ML20128H580

Discusses Health Effects of low-levels of Ionizing Radiation

ML20128H580
Person / Time
Issue date:	05/05/1996
From:	Powers D NRC
To:	Roxanne Summers NRC
Shared Package
ML20128H560	List: ML20128H557 ML20128H571 ML20128H580 ML20128H583
References
ACRS-GENERAL, NUDOCS 9610090397
Download: ML20128H580 (2)

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Oi/05/98 19:23 F.c 5058210345 2003.

To:

Roxanne Summers Q %Q9.,

em From: Dana A. Powers

Subject:

HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION I have just recently retumed home and have had just a brief opportunity to examine the facsimile transmission of the draft letter entitled " Health Effects of Low levels ofIonizing Radiation". I don't support this letter. My objections to the letter are at several levels: Overall I feel the letter is too narrow of a focus. It seems to treat the issues of radiation as though they were all caused by the shine exposure pathway. In fact, the L".S. Nuclear Regulatory Commission must confront threats of radiation exposure by all pathways. Shine may be the least neublesome of the pathways. Assuredly it is the best understood. Uncertamties in the form and upanke of radioactive materials are huge and largely unquantified. If there is any conservatism in the linear, no threshold assumption, its effects must pale in the face of these tremendous uncertainties. It would seem ther that a far more holistic approach to the issues of radiation exposure ought to be recommended rather than the narrow issue raised in the letter.

He recommendation for a unilcteral NRC examination of the linear, no threshold approximation appears ill advised. Suct an enmmation could have no impact. It is unlikely a unilateral conclusion by NRC researchers could ever be successfully implemented into regulations. The visible, dramatic change away from the traditional linear hypothesis will come about when there is much more of a unanimity among specialists involved in the study of radiation effects. It would seem, then, to me that it would be far better to recommend to the Commissioners that they assure NRC continues to participate in world-wide bodies addressing the issues of radiation exposure. An attempt by NRC to "go it alone" would be sunply a waste of money and esort.

I have no interest in transmitting the letter in anything like its current form to the Commissioners. I would have lengthy, strongly worded added comments to a similar letter transmitted by the ACRS. I think it would be regrettable if the ACNW chose to adopt the !e:ter unilaterally.

9610090397 960531 PDR ACRS GENERAL PDR

05/ts/ss 14:27 FAI 5054210245 3004'.

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- pernysph 10 "... create an independent body.. " What is this? Are we recomunending the creation ofa whole nesy commission? In the current budgetary environment you will act nowhere with this. I thmk there is an Executive Order that now limits the creation ofindependent bodies. I still do not see why the NCRP study cannot be counted on to do everything that is requested in the letter. In fact, they seem to have done it based on the quote earlier in the letter. If l

new evidence has just recently come to light they may want to re-evaluate their position.

- paragraph 10 on page 6: line5/6 i

The sentence seems to imply that anyone with an expertise in dose-response relationships is ipso facto biased. I for one cannot say this is accurate. I do not know how you abjudicate between the supposed biases and well founded, firmly held, defensible positions. The additional!axpertise being proposed here needs to be better defended so it is not attacked as " court stacking." Is it, in i

fact, true that past erammations of the data did not include assessments of the data qualityf? I i

would be stunned if this were the case. It seems to me that all these studies get scrutinized;in l

great detail for errors in design and statistical analysis.

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- paragraph 11 point (a):

j This recommendation seems to say put any old stray dog on the panel as long as he met claim to not have any expertise in dose-response relationships!! I might take it also to mean th4 anyone i

who advocates LNT must be excluded as well. As to point (b), is it true that there waslao experuse in stanstics among those involved in past erammarions of the issue? I woud be surprised.

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- paragraph 12 "..these studies..." Is there to be more than one study?

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- paragraph 6: I believe the anecdotal citation of a few studies is inconsistent;with a call to examine all the data. Furthermore, citation of the particular studies may make the readers thmk a bias exists among the authors of the letter.

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l I hope my comments are of some use in developing a letter that can be finalized. I regret that right now I don't thmk I can formulate specific language on the issue because I'm ju' t noti p

persuaded of the draft position. Even if the position is entirely correct, I'm not sure itsj worthwhile may to remedy the situation this way.

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7 these studies should be to ground regulatory actions on good science, supported by evidence and as independent as possible of extraneous factors.

The Committees believe this topic to be of very great importance and plan to continue their analysis and review of information.

Advisory Committee on Reactor Safeguards Advisory Ccamittee on Nuclear Waste I

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45,/18/98 14:27 F.C 5058310345 9002 9

To:

Roxanne Sanmers Cs,.

ows From: Dana A. Powers

Subject:

HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION 4

Many thanks for the conference phone call on Friday and the revisions proposed by Shack and Kress to the draft letter on low-levels ofionizing radiation. Both have clarified much about the intention of the draft letter for me. I regret that i have to be such a ' pain' on' his matter t

which is apparently far more transparent to other members of the Joint Subcommittee.thad it is to me.

The revised letter does not really address my original points that:

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- radiation damage is more complicated than a simple dose-response relarianship,

- if we are to recommend in this area, our recommendation should adeness the broad range ofissues at stake rather than focusing on one narrow conmoversial topic, and

- it is unlikely that findings of unilateral examinations could be translued into revisions of the existing regulations.

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But, I accept the idea at least in principle that a pie--! approach to the subject may be i appropriate. I feel, however, that the current draft letter does not accurately state the ' oints and p

recommendations that the Joint Subcommittee wants ACRS and ACNW to endorse. I.let me make some specific comments about the letter including editorial comments and perhaps my concems will k~=> apparent:

- pangsph 1: With regard to the last sentence in this paragraph, I do not knoiw that the CommissiammesWs a review and analyze the issue at all. In fact, I think it emerges toward the end of the lemur that sech a review and analysis is the actual recommendation that is being,made.

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- paragraph 3: In the last sentence of this paragraph the issues at hand are related to the emphasis on risk informed regulation. We should remember that in adopting a stance involving risk information the Commission did not abandon the concept of defense in-depth. Their support of risk-based regulation is not especially strong as reflected by the " informed" term. In areas of great uncertamty such as the effects oflow -level dose response relationships defense-in-depth may be a more useful guiding principle than risk. It is, in any case, not obvious to me that the Commission must use its resources to address the issue. Cannot an applicant propose rulemaking and defend a position seeking relief from burdens of the linear hypothesis?

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05/18/96 14:37 FAI $05831034$

, goes.

- paragraph 4; line 6: ".....' independent and special technical investigation....."

The letter does not indicate what the study is to be independent of. It would appear from the letter as now wrttren that the NCRP study is to do exactly what is requested. I now know that it is this study and those who will conduct it that the letter objects to. The rea.;ns for such objections are not ever stated. Similarly, later in the paragraph a call is made for impartial revievi. The letter i

does not say that it is believed that the proposed study by NCRP will not provide such an impanial review. I now know that this is in fact what is believed. The letter does not sate or defend this view, so a reader may well thmk that the planned NCRP study is adequate.

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- paragraph 5; line 3: I thmk this phrase should be reworded. Such an obviously biased phrase really detracts from a letter demanding an impartial exammation of a subject.

.....any study to contribute to the testing of the model." I thmk what is meant here is

..results of any study being used to test the model."

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- paragraph 6: Do you really mean that no healthy worker effect was detected in thb study? If so, I would thmk it a very dubious study indeed. Perhaps what is meant is that the i

investigators were able to correct for the healthy worker effect.

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- paragraph 6 -last sentence: Ihis sounds remm*=hly like Lamarckian biologyj i

-paragraph 7: Why isn't the quote the last word on the subject? I prestigious gnoup of experts has examined the data and hypotheses and published a conclusion it can defend. I know the authors of the letter don't thmk a full examination of the available data was con &cted in an unbiased manner. But, the letter does not say this nor does it say why the experts are believed to be such bad guys. This leads me to thmk the authors just don't like the conclusion and they want to. stack the supreme court with inexperienced people until they can get a vote that go. es their j.

way.

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- paragraph 8:last sentence on page 4 l

Tla logic may not be correct but the conclusion may not be' w argument here and you don't present a basis for conclusion. Is it going to be cost efMtive to go the route you plan? I think the proposed study is a waste of money because it can't result in the change of re@ I know the regulations are a pain in the neck to follow, but I dmnot know that they are especially expensive to follow, nor do I Know that implementing changes with the heavy costs of meraining will be cheap. Ought we have something akin to a regulatory analysis to support our position?

- paragraph 8 on pag'e 5:

Again, I call your attention to the fact that risk is not the only or even the most important basis for regulation. The current approach can be defended on the basis of defense-in-depth just as many other regulatory positions are defended.

paragraph 8 last line on page 5 I believe this is the real recommendation - re.examme the regulatory model.

06/05/98 19:23 FAI 5058310245 2 002 -

t To:

Roxanne Summers Q%C2em From: Dana A. Powers

Subject:

HEALTH EFFECTS OF LOW-LEVELS OF IONIZING RADIATION I have just recently retumed home and have had just a brief opportunity to examme the facsimile transmission of the draft letter entitled " Health Effects of Low-level:mfIonizing Radiation". I don't support this letter. My objections to the letter are at several levels. Overall I feel the letter is too narrow of a focus. It seems to treat the issues of radiation as though they were all caused by the shine exposure pathway. In fact, the L*.S. Nuclear Regulatory Commission must confront threats of radiation exposure by all pathways. Shine may be the least troublesome of the pathways. Assuredly it is the best understood. Uncertainties in the form and upake of radioactive materials are huge and largely unquantified. If there is any conservatism in the linear, no threshold assumption, its effects must pale in the face of these Lemendous uncerninties. It would seem then that a far more holistic approach to the issues of radiation exposure ought to be recommended rather than the narrow issue raised in the letter.

The recommendation for a unilateral NRC examination of the linear, no threshold approximation appears ill-advised. Such an exammation could have no impact. It is unlikely a unilateral conclusion by NRC researchers could ever be successfully implemented into regulations. The visible, dramatic change away from the traditional linear hypothesis will come about when there is much more of a unanimity among specialists involved in the study of radiation effects. It would seem, then, to me that it would be far better to recommend to the Commissioners that they assure NRC continues to participate in world-wide bodies addressing the issues of radiation exposure. An attempt by NRC to "go it alone" would be simply a waste of money and effbrt.

I have no interest in transmitting the letter in anything like its current form to the Commissioners. I would have lengthy, strongly-worded added comments to a similar letter transmitted by the ACRS. I thmk it would be regrettable if the ACNW chose to adopt the le:ter unilaterally.

V 9610090397 960531 PDR ACRS GENERAL PDR

" 3 004*.

05/ts/ss 14:27 FAI 5054210245

- paragraph 10 "... create an independent body..." What is this? Are we recomunending the creation of a whole nes.v commission? In the current budgetary environment you will get nowhere with this. I thmk there is an Executive Order that now limits the creation ofindependent bodies. I still do not see why the NCRP study cannot be counted on to do everything diat is requested in the letter. In fact, they seem to have done it based on the quote earlier in the letter. If I

new evidence has just recently come to light they may want to re-evaluate their position.

- paragraph 10 on page 6: lines /6 The sentence seems to imply tha' anyone with an expertise in dose-response relationships is ipso facto biased. I for one cannot say this is accurate. I do not know how you abjudicate between the supposed biases and well-founded, firmly held, defensible positions. The additional!axpertise being proposed here needs to be better defended so it is not attacked as " court stacking." Is it, in fact, true that past ernminations of the data did not inch'.de assessments of the data quality!? I would be stunned if this were the case. It seems to me that all these studies get scrnWin great detail for errors in design and statistical analysis.

I

- paragraph 11 point (a):

This recommendation seems to say put any old stray dog on the panel as long as he oast claim to not have any expertise in dose-response relationships!! I might take it also to mean th4 an'yone who advocates LNT must be excluded as well. /a to point (b), is it true that there wasino expertise in statistics among those involved in past erammarions of the issue? I would be surprised.

- paragraph 12 "...these studies..." Is there to be more than one study?

- paragraph 6: I believe the anecdotal citation of a few studies is inconsistent;with a call to examine all the data. Furthermore, citation of the particular studies may make the readers think a bias exists among the authors of the letter ji l!

I hope my comments are of some use in developing a letter that can be finalized. I regret that right now I don't think I can formulate specific language on the issue because I'm ju): noti persuaded. of the draA position. Even if the position is entirely correct, I'm not sure ity worthwhile tetry to remedy the situation this way.

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' ' ' t'AY-18-1996 23:07 STEINDLER 7082413750 708 241 3750 P.01 FHX COVER SHEET DATE: S/18/%

PRIORrIY: HIGH/lGDIUlW/ ROUTINE TIME: 10:41 PM PAGES INCLUDING COVER:

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l TO:

B. John Garrick

@ FAX 714 833 2085 Noel Dudley

@ FAX 301415 5589 cc: Roxanne Surnmers FROM: MARTIN J. STEINDLER

[

Phone (H) 708 241 3750*

Phone (O) 708 252 4314 Fax (O) 708 252 5528 FAX.....(H) 708 2413750#

MESSAGE:

Noel, John; Regarding version ' Final Draft IB, 5/17/96' of the Maalth F% cts letter faxed to me by Noel, please note the following.

1. Page 4, perhaps the terms ' logic' might be better ' conclusion'. The softening of the sentence is ok but there is a loss of ' punch'.

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2. Page 5,1st full para.: I don't understand why ' scientifically-based' has been rernoved. The term ' appropriate' could very well refer to one that is incorrect but conservative, which is exactly what we now have and want to reexamine. I urge retention of what was there but I won't object absolutely if this is all that stands in the way of getting the letter out.

The rest of the changes are ok but strike me as not substantive. I urge that any future messages be handled in accord with information left with Rkh Major or John Garrick, regarding where and how I can be reached.

@ Address is 1524 Chicago Ave, Downers Grove IL 60515-3450. Fax number is as the phone munber.

1. No unattended reception. Call and talk to us before sending.

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