisotopes) for three years and died in 1932.
At that point, the Food and Drug Administration took over regulatory authority for radiation and radioactivity and public fear set in.
Mr. Muckerheide concluded by saying that the President of the Health Physics Society, Marvin Goldman, estimated that a trillion dollars is being spent for negligible, if any, public health benefits in clean-up and decommissioning, not to mention the failure to take advantage of nuclear technology.
The regulators, whether state, local, or national, add to the perception of risk when they over-respond to incidents that have no real potential health effects, thus confirming the public's fear.
National Council for Radiation Protection and Measurements (NCRP)
Presentation Ronald Kathren, Chair of the NCRP Scientific Committee SCl-3 that prepared Report 121 on " Principles and Application of Collective Dose in Radiation Protection," stated that the scientific bases for the report included reviewing the existing evidence of genetic and somatic effects, both on a cellular level and on animal and human studies.
The report concluded that the evidence that existed when the report was written "was consistent with a linear, no-threshold response at low doses."
The report also noted, however; that "few experimental studies and essentially no human data can be said to prove or even provide direct support for the concept of collective dose."
Mr. Kathren stated that collective dose really addresses societal risk, not individual risk, and it differentiates between the two.
He discussed four of the nine recommendations made by the report:
e that the concept of collective dose is but one of many for assessing acceptability of a facility or a practice in which there will be an associated radiological exposure;
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9 e
that regulatory limits should not be set in terms of collective dose and that collective dose applications should be limited to < hose stochastic effects and to the dose range in which risk and dose are assumed to be proportional and dose rate-independent; that present and future population uncertainties must be e
considered when predicting effects far into the future; that when the collective dose is smaller than the reciprocal e
of the relevant risk coefficient, it should be noted that the most likely number of excess cancers is zero.
Health Physics Society i
i Mr. Charles Willis, NRR, was asked to give a brief account of the position that the Health Physics Society (HPS) recently published.
Mr. Willis is on the Board of Directors of HPS.
He stated that it is the opinion of HPS that the secondary effects of overprotecting the population from radiation were devastating:
the ten thousand people a year that are' killed by failure to use radiation as a means of pasteurizing food, the impact of research in medicine, etc. are resulting in a' great deal of damage.
The reason for choosing 10 rem per lifetime, while allowing 5 rem per year was simply because the BEIR V report used the 10 rem cutoff, saying it was not clear that an effect from amounts below that could be detected.
On a question by Dr. Steindler, Mr. Willis replied that the 5 rem per year did not assume that someone would have that rate of exposure throughout a lifetime.
The 10 rem per lifetime was also an estimate, not an absolute cutoff.
Dr. Pollvcove, NRC Visitina Medical Fellow Dr. Pollycove began by describing how the damage to DNA is caused l
predominantly by free radicals produced by ionizing radiation but l
is also caused by other basic damage.
The mutations initiate changes in the DNA which then develop, induce cancer, and form tumors.
In the absence of data from the effect of low doses, it I
seemed reasonable to extrapolate and use the linear model.
Where data from low doses showed little or no effect, the tendency was to use only the data points that showed high dose damage and consider the data showing decreased risk as anomalous.
Although early epidemiological studies showed that areas with high l
background radiation had decreased mortality and decreased cancer, compared to low background areas, these studies were discarded because of poor controls, poor public health data and measurements, lack of individual dosimetry, etc..
l However, Dr. Pollycove stated that good data with high l
statistical power and good controls now exist.
He cited a 10-l year study by Johns Hopkins University of 700,000 nuclear l
shipyard workers that demonstrated a decrease in mortality of l
]
I
c 10 those who had received 0.5 rem or more of lifetime exposure, with some exposures as high as 40 or 50 rem. The mortality rate was I
.76 percent that of the control group, with a 95 per~ent confidence limit of.73 to
.79, and there was no increase in l
leukemia, lymphatic or hematopoietic cancers.
The control group of nonshipyard workers was carefully matched with shipyard workers as to age, level of health, etc., and the shipyard I
workers not exposed to radiation had exactly the same mortality rate as those in the outside control population.
Dr. Pollycove also discussed several other studies, including l
Hiroshima and Nagasaki data, Canadian data, and the B.L. Cohen study comparing radon levels in U.S. counties with cancer statistics.
He stated that when these studies have shown a beneficial effect from low doses of ionizing radiation, they have also frequently been dismissed as anomalies.
He then pointed out that the 1994 UNSCEAR report provides extensive documentation of many cellular repair mechanisms, including the immune system, that are stimulated by low-dose l
radiation.
He added that there is no essential difference between the intrinsic damage to DNA as a result of normal cellular metabolism and damage caused by radiation.
Altogether, DNA undergoes about 10,000 mutations per hour per cell, or 240,000' mutations per day per cell.
The additional damage done by a dose of 20 rem would be 400 mutations--a very small addition compared to 240,000.
Dr. Pollycove explained that the body's repair. mechanism handles this level of damage well in most people under the age'of 45 to 50.
Because the ability to repair the 240,000 mutations gradually decreases with age (about 1 percent / year), susceptibility to cancer noticeably increases around 45-50 years.
Dr. Pollycove stated that the repair mechanism is actually boosted by radiation in the lower dose ranges.
The additional incremental damage is very small but the additional stimulatory effect of low-dose radiation causes a decrease in cancer cells, even in those areas not actually irradiated.
This effect can be seen in a Japanese experimental study that consistently showed patients with non-Hodgkin's lymphoma having a 90 percent survival rate using the, low-dose (e.g., 10 rem twice a week) radiation treatment, compared with a survival rate of 35-36 percent with chemotherapy.
The UNCSEAR 1994 report shows many repair mechanisms -- nearly 1,000 references -- similarly affected by low-dose radiation stimulation.
At much higher doses of radiation (e.g.,
200 rem), the cellular repair function is itself impaired and the beneficial effect is negated.
Finally, Dr. Pollycove demonstrated the use of a mathematical model developed by Dr Kenneth Bogen at Lawrence Livermore National Laboratory, called a cytodynamic model based on known biological mechanisms of repair.
This model predicts incidence
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j 11 of cancer as a result of radiation exposure.
The key point emphasized by Dr. Pollycove is that the function to study is not the number of mutations produced but the DNA' repair capacity.
When stimulated at low doses, a beneficial effect on the repair mechanism is obtained, and when impaired at high doses, a detrimental effect occurs.
The key is the repair mechanism, whether it is affected by genetics, aging, or radiation.
It is a consistent picture that can be modeled and adjusted.
Dr. Pollycove concluded by stating that the key to science is a simple statement: if the theory disagrees with the experiment, the theory is wrong.
Discussion During a brief discussion period that followed Dr. Pollycove's presentation, Mr. Kathren stated that there may.or may not be a hormatic effect.
The original linear theory was based on a study of radiation effects on fruit flies in the 1920s by Herman Mueller.
That study and concern about nuclear fallout caused the various groups to use a linear, non-threshold theory because it 1
was a simple, relatively satisfying mathematical relationship, and almost anyone could understand it.
Dr. Steindler summarized the session as follows:
o Carl Paperiello presented the practical constraints under which the NRC operates, which may differ from the science.
e Jim Muckerheide indicated that the evidence against the linear hypothesis was strong and much of it had been suppressed until recently.
Ron Kathren gave a carefully qualified and circumscribed discussion of the collective dose calculations, pointing out that collective doses are societal, not individual.
Dr. kellycove presented data from the UNSCEAR report and e
elseubers that substantiated an understandable mechanism for stimulation of the DNA repair mechanism by radiation.
Dr. Steindler identified the problem of the quality of control populations and the impact of the surrounding environment that could confound the data or at least challenge them.
He noted that what has been discussed at this meeting would not only cause a major shift in essentially all regulations, but would have an enormous economic impact and could probably be implemented only after extensive litigation.
Dr. Steindler posed the following questions:
Would the NRC Commissioners consider that a worthwhile effort?
Do we have a mechanism for determining the
//
12 threshold?
How good is the science?
To the last question, Dr. Pollycove stated that he trusted the l
data in the Nuclear Shipyard Workers Study and the Canadian fluoroscopy study because both studies were designed to prove the opposite, and everything possible was done to avoid getting data that refuted the linear theory.
When such data were obtained in the Canadian study, they were hidden.
Although DOE spent $10 million for the shipyard study, the report was never released.
It was finally published in the Health Physics Newsletter.
Mr. Muckerheide added that there is data not being fairly addressed.
Not all the answers are available because some of the sources of data and sources of work have been interrupted.
Funds have not been made available to disprove the linear theory, although funds are available for studies to prove negative i
effects of radiation exposure.
Mr. Paperiello suggested that while regulators are applying very low dose restrictions on some sources of radiation, other naturally occurring sources are being ignored.
The background radiation dose from exposure to coal ash is ten times natural background, for example.
We use the pronouncements of certain groups such as NCRP because that is all we have.
Dr. Miller stated that NRC regulations should be based on scientific truth.
NRC should be conservative, but when there is sufficient data to reexamine its regulatory basis, NRC should do it and deal with the consequences.
NRC should not regulate in the realm of politics but in the realm of science.
Dr. Kress suggested that the NRC does not deal well with uncertainties, particularly large and unquantified uncertainties.
Dr. Garrick stated that the information on which the public can j
base an opinion is rarely presented in a form that can be easily
)
understood.
The remediation phase of the weapons sites is an ideal situation to try to remedy this, with costs ranging from
$250 billion to a trillion dollars.
The impact of regulating on the linear theory versus the hormesis theory should be quantified in terms of resources, cost, and safety.
Mr. Muckerheide added that there were experiments that could prove the effect of low doses.
Conclusion Drs. Garrick and Steindler would draft a letter to be approved by both Full Committees.
l 1
13 SUBCOMMITTEE COMMENTS AND CONCERNS Scent fuel storace:
Subcommittee Members raised concerns in the following areas:
o regulatory requirements associated with certified transportation casks e
the use of burnup credit in criticality calculations e
the potential for cask corrosion e
the role of risk assessment in the regulatory process the licensing criteria for dual-purpose canisters e
e the maintenance of high-performance systems over long periods of time.
The Subcommittee asked for additional information on :
e staff activities related to the application of burnup 3
credit e
storage of failed fuel elements j
e licensing of multi-purpose casks e
the results of the Brookhaven National Laboratory risk studies.
Decommissionine Subcommittee Members raised concerns in the following areas:
e
. assuring that the spent fuel pool remains functional
[.shilelargecomponentsofthereactorarebeingremoved i
4 e
the need for a code to model the consequences of 1
partial drainage of the pool Health Effects of Low Levels of Ionizine Radiation Subcommittee Members raised concerns in the following areas:
e the quality of control populations and the impact of the surrounding environment that affect the data obtained on health effects of low levels of radiation a
whether the data currently available is adequate and
,9
14 whether it has been fairly addressed e
low dose restrictions are applied to some sources of radiation but not to others e
NRC's regulatory basis should be scientific truth, not political truth e
the NRC does not deal well with uncertainties, particularly those that are large and unquantified e
information for the public is not presented in a form that is easily understood by the general public e
the NRC should quantify the impact of regulating on the linear theory vs. the hormesis theory in terms of resources, cost, and safety.
SUBCOMMITTEE RECOMMENDATIONS e
Spent fuel storage would not be discussed further by the Subcommittee.
The Standard Review Plan would not be recommended for review by a Full Committee at this time, e
Decommissioning would be discussed again when the results of the Brookhaven study were available.
e A report to the Commission on the health effects of low-level radiation would be drafted by Drs. Garrick and Steindler, to be forwarded to both Full Committees for signature, o
The next meeting of the Subcommittee would be held on August 1-2, 1996.
The subjects, in addition to decommissioning, would include the agency's safety analysis philosophy and expert judgment.
Dr. Garrick would remain the Subcommittee Chairman for this year. Dr. Kress would become the Chairman for the following year.
The membership of the Committee would remain the same, but additional members from either Full Committee were welcome to attend and participate fully.
The meeting adjourned at 6:05 p.m. on March 26, 1996.
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